This Privacy Notice (“Notice”) describes the privacy practices of ProSciento, Inc. and its subsidiaries (“us,” “we,” or “ProSciento”) in connection with the www.prosciento.com website and any other website that we own or control and which refers to this Notice (this “Website”), or when we process your personal data through other channels such as phone, email, SMS text or any other online platform.
The Website is designed for individuals acting in a business capacity, prospective customers and their representatives, prospective employees as part of our recruiting activities, and for current and prospective participants in clinical research studies that we manage.
Information for residents of California or those located in the European Economic Area (EEA), United Kingdom, and other regions with laws that may be different than those under US Federal law is available in our Regional Privacy Notice Supplement.
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Introduction
ProSciento is committed to protecting your personal data. Our services feature broad scientific expertise, direct patient access, advanced methodologies, and integrated global operations that are exclusively focused on diabetes, NASH, and obesity to support our customers’ commitment to improving human health. We operate as a service provider to our customers (including, for example, pharmaceutical life sciences companies) and generally process personal data in that capacity, except when we process personal data in connection with operating this Website or in your use of this Website, in our personnel recruiting activities, for our advertising and promotional activities, and occasionally in connection with our relationships with our vendors and suppliers; in which cases we operate as a data controller of personal data, and it is this data processing as a data controller which this notice addresses. In our role as a service provider or supplier for our customers, our contracts and applicable law generally restrict us from processing personal data of customers except for the purposes permitted under the contracts and applicable law. In these cases, we do not decide why or how that Personal Data will be processed. We will only access personal data to provide the services that our customer has directed us to provide, or if we are required to do so by law.
When you give your data to one of our customers or when we collect your Personal Data on their behalf, our customer’s privacy notice, rather than this notice, will apply to our processing of your personal data. If you have a direct relationship with one of our customers, please contact them to exercise your privacy rights.
For purposes of this Notice, personal data means information relating directly or indirectly to an identifiable individual, subject to certain exceptions under applicable law.
Additional license terms, terms of use, contracts, agreements, and privacy statements may also apply to particular Services. If there are contradictions between this Notice and the more specific information for a particular Service, the more specific information shall prevail to the extent permitted under applicable law.
A. Types of Personal Data Collected
We may collect personal data from the following categories of sources: from you directly either online or offline (such as through phone or mail); from third parties sources such as our customers, partners, vendors, or suppliers; or automatically using cookies and similar online technologies.
The table below describes the categories of personal data we collect, process or store and how we obtain it.
| Personal Data We Collect, Process, or Store | How We Obtain It |
| Business and personal contact information, such as your name, professional title, company name, phone number, mailing address and e-mail address. Please visit our Terms of Use for details regarding how we use your phone number to communicate with you through SMS text. | You provide it directly to us when you sign up as a customer or when you use one of our services. You, as a representative of one of our customers, give it directly to us. Our customers (including their employees, contractors, and other representatives of their companies) provide it to us. When we purchase lists of individuals who might be interested in becoming customers of ours. |
| Feedback or correspondence, including identification data, your feedback or questions and any additional information you may provide to our customer support teams. | You provide it directly to us when you contact us with questions, feedback, or otherwise correspond with us. Information you provide to our sales and customer support teams including call recording, text and chat transcript data. You provide it directly to us during live chat sessions. You provide it directly to us during interviews. |
| Information about clinical trial investigators, such as medical specialization and institutional affiliations. | You provide it directly to us. We receive it from our customers in the context of a clinical research study. |
| Physical and health-related information about actual and prospective clinical research study participants, such as gender, weight, height, health-related behavior, and certain medical conditions or treatments. | For prospective research participants: you provide it directly to us by contacting us in order to participate in one of the active research studies (e.g by completing phone questionnaires including information about your current health status). For actual clinical research study participants: you provide this information to the study site as part of the research study, and we process this information on behalf of our customers (pharmaceutical life sciences companies – study sponsors). |
| Customer and transaction information such as information about purchases or other transactions with us and information about your customer service interactions with us. | You provide it directly to us for the provision of the services. |
| Survey information from surveys we or our service provider’s conduct. | You provide this information directly to us in case we conduct a survey, and you voluntarily participate. We receive it from our service providers that conduct the survey on our behalf. |
| Photographs | You may provide in connection with surveys, feedback, use of our Services, or your communications with us. |
| Information we collect about you, your computer or mobile device, and activity occurring on or through the Website using cookies, web beacons, and other technologies: Information about your device’s hardware, such as model, device identifiers, and screen resolution. Information about the software on your device, such as your browser type and operating system. Information about the network to which you are connected and inferences we may draw from it, such as your general geographic area, including your Internet Protocol (IP) address. Information about your use of and actions on the Website, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, links you click, access times, and length of access; and the website that referred you to our Website, if applicable. Information about your interaction with our emails, such as whether you opened our email and how long you had it open. Details regarding how you may set your preferences related to the above automatically-collected information may be found in the Your Choices section below. You may visit our Cookie Notice for additional details. | We collect this information automatically. |
| Other information | Any other information that you provide to us voluntarily. Publicly available information (such as social media posts) Information we are required to collect, or that is appropriate to collect, in order to comply with applicable laws. |
If you submit any personal data relating to other people to us or to our service providers in connection with the Website or Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.
B. Uses of Personal Data
We may use your personal data for the following purposes and as otherwise described in this Notice or at the time of collection:
- To provide our Website and Services. We may use personal data to:
- Provide, operate, improve, analyze, and secure the Website and Services, including to develop new products and services.
- Communicate with individuals and customers about our Services, including by sending announcements, updates, security alerts, and support and administrative messages. Please visit our Terms of Use for details regarding how we use your phone number to communicate with you through SMS text.
- Personalize individuals’ experience with the Website, and our communications.
- Provide customer service, support, and maintenance for the Website and our Services, including by responding to requests, questions, and feedback.
- To respond to inquiries. We may use personal data to respond to you and communicate with you regarding your inquiries regarding our Services.
- To provide training. We may use personal data in the context of providing seminars and training (whether in-person or online).
- To evaluate eligibility to participate in clinical research studies. We may use personal data from individuals who submit their information to us in connection with clinical research.
- To send you marketing communications. We may send you ProSciento-related marketing communications or communications sent on behalf of our customers as permitted by law. You will have the ability to opt out of our marketing and promotional communications as described under the Your Choices section below.
- To display advertisements. We may work with advertising partners to display advertisements online. These advertisements are delivered by our advertising partners and may be directed to you based on your use of the Website or your activity elsewhere online.
- To comply with law. We may use personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- For compliance, fraud prevention, safety, and auditing. We may use personal data where required to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Website or our Services; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) conduct auditing activities; and (e) comply with and respond to binding orders or requests from law enforcement or in connection with any applicable law, regulation or legal process.
- To create anonymous data. We may create anonymous data from your personal data and other individuals whose personal data we collect. We may use this anonymous data, which does not constitute personal data under applicable laws, without restriction for our lawful business purposes, including to analyze and improve the Website and promote our business.
- For personal recruiting, as set forth in Section D, Job Applicants.
C. Sharing of Personal Data
We may share your personal data for the following purposes with the following categories of recipients, and as otherwise described in this Notice or at the time of collection:
- ProSciento Companies. We may share personal data with our corporate parent and subsidiaries, for purposes consistent with this Notice.
- Service Providers. We may share personal data with certain third-party service providers pursuant to contracts or arrangements that we have with third parties in order to fulfil our business purposes. Examples include conducting clinical trials and research, Website hosting, training, email delivery and other third parties in the areas of payment and delivery services, advertising, analytics, search engine providers, and credit reference services. We authorize these third parties to use personal data only as necessary to carry out their specific business obligations to ProSciento.
- Business Transfers. We may sell, transfer, or otherwise share some or all of our business or assets in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we my transfer personal data to a recipient entity.
- Compliance, Fraud prevention, Safety, and Audit. We may share personal data for the compliance, fraud prevention safety, and audit purposes described above.
- With your consent. We may share personal data with your consent.
- Personnel Recruiting. We may share personal data in connection with our personnel recruiting activities, such as with service providers that assist in the recruiting and onboarding of our personnel.
- Anonymous, aggregated, or de-identified data. We may share anonymous, aggregated, or de-identified data from your personal data and other individuals whose personal data we collect, such as compilations of statistical or quantitative data, for our business or scientific purposes, such as to publish reports and create marketing materials.
D. Job Applicants
When you visit the ‘Careers’ portion of our Website, we collect the information that you provide to us in connection with your job application or other employment inquiry. This includes business and personal contact information, professional credentials and skills, educational and work history, photographs, and other information of the type that may be included in a resume. This may also include diversity, compensation, and other non-required information that you voluntarily provide. We use all of the foregoing information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to operate and improve our business, and as otherwise necessary for compliance, fraud prevention, safety, and audit purposes.
Personal data relating your job application is retained for the period of your employment and thereafter in accordance with ProSciento’s data retention policies and relevant laws.
E. Your Choices
In this section, we describe the rights and choices available to you. Additional information for individuals located in California, the European Economic Area (EEA), United Kingdom, and other regions with laws that may be different than those under US Federal law is located in our Regional Privacy Notice Supplement.
- Providing your information. You may choose not to provide your personal data, though we may not be able to provide you with some Services or some functionality of the Website. Information required for a certain Service or functionality of the Website will be disclosed to you at the time of collection.
- Opt out of marketing communications. You may opt out of marketing-related communications at any time by following the opt-out or unsubscribe instructions contained in the message. You may continue to receive transactional, service-related and other non-marketing emails.
- Cookies & other similar technologies. You may review and set preferences for cookies and other similar technologies at any time using the Cookie Compliance banner displayed on the Website. This includes the ability to reject all Cookies/tracking if desired. If you choose to opt out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed. Please visit our Cookie Notice for more detail.
- SMS Text. Please visit our Terms of Use for details regarding your choices in how we communicate with you through SMS text. Mobile information will not be sold or shared with third parties for marketing or promotional purposes.
F. Security Practices
The security of personal data is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal data we collect. Your information may be stored and processed in the United States or any other country where we and our subsidiaries or service providers are located. When you use our Website, you are transferring information to the United States and other locations where we or our service providers operate. While we strive to protect personal data, we cannot guarantee the security of the personal data we receive or collect, as no transmission of information through the Internet can ever be completely secure.
G. Retention
We retain personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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, and the applicable legal requirements.
H. Individuals in California and Outside the United States
Additional information for residents of California or those located in the European Economic Area (EEA), United Kingdom, and other regions with laws that may be different than those under US Federal law is available in our Regional Privacy Notice Supplement.
I. Children’s Data
We do not knowingly collect personal data from children under the age of 17. If you are under the age of 17, please do not provide any information to us. If we become aware that we have collected information from a child under the age of 17, we will make commercially reasonable efforts to delete the information from our systems.
J. Other Websites
The Website may contain links to other websites or online services operated by third parties, which we do not control. Other websites and services may follow different rules and conventions regarding the collection, use and sharing of personal data and may not comply with the same standards as ProSciento. We encourage you to read the privacy policies of the other websites and online services you access or use carefully.
K. Updates and Changes to Privacy Notice
ProSciento may, in its sole discretion and without prior notice, change, modify or alter any or all portions of this Notice. ProSciento will notify you of material changes by updating the date of this Notice and posting it on the Website. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Website.
Any revisions shall be effective immediately upon posting. In all cases, your continued use of the Website after the posting of any modified Notice indicates your acceptance of the terms of the modified Notice.
L. Contacting Us
Please direct any questions or comments about this Notice or our privacy practices, or if you wish to exercise your rights as a Data Subject to DPO@prosciento.com or via 833-602-2089 (toll free).
If you have questions regarding ProSciento’s Research Studies, please contact us via hello@myproscientostudy.com or 800-247-3140 (toll free).
Last modified: August 6, 2024
