Last Revised: 02/13/2020
It does not apply to information collected:
If the changes have minor, if any, consequences, they will take effect 7 days after we notify you. Substantial changes will be effective 30 days after we initially posted or sent you the notice. If we need to adapt the policy to new legal requirements, the new policy will become effective immediately or as required by law.
Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy, you can choose not to accept it and terminate your use of the Services. Continuing to use the Website after the new policy takes effect means that you agree to the new policy.
Information That We Collect
We collect certain information about you to provide you with the ClinEdge Services and use such information to meet legal, statutory and contractual obligations.
When you use the Services, we collect certain information about you (“Information”) in the following forms:
How We Collect Your Information
We collect Information in the following ways:
From time to time, we will change our analytics and marketing service providers and will provide additional information about these services when we update this policy.
Do Not Track
Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. Our Services do not respond to Do Not Track (DNT) signals.
How We Use Your Information
The purposes and reasons for processing your Personal Information are detailed below:
Where you have consented to us providing you with information and/or marketing, you are free to withdraw this consent at any time and unsubscribe from our mailing lists or newsletters, by sending an opt-out request to: https://clin-edge.com/data-subject-requests-gdpr/.
Transfer of Information Outside your Territory
We will store and process your Personal Information in the United States, on our cloud-based services’ sites. From time to time, we will make operational decisions which will have an impact on the sites in which we maintain personally identifiable information. We make sure that our data hosting service providers provide us with adequate confidentiality and security commitments.
If you are a resident in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.
To the extent required under EU data protection laws, transfer of personal data to our US hosting service providers is governed by our hosting services’ EU-US Privacy Shield certification.
ClinEdge certifies that it adheres to the relevant Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability in fulfilling its relevant responsibilities for the receipt, processing, storage, and reporting of data.
Sharing Your Information
The ways in which we share your Information include the following:
Your Controls and Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information, including the right to request access to the Personal Information we hold about you and that we amend, If you find that your Personal Information is not accurate, complete or up-to-date, or delete it.
At any time, you can exercise your following opt-out options:
At any time following your opt-out request, we can remove or de-identify your Personal Information altogether and request that you stop using the Website.
You may exercise your controls and choices, or request access to your Personal Information, by modifying your profile or by contacting us at firstname.lastname@example.org or following instructions provided in communications sent to you.
We will need to ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate the Personal Information that you request to access.
We can delete your Personal Information, by removing any identifying information and transforming personally identifiable information that relates to you into anonymized information.
Please be aware that, if you do not allow us to collect Personal Information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us at email@example.com.
Data Security and Integrity
The security, integrity and confidentiality of your Personal Information are important to us.
We have implemented technical, administrative, and physical security measures that are designed to protect your Personal Information from unauthorized access, disclosure, use and, modification, including: SSL, TLS, encryption, pseudonymization, restricted access, two factor authentication, firewalls and anti-virus/malware.
From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
The safety and security of your Personal Information also depends on you. Where we have given you (or when you have chosen) a username or password for access to certain parts of our Website, you are responsible for keeping this password confidential. Do not share your password with anyone.
How Long We Keep Your Personal Information
ClinEdge retains Personal Information as needed to comply with our legal obligations and we have strict review and retention policies in place to meet these obligations.
We are required in some cases to keep your Personal Information (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
If we retain your Personal Information for any legitimate business purpose other than to provide the Services, we will make efforts to limit the access to such information and keep the retention time to a minimum.
We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.
Children Under 13
Most of the services available on this Website are intended for persons 18 years of age and older. Any individual who requires information about any of our services, must be 18 and over.
We will not knowingly collect, use or disclose Personal Information from a minor under the age of 18, without obtaining prior consent from a person with parental responsibility through direct off-line contact.
We will provide the parent or guardian with notice of the specific types of Personal Information being collected from the minor and the opportunity to object to any further collection, use, and storage of such information.
We abide by the laws designed to protect children. If we become aware that we have unknowingly collected Personal Information from persons under the age of 13, we will make commercially reasonable efforts to delete such information from our database.
If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us at firstname.lastname@example.org to request it be deleted.
Your California Privacy Rights
If you are a user of this service and a California resident under the age of 18, you may request to have your Personal Information removed by calling us at 857-496-0054 or emailing us at email@example.com. In certain situations, content or Personal Information cannot be removed.
As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose information for such third parties’ marketing purposes and the categories of information we may disclose. See Contact Us below.
Your Rights (EU & Canadian Residents Only)
Our processing of your personal data is based on following lawful grounds:
You have the right to access any personal information that ClinEdge processes about you and to request information about:
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.
These requests can be made online: https://clin-edge.com/data-subject-requests-gdpr/. Or by mail: 108 Myrtle St, Quincy, MA, 02171 Attention: DPO
If we receive a request from you to exercise any of the above rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.
Sharing and Disclosing Your Personal Information We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. ClinEdge uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws accordance with Article 28 GDPR and any other appropriate confidentiality and security measures. We do not share your personal information with Sierra, the study sponsor.
Accessing or Correcting Your Information
You may send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. These requests can also be made online: https://clin-edge.com/data-subject-requests-gdpr/. Or by mail: 108 Myrtle St, Quincy, MA, 02171 Attention: DPO
If we need to delete your personal data following your request, it will take some time until we completely delete residual copies of your personal data from our active servers and from our backup systems.