Privacy Policy

INTRODUCTION

This website and policy are provided and maintained by Trialbee AB (Trialbee), corporate registration number 556814-3019, with its principal place of business at Södra Tullgatan 3, SE-211 40 Malmö, Sweden.

This privacy policy informs you of the principles governing our use of the personal data which you submitted, or we obtained by you via a website or by registering as a user of the online services which we provide.

Trialbee’s approach to protecting personal data worldwide recognizes various jurisdictions and legal systems will apply:

To the rest of world, different legal rules apply, and we will be using and protecting personal data in accordance with rules operating in the European Economic Area (EEA) which has adopted the General Data Protection Regulation (GDPR). If you do not agree to the terms of this privacy policy, you should not access or use Trialbee’s website.
In the United States of America, the Federal Trade Commission has authority over our compliance when applicable regarding personal data. If you do not agree to the terms of this privacy policy, you should not access or use Trialbee’s website.

PURPOSE
DEFINITIONS AND ACCRONYMS
DATA WE COLLECT ABOUT YOU
HOW YOUR PERSONAL DATA IS COLLECTED
HOW WE USE AND DISCLOSE YOUR DATA
DATA PROCESSING
TRANSFER OF PERSONAL DATA
DATA SECURITY
DATA RETENTION
YOUR DATA PRIVACY RIGHTS UNDER GDPR AND UK PRIVACY
YOUR DATA PRIVACY US
CHILDREN
OTHER INFORMATION

1. PURPOSE

This privacy policy describes how Trialbee collects, uses, processes, and protects your personal data and informs the choices available to you regarding how you can manage your personal data.

We recommend that you read this privacy policy with any other privacy policy or processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

This privacy policy identifies Trialbee as “we,” “us” or “our” and is mentioned in this privacy policy, we are responsible for processing your data.

1.1. Processor

We have a data protection officer who is responsible for dealing with questions, and/or requests in relation to this privacy policy. If you have any questions about this privacy policy, including requests to exercise your legal rights, please contact the data protection officer using the contact details below.

1.2. CONTACT DETAILS

Trialbee’s contact details for privacy rights questions and requests are:

Full name of legal entity: Trialbee AB, Data Privacy Officer

Email Address: [email protected]

1.3. COMPLAINTS

You have the right to make a complaint at any time to the relevant supervisory authority in the country where you reside.

We would however appreciate the chance to deal with your concerns before you approach one of the national supervisory authorities, so please contact us in the first instance at [email protected].

To find more about this right and to locate the appropriate Data Privacy Authority, go to the following:

If you reside in Europe, then contact the European Commission website: https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights_en
If you reside in the UK, go to the Information Commissioner’s Office (ICO) website: ico.org.uk
If you reside in the United States, you may contact the US Federal Trade Commission at: https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc
If you reside in the Asia Pacific area, you may contact the Asia Pacific Authorities (APPA) website: https://www.appaforum.org/contact/

1.4. CHANGES TO PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES IN YOUR PERSONAL DATA

We reserve the right to amend this privacy policy and will notify you by updating this notice, so please check this privacy policy from time to time. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by contacting us at [email protected].

1.5. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. DEFINITIONS AND ACCRONYMS

Anonymized: type of information sanitization whose intent is privacy protection. It is the process of removing personally identifiable information from data sets, so that the person’s identity becomes anonymous.
EEA: European Economic Area
GDPR: General Data Protection Regulation
CCPA: United States California Consumer Privacy Act
VCDPA: United States Virginia Consumer Data Protection Act
CPA: United States Colorado Privacy Act
CPRA: United States California Privacy Rights Act
CTDPA: United States Connecticut Data Privacy Act
UCPA: United States Utah Consumer Privacy Act
ICO: United Kingdom Information Commissioner’s Office
PII: Personal Identifiable Information. This is any data that could be used to identify you as an individual.
PHI: Protected Health Information. This is any healthcare data that could be used to identify you as an individual.

Third Parties:

Service providers acting as processors and who provide services to us.
Our partners who provide complimentary support and services for the purpose of recruiting for the clinical study.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services to us.
Regulators and other state authorities acting as processors or joint controllers in any jurisdiction in which we are operating and who require reporting of processing activities in certain circumstances.

Covered Entity: an institution, organization or other entity that is subject to the rules of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in the United States. Covered Entities include: (i) a health plan, (ii) a healthcare clearinghouse and, (iii) a healthcare provider which transmit any personal identifiable health information in electronic form in connection with a transaction covered by HIPAA.

PIHI: Personal Identifiable Health Information and is any information including demographic information collected from an individual that:

relates to (a) the past, present, or future physical or mental health or condition of an individual; (b) the provision of healthcare to an individual; or (c) the past, present, or future payment for the provision of healthcare to the individual; and
Identifies the individual or there is a reasonable basis to believe it can be used to identify the individual; and
PIHI does not include education records or medical records covered by the Family Education Rights and Privacy Act or employment records held by Trialbee in its role as an employer.

Personal Information: any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

3. DATA WE COLLECT ABOUT YOU

Like many commercial organizations we monitor the use of this website by collecting aggregate information using cookies.

Typically, we collect information about the number of visitors to the website, to each web page and the originating domain name of the visitor’s Internet Service Provider.

This information is used to understand the visitor’s use of the website and may be shared with our affiliates and/or other third parties. We have no means reasonably available to us to ascertain the identity of individual users from aggregate information.

We may collect, use, and share Aggregated Data such as general statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We may also collect categories of personal data about you which are grouped as follows:

Monitor the patterns of people who visit the website.
Site usage information which helps us improve the design and layout of our website, and to personalize your experience by tailoring the content you see thus optimizing your user experience.
Identity Data includes first name, given name, last name, or similar identifier, gender, race, or ethnicity (this would only be collected when an approved clinical research study protocol has a diversity and inclusion requirement).
Contact Data includes ZIP code/ Postal code, email address, and telephone numbers.
Transactional Data includes details of products and services you have received or purchased to help us identified other people who the clinical research study may be suitable for. This includes and not limited to; web-forms that collect data, contact information, or a survey.
Technical Data includes Internet Protocol (“IP”) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology that is on the device you use to access this website.
Usage Data includes information about how you use our website, and / or services for the purposes of determining your suitability for the clinical research study.
Communications Data includes your preferences in receiving communication from us for the purpose of determining your suitability for the clinical research study.
Health Data includes information in relation to aspects of your health conditions(s), medical history and treatment to help us determine your suitability for the clinical research study organized by our clients.

We will ask you to provide us with sensitive personal data, for example, information relating to your physical or mental health or condition, but only if you voluntarily provide us with this information and consent to our collection of such information for the purposes set out in this Privacy Policy and any specific privacy statement provided.

We may also obtain information about your opinions if, for example, you send us feedback, or ask us questions.

We may also, occasionally, receive anonymized information about you from other sources which we will use to help us better support recruitment for the study.

4. HOW YOUR PERSONAL DATA IS COLLECTED

We use various methods to collect the categories of data described above through but not limited to:

Data Interactions. You may have given your personal data by filling in forms or by corresponding with us by phone, and email or otherwise. This includes personal data you provide when you apply or register online or request information.

Automated Technologies or Interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions or patterns. We collect this personal data by using cookies, log files, and other similar technologies. We may also receive technical data about you from other websites that you visit employing our cookies. This aggregate data gives a “macro-view” of visitor traffic patterns and provides insight to what sections of the website users visit the most. None of this information is linked to any personal information. We collect, and log technical data as described in section 3 above Data We Collect About You.

Third-parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:

Analytics providers such as Google, Piwik Pro
Advertising Networks
Search Information Providers
Portals

5. HOW WE USE AND DISCLOSE YOUR DATA

We will use your personal data in the following circumstances:

To support services to our client for the purposes of recruiting into a clinical research study.
To perform obligations to you, our clients, or as required by law.
Where we need to comply with a legal or regulatory obligation.
In the EEA, when necessary for our legitimate interests or those of a third party, and your interests and fundamental rights do not override those interests.
To support our work with our partners, who provide complimentary support and services for the purpose of recruiting for the clinical study.

Trialbee will not share your personal data unless:

We have informed you otherwise and obtained your permission, or
There is a legal or regulatory obligation, or
The law forces us to share the data.

In relation to using your personal data as described above, we will only do so where (i) we have your consent or (ii) you are an existing recipient of these communications. You have the right to withdraw consent at any time by contacting us via email at [email protected].

Declaration of Consent

Trialbee study websites will describe how we plan to use your data. This consent area usually appears before or after an online questionnaire, but always before you submit any personal data to us.

5.1. WHY AND HOW WE USE YOUR DATA

The matrix below describes the ways we plan to use your personal data, the legal basis, and identifies the legitimate interests where appropriate.

Note, that we may process your personal data for more than one lawful ground depending on the specific purposes, this has been set out in the table below:

How we plan to use your data:	Category(ies) of data	Lawful basis for processing, including legitimate interest
To complete your registration request.	Identity Data Contact Data	Performance of a contract with you or upon your request/registration submission.
To process and deliver services.	Identity Data Contact Data Transactional Marketing and Communications Data	Performance of a contract with you. Necessary for our legitimate interest.
To manage our relationship with you which could include: Notifying you about changes to our terms or privacy policy. Asking you to leave a review or take a survey/questionnaire.	Identity Data Contact Data Profile Marketing and Communications Data	Performance of a contract with you. Necessary for our legitimate interest, to keep our records updated and to help us monitor your interactions with us and ensure we deliver a satisfactory experience/service.
To consider whether you are eligible/suitable for participating in a clinical research study, related to a clinical investigation, or clinical support program sponsored by our clients.	Identity Data Contact Data Health Data	Necessary for scientific research purposes when participating in the recruitment process to be enrolled in a clinical research study sponsored or managed by one of our clients. Necessary for our client’s legitimate interests in conducting and completing a clinical research study.
To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.	Identity Data Contact Data Technical Data	Necessary for our legitimate interests, for running our business, provision of administration, IT services and network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise. Necessary to comply with a legal obligation. Necessary to resolve disputes.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity Data Contact Data Profile Usage Data Marketing and Communications Data Technical Data	Necessary for our legitimate interests, to study how you use our services, to support the recruitment process in relation to the clinical research study, to develop them, and to inform our marketing strategy.
To use data analytics to improve our website, services, marketing, and awareness about the clinical research study, manage your, experience with us and our services, and to provide an audit record for consent.	Technical Data Usage Data	Necessary for our legitimate interests, to define other people similar to you who may be interested in the clinical research study we are supporting with our services, to keep our website updated and relevant, to develop our business, and inform our marketing strategy.
To make recommendations to you about studies or opportunities to participate in studies, that may be of interest.	Identity Data Contact Data Technical Data Usage Data Profile	Necessary for our legitimate interests, to develop and provide our services. Necessary for our client’s legitimate interests in enrolling, conducting and completing a clinical research study.
To comply with legal obligations, including government investigations, subpoenas, or other legal process or as otherwise necessary to prevent physical or financial harm or to prevent crime and fraud.	Identity Data Contact Data Technical Data Usage Data Profile	Necessary for our legitimate interests, to protect our business, employees, you, and the public. Necessary to comply with a legal obligation. Necessary to resolve disputes.

5.2. DISCLOSING INFORMATION TO THIRD PARTIES

Trialbee may share your personal data with trusted clients and service providers where needed, as set out below for the purposes set out in the table in section 5.1 Why and how we use your data.

Clinical research centres, sites, or clinics who are conducting the clinical research study that you submitted your information for.
Third party sub-contractors who provide services for us and/or help to provide services to you.
Third party sub-contractors who may transfer, or merge.
We may disclose personal information to law enforcement, government authorities, or otherwise in response to a legal subpoena or process as required by applicable law or in the circumstances involving the possibility of physical or financial harm, fraud, or crime.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes, unless you have consented to this, and only permit them to process your personal data for the specified purposes and in accordance with our instructions. Please note that Trialbee is not responsible for any personal data that you provide directly to a third party, such as social media networks. For information on how these third parties process your personal data, please see the respective third party’s privacy policy.

We do not sell or lease your personal data to any third party. Our use and disclosure of PHI is limited to the minimum amount needed to accomplish the intended purpose of the specific clinical research study and is used in relation to pre-qualification activities for such clinical research studies. This includes using questionnaires that only ask questions related/associated to the specific clinical research study as specified in approved protocols. Your information will not be disclosed unless we have clear consent from you to do so.

5.3. USE OF HEALTH DATA IN THE UNITED STATES

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and subsequent regulations published by the Department of Health and Human Services (“DHHS”) impose restrictions on other organizations (Covered Entities) which may be covered under HIPAA with respect to your relationship with Trialbee. Trialbee may, in providing recruitment services for one of these organizations, be required to comply with certain aspects of HIPAA in their conduct of human subject research activities.

Although Trialbee is not a Covered Entity as defined in the HIPAA privacy regulations, our policies, and procedures, which govern the privacy rights of research participants included in this privacy policy, are compatible with those required by HIPAA for Covered Entities and will become standard for research activities involving PIHI.

All PIHI data collected by Trialbee in connection with clinical study recruitment is captured electronically and transmitted through a secure network connection to a secure database. Trialbee’s data security policies are consistent with Good Clinical Practices, HIPAA, and GDPR standards.

5.4. OPTING OUT OF COMMUNICATIONS FROM TRIALBEE

You can opt-out and request us to stop sending you information, and/or reminders, for which you have consented to receiving, at any time by contacting us at [email protected].

Opting out of receiving information, and or reminders, will not impact the personal data provided to us.

5.5. USE OF COOKIES

We use cookies and other technologies to improve our website to record user-specific information on webpages which are accessed or visited. The use of cookies allows a better user experience when visitors return to the website.

In addition to using strictly necessary cookies, which are those that allow the website to open and function, we use cookies:

to learn how our website is used and how it performs, including cross-site statistics,
to provide you with additional functionalities and personalization,
to provide you social media interactions, and
for targeting and marketing purposes.

You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of the website may become inaccessible or not function optimally. With most types of internet browsers, you can erase cookies from your computer’s hard drive, block all cookies, block specific kinds of cookies, or even receive a warning before a cookie is placed on your system. Refer to your browser instructions or help button to learn more about cookies.

5.5.1. COOKIE PRIVACY PREFERENCES AND CONSENT

To ensure we are compliant with local regulations we use a cookie pop-up. This automatically updates to ensure it reflect the regulations in your location. You may have the chose to accept all cookies, accept functional or necessary cookies, or reject / deny all cookies. If you consent to cookies, those cookies will be stored on your computer, tablet, or smartphone. If you opt-out of cookies, this may impact the functionality of the website you are trying to view.

5.5.2. USE OF DATA FOR MARKETING

We do not sell, lease, or transfer your personal data to any non-affiliated entity for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent. We may use third party companies who partner with us to provide complimentary support and services to Trialbee’s digital marketing for the purpose of recruiting for the clinical study. These companies may use data about your visits to this and other websites to measure advertising effectiveness and to provide advertisements about goods and services that may be of interest to you. If you would like more information about this, please contacting us at [email protected].

5.5.3. TRIALBEE COOKIE STATEMENT

We use cookies to make the website work optimally. Cookies are used to save your settings, analyse how you browse, and customize content to suit you. They are also used to promote our services, and some cookies come from partners we work with.

6. DATA PROCESSING

Trialbee AB, company registration number 556814-3019, address: Södra Tullgatan 3, 211 40 Malmö, Sweden, [email protected], gathers, processes, stores, and shares personal data on behalf of the Controller for clinical research recruitment.

The Controller (the research study Sponsor) intends to conduct a clinical study to determine the safety and effectiveness of an investigational product. With regards to the processing of your personal data during the application process the Controller is the data controller responsible for processing your personal data in accordance with applicable data protection legislation. However, the Controller has assigned Trialbee AB (“Trialbee”) the task of processing your application for the study.

If you are interested in participating in the study Trialbee will ask you, on behalf of the Controller, to provide certain information about yourself to process your application for the study. This allows us to evaluate your potential eligibility for the study and to contact you during the application process. The information we intend to collect are your name, telephone number(s), e-mail address, ZIP code / postal code and answers to questions we ask you for determining eligibility. These answers may include information about your health. Health information is only used for the purposes of determining your eligibility for the clinical research study. This information will not be shared with the sponsor or the client who has requested our services for the purpose of recruiting into the clinical research study. Please see section 5.2 for who we may share your data with, your data will only be shared if you provide consent.

Information about you is stored in Trialbee’s system until the clinical study recruitment is completed, Trialbee’s services related to the study are complete or until you request that the data is deleted by emailing [email protected], whichever occurs first.

You can at any time withdraw your consent to the Controller’s processing of your personal data for the purposes of evaluating your application by contacting Trialbee at [email protected]. If you withdraw your consent, then Trialbee will stop processing your personal data. If your information has been shared with a trusted third party, we will notify them of your withdrawal. If you have chosen to participate in the clinical research study and have signed the Informed Consent Form (“ICF”), you will need to communicate your request to withdraw your personal data with the research centre.

For further information about the Trialbee’s processing of your personal data on the Controller’s behalf and your rights according to applicable data protection legislation, see section 6.1 Data Subject Information.

6.1. DATA SUBJECT INFORMATION

Information about Trialbee’s processing of your personal data on behalf of the Controller to register your information for this clinical research study is listed below.

Ipsen Pharma SAS (the Controller)

A Limited Company registered in France under Registration Number 308197185 Nanterre.
65, quai Georges Gorse ADDRESS 2
Boulogne-Billancourt – 92100 France

Relevant point of contact

Trialbee AB (“Trialbee”) (the Processor)
Company registration no. 556814-3019
Södra Tullgatan 3
211 40, Malmö
Sweden

Categories of personal data

Name, telephone number(s), e-mail address, ZIP code / Postal code, gender, age, and answers to questions we ask you for determining eligibility. These answers may include information about your health.

Purpose of processing

To administer patient recruitment to the clinical study. This includes administering your registration for the study by evaluating your eligibility and contacting you during the pre-qualification process.

Legal basis for processing

Your consent.

Legal basis for processing personal data regarding your health

Your consent.

Categories of recipients

The personal data will be processed by Trialbee on behalf of the Controller. Your personal data may also be shared with those involved with processing your application on behalf of Trialbee, i.e., medical professionals acting on behalf of the Controller and/or engaged by Trialbee on behalf of the Controller and/or staff from a study clinic (also known as a research centre, or site) who may contact you to determine study eligibility. These will be the only parties with access to this information.

Retention period

Trialbee will retain your personal data, on behalf of the Controller, until the clinical study recruitment is completed, Trialbee’s services related to the study are complete or until you request that the data is deleted, whichever occurs first.

Your rights

In accordance with applicable data protection legislation, you have a right to request access to or rectification of your personal data. Further, and to the extent set out in applicable data protection legislation, you may request erasure of personal data or restriction of the processing of your personal data. Under certain circumstances, you also have a right to object to processing as well as the right to data portability in accordance with applicable data protection legislation. If you want to exercise any of the above-mentioned rights, please do not hesitate to contact Trialbee (see contact details above). Where the processing of your personal data is based on your consent, you can withdraw such consent at any time by contacting either the Controller or Trialbee. Should you dissatisfied with our processing of your personal data, please let us know, and we will do our best to meet your complaints. Your integrity is important to us, and we always strive to protect and secure your personal data in the best viable way. Should we nevertheless, in your opinion, fail in this ambition, please note that you have the right to lodge a complaint at any time to the relevant supervisory authority in the country where you reside.

7. TRANSFER OF PERSONAL DATA

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when transferred to our affiliates or third parties in other countries.

8. DATA SECURITY

We and our third-party hosting partners have put in place the appropriate security measures to prevent your personal data from being lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data with least privilege to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have procedures in place to deal with suspected data security breaches and will notify you and any applicable regulators of breaches in accordance with relevant legal requirements.

9. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for persona data, we consider the amount, nature, and sensitivity of the personal data, the potential risk or harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, along with the applicable legal requirements.

We also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. YOUR DATA PRIVACY RIGHTS UNDER GDPR AND UK PRIVACY

Under certain circumstances in the EEA and UK, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

In the EEA, you have the right to make a complaint at any time to the relevant national supervisory authority. For example, in the UK this would be the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach one of the national supervisory authorities so, please contact us in the first instance.

A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10.1. NO FEE REQUIRED

You will not have to pay a fee to access your personal data or to exercise any of the other rights above.

11. YOUR DATA PRIVACY RIGHTS US

For US Patients: The protected health information (PHI) you disclose to Trialbee, while no longer protected by US federal privacy laws, will be protected by Trialbee by using and disclosing it only for the purposes described in the Privacy Policy or as otherwise required by applicable law.

You may be entitled to certain rights with respect to your Personal Information under the law of your state of residence. Please refer to our state specific privacy policy for more details. We reserve the right to amend the state specific privacy policy and will notify you by updating its notice, so please check the policy from time to time.

12. CHILDREN

Our website is directed and intended to be used by an adult audience (such as individuals interested in clinical research and healthcare professionals). We do not knowingly collect information from children but may collect information from a parent or guardian of a child under the age of 18 years old, who are interested in finding out about the suitability of a clinical research study for their child. Please do not use this website if you are under eighteen.

If you are a parent or guardian of a child under the age of 18 years old who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by emailing us at [email protected].

13. OTHER INFORMATION

You should note that if our business (or any part of it) is sold or transferred at any time, the information we hold may form part of the assets transferred although it will still only be used in accordance with this Privacy Policy.

For quality control and training purposes, we may monitor or record your communications with us.

Consent to Share Information

Your personal information and your answers to the study questions are only used for the purposes of determining if the clinical research study may be suitable for you. You can at any time withdraw your consent and have your personal data removed by contacting [email protected].