This Privacy Policy 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 posts this Privacy Policy (this “Website”).

The Website is designed for individuals acting in the business capacity, and prospective clients and their representatives; and for current and prospective participants in clinical research studies that we manage. Our Website is not intended for personal, family or household use. Accordingly, we treat all personal information covered by this Privacy Policy, including information about any visitors to the Website, as pertaining to individuals acting as business representatives or clinical research study participants, rather than in their personal capacity. Information that individuals provide in connection with clinical research studies is subject to our HIPAA Notice.

We provide important information for individuals located in the European Union, European Economic Area, and United Kingdom (collectively, “Europe” or “European”) below.

A. Types of Personal Information Collected.

We may collect information about individuals in the following ways:

Information you provide to us, which includes:

  • Business and personal contact information, such as your name, professional title, company name, phone number, mailing address and e-mail address
  • Profile information, such as the username and password that you may set to establish an account on the Website.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Information about clinical trial investigators, such as medical specialization and institutional affiliations.
  • Information about actual and prospective clinical research study participants, such as gender, weight, height, health-related behavior, and certain medical conditions or treatments.
  • Other information that you provide to us voluntarily.

Cookies and Other Information Collected by Automated Means. We, our service providers, and other third parties may automatically collect information about you, your computer or mobile device, and activity occurring on or through the Website. These parties may collect this type of information over time and across third-party websites and may use cookies, web beacons, and other technologies to collect this information. The information may include:

  • Information about your device’s hardware, such as model and screen resolution.
  • Information about the software on your device, such as your browser type.
  • Unique identifiers associated with your device, such as device identifier (e.g., Google Advertising ID or Apple ID for Advertising).
  • Information about the network to which you are connected and inferences we may draw from it, such as your IP address and general location information such as city, state or geographic area.
  • 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 the Website, if applicable.
  • Information about your interaction with our emails, such as whether you opened our email and how long you had it open.

See our Cookie Policy for more information.

B. Use and Sharing of Information Collected.

  1. Use of Personal Information. We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
    • To provide our services. We use personal information to:
      • Provide, operate and improve the Website, including to develop new products and services.
      • Provide the services that individuals request.
      • Communicate with individuals about our services, including by sending announcements, updates, security alerts, and support and administrative messages.
      • Personalize individuals’ experience with the Website, and our communications.
      • Provide support and maintenance for the Website and our services, including by responding to requests, questions and feedback.
    • To evaluate eligibility to participate in clinical research studies. We use personal information from individuals who submit their information to us in connection with a clinical research study in accordance with our HIPAA Notice. We currently do not request information from individuals in Europe through the Website pertaining to participation in clinical research studies.
    • To send you marketing communications. We may send you ProSciento-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
    • To display advertisements. We work with advertising partners to display advertisements online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Website or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
    • To comply with law. We use personal information 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, and safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate 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; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
    • To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.
  2. Sharing of Personal Information. ProSciento does not share, provide, sell, lease, trade or rent your personal information to third parties for direct marketing purposes, unless you affirmatively agree to such disclosure. We may share personal information as described below or otherwise in this Privacy Policy.
    • ProSciento Companies. We may share personal information with our corporate parent and subsidiaries, for purposes consistent with this Privacy Policy.
    • Service Providers. We may share personal information with certain companies and individuals pursuant to contracts or arrangements that we have with such companies in order to fulfill our business purposes. Examples include conducting clinical trials and research, website hosting, and email delivery. We authorize these parties to use personal information 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, including personal information, 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.
    • Compliance, Fraud prevention and Safety. We may share personal information for the compliance, fraud prevention and safety purposes described above.

C. 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. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this 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, and safety purposes.

D. Your Choices.

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below

  • Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.
  • Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Website and third party websites. For more details, see our Cookie Policy.
  • Targeted online advertising. Some of the third parties that collect information about users’ activities on or through the Website may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
    Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
    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.
  • Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

E. Security Practices.

The security of personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of any personal information.

F. 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 follow different rules regarding the collection, use and sharing of personal information. We encourage you to read the privacy policies of the other websites and online services you access or use.

G. Updates and Changes to Privacy Policy.

ProSciento may, in its sole discretion and without prior notice, change, modify or alter any or all portions of this Privacy Policy. ProSciento will notify you of material changes by updating the date of this Privacy Policy 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 Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

H. Contacting Us.

Please direct any questions or comments about this Privacy Policy or our privacy practices to DPO@prosciento.com.

 

I. Notice to European Users.

The information provided in this “Notice to European Users” section applies only to individuals that reside in Europe.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. ProSciento, Inc. is the controller of your personal information covered by this Privacy Policy.

Data Protection Officer. The contact information of our Data Protection Officer is: DPO@prosciento.com.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purpose (click link for details)
Details regarding each processing purpose listed below are provided in the section above titled “Use of Personal Information”.
Legal basis
To provide our servicesProcessing is necessary to perform the contract governing our provision of our services or to take steps that you request prior to signing up for our services.
If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request.
  • To send you marketing communications
  • To display advertisements
  • For compliance, fraud prevention and safety
  • To create anonymous data
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with lawProcessing is necessary to comply with our legal obligations.
With your consentProcessing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. If you provide us with any sensitive personal information (e.g., health information) when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information to us.

Retention

We retain personal information for as long as necessary to fulfill 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to DPO@prosciento.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact DPO@prosciento.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:

  • Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
  • Pursuant to the consent of the individual to whom the personal information pertains
  • As otherwise permitted by applicable European requirements.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

 

Cookie Policy

This Cookie Policy explains how ProSciento, Inc (“ProSciento”, “we”, “us” or “our”) uses cookies and similar technologies in connection with the www.prosciento.com website and any other website that we own or control and which posts or links to this Cookie Policy (collectively, the “Website”).

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.

Our Website may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers or business partners on our Website, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.

What types of cookies and similar tracking technologies does ProSciento use on the Website?

On the Website, we use cookies and other tracking technologies in the following categories described in the table below.

TypeDescriptionExamplesHow to control them
AdvertisingThese cookies are used by advertising companies to collect information about how you use our Website and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Service and elsewhere, and to measure how the ads perform. Facebook
Twitter
Google AdWords
LinkedIn Ads
See ‘your choices’ below.
Facebook users may manage their ads preferences here.
Twitter users may manage their Personalization and data settings here.
Google users may view information about managing their ads settings here.
LinkedIn users may manage their ads settings here.
AnalyticsThese cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.Google Analytics
LinkedIn Analytics
See ‘your choices’ below.
Google Analytics and LinkedIn Analytics uses their own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plugin available here.
EssentialThese cookies are necessary to allow the technical operation of our Service (e.g., they enable you to move around on a website and to use its features).Google Tag ManagerSee ‘your choices’ below.
Functionality/
performance
These cookies enhance the performance and functionality of our Service.See ‘your choices’ below.

Other technologies

In addition to cookies, our Website may use other technologies, such as pixel tags to collect information automatically.

Browser Web Storage

We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.

Web Beacons

We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Website and in our HTML formatted emails to track the actions of users on our Website and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Website, so that we can manage our content more effectively.

Your choices

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Website may not work properly.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Website.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

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, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

Changes

Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.

Questions

If you have any questions about this Privacy Policy, please contact us by email at DPO@prosciento.com.

Last modified 18 March 2020.

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