The collection, use, and retention of personal information and transfer from the European Union, United Kingdom or any affiliated TrialAssure location to the United States will be defined in Standard Contractual Clauses (SCCs) as applicable to meet business needs.
The data protection landscape is rapidly evolving and recent events may be reviewed at the following URL: https://www.privacyshield.gov/NewsEvents
TrialAssure is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
Users may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework at https://www.privacyshield.gov.
Data Protection Officer:
TrialAssure has appointed a Data Protection Officer (DPO) to ensure appropriate implementation of applicable legal and regulatory data protection and privacy requirements, including the EU General Data Protection Regulation (GDPR). The TrialAssure DPO is responsible to advise TrialAssure Senior Leadership as required to attain and maintain compliance to such laws, regulations, and safeguards, and to continually review and advise on TrialAssure business practices and codes of conduct related to Data privacy and protection.
Collected Data & Data Usage:
TrialAssure collects Data from individuals who visit our website (“Visitors”) and individuals who use TrialAssure services (“Customers”).
When you request additional information about TrialAssure, contact TrialAssure via our website, or register to use TrialAssure services, TrialAssure may require you to provide contact information such as your name, company, name, title, address, phone number(s), fax number, and email address.
When purchasing TrialAssure services, financial qualification and billing information may be requested, such as billing name and address, credit card number, and the number of project team members.
TrialAssure uses the collected Data to perform the requested services. For example, if you complete a web contact form, TrialAssure will use the information provided to contact you with details regarding the TrialAssure services of interest.
TrialAssure may also use the collected Data for marketing or other legitimate business purposes. For example, TrialAssure may use the collected Data to contact you to further discuss your interest in TrialAssure services, and to send information regarding our company or partners, which may include promotions and events. You may opt-out of receiving marketing communications from TrialAssure at any time by referring to the Opt-Out Policy below.
All financial and billing information collected is used solely to verify the qualifications of prospective Customers and to invoice for services provided. Financial and billing information is not used by TrialAssure for marketing or promotional purposes.
TrialAssure may also collect information about your interaction with our website. For example, TrialAssure may use technologies, such as cookies (described below), to collect information about the pages you view, the links you click and other actions you take on our site. Additionally, TrialAssure may also collect certain standard information that your browser sends to every website you visit, such as your IP address, access times, and referring website addresses. This information is primarily used to help diagnose technical problems, for administrative purposes, to compile non-identifying aggregate statistics about site usage and to improve the quality of our website and services.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to TrialAssure, either by responding to a promotional offer, completing a contact or interest form or registering for an account, you remain anonymous to TrialAssure.
There are two types of cookies, session cookies and persistent cookies. Session cookies exist only during an online session. They disappear from your computer when you close your web browser or turn off your computer. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer. They include information such as a unique identifier for your browser.
TrialAssure may use persistent cookies to identify the fact that you are a TrialAssure Customer or prior TrialAssure website Visitor (whichever the case may be). TrialAssure is particularly careful about the security and confidentiality of the information stored in persistent cookies. For example, TrialAssure does not store account numbers or passwords in persistent cookies. Users can disable their web browsers’ ability to accept cookies and will still be able to browse the TrialAssure website.
Pages within TrialAssure’s website and software service may contain links to other/external websites. TrialAssure is not responsible for the privacy practices or the content of these websites. When visiting these sites, TrialAssure encourages you to verify and understand their privacy policies prior to providing any private Data. When accessing a linked site, you may be disclosing your private Data; it is your responsibility to keep such information private and confidential.
TrialAssure recognizes potential liability in cases of onward transfer to third parties. TrialAssure will not transfer any personal information to a third-party without first ensuring that the third-party adheres to the Privacy Shield principles.
Sharing of Collected Data:
Except in the cases where TrialAssure explicitly states otherwise, at the time we request information, or as provided for in the TrialAssure Master Subscription Agreement, TrialAssure does not disclose to third parties your personally identifiable Data except as follows: TrialAssure may share your Data with Agents who process Data only on behalf of TrialAssure and for TrialAssure purposes (as used here, “Agents” are persons or companies who act on behalf of or under the direction of TrialAssure). TrialAssure may share your Data as required by law or in the interest of protecting or exercising TrialAssure or others’ legal rights (e.g., without limitation, relating to requests from law enforcement officials and relating to court proceedings). TrialAssure may share or transfer your Data relating to a prospective or actual sale, merger, transfer, or other reorganization of all or parts of TrialAssure business. TrialAssure may also share Data with third parties involved in the normal business operations; for example, with contract research organizations (CROs), study sponsors, or others that are involved in study management as commonly done in our industry. TrialAssure reserves the right to fully use and disclose any Data that is not in personally identifiable form (such as site usage statistics that do not identify you individually by name).
TrialAssure may also use a third-party intermediary to manage the credit card processing. This intermediary is solely a link in the distribution chain, and is not permitted to store, retain, or use the Data provided, except for the sole purpose of credit card processing.
TrialAssure will not disclose personally identifiable Data to any third party unless it first either ascertains that the third party adheres to the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework, or is subject to GDPR EU Directive on Data Protection or another adequacy finding, or enters into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant Privacy Shield Principles.
TrialAssure offers Visitors and Customers a means to choose how we may use the Data provided. If, at any time after providing TrialAssure with Data, you change your mind about receiving commercial information from TrialAssure or about sharing your Data with third parties, send a request specifying your new choice to support@TrialAssure.com.
Customers can not opt-out of receiving emails from TrialAssure that are directly related to their use of TrialAssure services such as email notifications, or service notifications.
Correcting & Updating Data:
TrialAssure is dedicated to maintaining accurate and up to date Customer Data. If you need to update Data and/or billing information or to have your information deleted please email support@TrialAssure.com or call +1 855 667 9444. TrialAssure will respond to your correction or update request within 30 days from the date of your request.
Customer-Provided Data & Data Services:
Where Customers are contracting TrialAssure services to process Customer-provided Data, TrialAssure will comply with all GDPR principles relating to processing of personal Data as defined in GDPR Chapter 2, Articles 5-11.
Customers are responsible to ensure processing requests are permitted based on Data Subject Consent and adhere to the lawfulness of processing defined in GDPR Chapter 2. TrialAssure will also comply with all other rules and regulations in processing of Customer-provided data as appropriate (i.e. Policy 70, HIPPA).
TrialAssure will not review, share, distribute, print, or reference any such Data except as defined in the TrialAssure Master Subscription Agreement, or as may be required by law. Individual records may at times be viewed or accessed only for resolving a problem, support issue, or suspected violation of the Master Subscription Agreement, or as may be required by law.
Customers are responsible for maintaining the confidentiality and security of their user registration and password. Customer-provided Data retention and destruction is managed per the appropriate Customer agreement and must comply with applicable legal and regulatory requirements.
Security & Breach Notification:
TrialAssure has placed commercially reasonable security measures in place to protect the integrity, availability, and confidentiality of Data. These measures include policies, procedures, employee training, and physical access and logical security controls. In addition, when accessing the TrialAssure software systems, Data transmitted to TrialAssure servers are secured using standard security protocols and mechanisms such as SSL encryption to ensure data confidentiality and integrity.
If individual personal Data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification of affected individuals, TrialAssure will issue a notification of the breach by email or fax or, if TrialAssure is unable to contact the individual by these means, then by U.S. mail.
Notice will also be sent to Customers when a breach affects Customer-provided Data, and to legal and law enforcement authorities as required under current laws and regulations. Any measures necessary for TrialAssure or legal and law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system will be taken.
TrialAssure may delay notification to Customers and/or individuals if TrialAssure or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until TrialAssure or the agency determines that notification no longer compromises an investigation.
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through TrialAssure internal processes, TrialAssure has agreed to participate in the VeraSafePrivacy Shield Dispute Resolution Procedure.
Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
Data Subject’s rights:
Users whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that TrialAssure maintains about them to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment or deletion should be sent to: support@TrialAssure.com
Data Minimization, Retention, & Destruction:
Data which permits identification of Data Subjects will be minimized to only the Data required to perform contracted services and processing activities to which Data Subjects have consented. All data will be anonymized to the extent possible. Data permitting identification of Data Subjects will be retained only for the period defined in the applicable agreement(s).
Personal Data may be stored for longer periods insofar as the Data will be processed solely for archiving, purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with GDPR Article 89(1) ensuring appropriate technical and organizational measures to safeguard the rights and freedoms of the Data Subject.
Attn: Data Protection Officer 6880 Commerce Blvd.
Canton, MI 48187