Privacy Policy

Last Revised: 02/13/2020

 

Welcome to the Privacy Policy for the MOMENTUM study website (the “Website”). Sierra Oncology has partnered with ClinEdge (“ClinEdge,” “we” or “us”) to assist with certain services for the MOMENTUM study, including Study Branding, Collateral, Website Development, Enrollment, Advertising and hosting the MOMENTUM study website (the “ClinEdge Services”).

 

This Privacy Policy describes how ClinEdge collects, uses and discloses information about users of the Website, content, applications, services, tools and features (collectively the “Services”).  Please read this Privacy Policy carefully.

 

This Privacy Policy applies to information we collect:

  • On the Website or through forms on the Website
  • In email, text, and other electronic messages between you and the Website

 

It does not apply to information collected:

  • by us, offline or through any other means, including information collected through any other electronic means or any other Website specified by us or a third party;
  • by any other third party, including through any application or content (including advertising) that may link to or be available from the Website.

 

YOU ALSO ACKNOWLEDGE THAT ClinEdge WILL PERIODICALLY CHANGE, MODIFY, ADD OR REMOVE OR OTHERWISE UPDATE THIS PRIVACY POLICY AT ITS DISCRETION, IN WHICH CASE WE WILL NOTIFY YOU BY EMAIL AT THE LAST EMAIL ADDRESS YOU PROVIDED US, BY POSTING NOTICE OF SUCH CHANGES ON THE WEBSITE, OR BY OTHER MEANS, CONSISTENT WITH APPLICABLE LAW .

 

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.

 

We will not use information collected about you for any other purpose without your consent, other than for the purposes specified in this Privacy Policy or where there is a legal requirement to do so.

 

When you use the Services, we collect certain information about you (“Information”) in the following forms:

 

  • “Personally Identifiable Information,” which means information that identifies you (either directly or indirectly), including:
  • Full Name
  • Age
  • Zip Code/Postal Code
  • Personal Email
  • Telephone Number
  • Health/Medical Information
  • internet protocol (IP) addresses
  • Demographic and Interests (via Google Analytics)
  • Aggregate Information,” which means information that does not directly or indirectly identify, and cannot reasonably be used to identify, you.

 

How We Collect Your Information

 

We collect Information in the following ways:

 

  • Use the Services: we collect Personal Information that you provide to us when you –
    • fill out a form to be considered for potential study opportunities;
    • input information into the Services;
    • create user generated content;
    • request products, services or information from us;
    • participate in public forums or other activities through the Services; or,
    • otherwise interact with us or the Services.
  • Web Analytics and Marketing Automation: we use third parties’ analytics tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content. We also use third party marketing automation tools to help us with our marketing efforts.

 

The privacy practices of the third-party company is subject to their own privacy policy. Please read these policies at: and http://www.google.com/intl/en/policies/privacy/.

 

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.

 

These service providers use cookies, pixel tags or other technologies to collect and store Information, such as time of visit, pages visited, time spent on each page of the Website, device identifiers, type of operating system used and other website(s) you may have visited.

 

  • They may combine information they collect from your interaction with the Services with Personal Information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. We do not combine the information collected through the use of analytics services with your Personal Information.  Although Google Analytics places a permanent cookie on your web browser to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google.  Google’s ability to use and store information collected by Google Analytics about your visits to our Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.  You can prevent analytics and marketing automation services from recognizing you on return visits to our Website by disabling third party cookies on your web browser.
  • Online Forms: when we collect your Personal Information, it is secured in our database and stored in portals for sites to securely access and follow up with potential participants to determine eligibility for this study.
  • Website Cookies: We, and our analytics and service providers, collect information about you. This information may include the internet protocol (IP) address that your device used, the time and length of your visit, the pages you looked at on our Website, and the site you visited just before coming to ours. We only use this information to measure Website activity and to develop ideas for improving our Website.  In doing this, we may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access.  A “cookie” is a small piece of information which is sent to your browser and stored on your computer’s hard drive.  Cookies do not damage your computer.  You can set your browser to notify you when you receive a “cookie”. This will enable you to decide if you want to accept this cookie or not.  If you disable or refuse cookies, please note that some parts of the Website may then not function properly.
  • Via Phone Call and Text: you may be contacted by a staff member at a research study site if you meet the study requirements to discuss participation in the study. By providing your phone number and/or email to us through the Services, you consent to being contacted by us.


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

 

ClinEdge takes your privacy seriously and will only use your Personal Information for the purposes specified in this Privacy Policy or where there is a legal requirement to do so. We only retain your Personal Information for as long as is necessary and for the purpose(s) specified in this Privacy Policy.

 

The purposes and reasons for processing your Personal Information are detailed below:

 

  • We use your Personal Information to provide you with the ClinEdge Services, make it better, and to continue developing the Services.
  • We use your Personal Information to contact you, respond to your questions or to provide you with information you requested.
  • We collect your Personal Information for study and trial qualification
  • We collect and store your Personal Information as you expressed interest in participating in a study or trial.
  • We will use your Personal Information to enforce our terms, policies and legal agreements We will use your Personal Information comply with court orders and warrants and assist law enforcement agencies.
  • We will use your Personal Information to prevent fraud, misappropriation, infringements, identity thefts, cyber security attacks and any other misuse of your Personal Information and the Services.
  • We will use your Personal Information to take any action in any legal dispute and proceeding.

 

We only retain your Personal Information for as long as necessary for the purpose(s) specified in this Privacy Policy.

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:

 

  • When we contract or partner with a third party to provide services on our behalf, including Services development and maintenance. We require all third parties to process your Information in accordance with this Privacy Policy and as permitted by applicable data protection laws.
  • When we make your Personal Information available to the study research sites for study and trial qualification and to contact interested patients.
  • When we share Personal Information with third parties in connection with the sale of our business (including merger, acquisition, or sale of all or a material portion of our assets, change in corporate control, or insolvency or bankruptcy proceedings).
  • In addition, we share Aggregate Information with third parties, however we will use industry standard measures and appropriate technical and legal guidance to make sure that such information will not likely identify you.

 

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:

 

  • object to the transfer of your Personal Information to a third party, other than to third parties who help us perform tasks as explained in this policy, or,
  • object to the use of your Personal Information for a purpose that is materially different from the purposes for which we originally collected such information, under this Privacy Policy, or from the purposes that you have authorized at a later stage.

 

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.

 

Following the termination or expiration of the Services, we will stop collecting any Personal Information from or about you. However, we will store and continue using or making available your Personal Information according to our data retention section in this Privacy Policy.

 

You may exercise your controls and choices, or request access to your Personal Information, by modifying your profile or by contacting us at privacy@clin-edge.com 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 privacy@clin-edge.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.

 

In any case, as long as we use your Personal Information to provide our Services, we will keep the information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this Privacy Policy.

 

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 privacy@clin-edge.com to request it be deleted.

 

Your California Privacy Rights

 

This Privacy Policy describes how we may share your information for marketing purposes. It applies to all users of the Services, including California residents.

 

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 privacy@clin-edge.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:

  • All processing of your personal data which are not based on the lawful grounds indicated below, are based on your consent.
  • We will process your personal data to comply with a legal obligation and to protect your and others’ vital interests.
  • We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
  • Communications with you, including direct marketing where you are a user of our Services, or where you make contact with us through the Website or through other digital assets.
  • Cyber security.
  • Support, customer relations and Services and Website operations.
  • Enhancements and improvements of user experience with the Services and Website.
  • Fraud detection and misuse of the Services and Website.

 

You have the right to access any personal information that ClinEdge processes about you and to request information about:

 

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data
  • If we did not collect the data directly from you, information about the source

 

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.

 

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us (additional information about this right is available under “Your Controls and Choices” section in this Privacy Policy).

 

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 privacy@clin-edge.com 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.

 

Contact Us

 

For any questions regarding the way we process your Personal Information or this Privacy Policy, you can contact us by sending an email to privacy@clin-edge.com or by phone at 857-496-0054 or at: ClinEdge, Attn: Bob Place, 108 Myrtle Street, Suite 201, Quincy, MA 02171.

 

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