The website is designed for individuals acting in a business capacity, prospective clients and their representatives and for current and prospective participants in clinical research studies that we manage.
This policy provides important information for website visitors located in California, the European Economic Area (EEA), and United Kingdom.
- Information for all Visitors
- Information for Visitors Resident in the EEA
- Information for Visitors Resident in California
Please view the links below to enable accessibility options within your browser to improve your access to the information contained on this page.
1. Information for all Visitors
ProSciento is committed to compliance with the data privacy laws of all the territories in which it operates, including protecting the rights of individuals whose personal data (PD) ProSciento controls or processes in accordance with the California Consumer Protection Act, the The General Data Protection Regulation (EU) 2016/679 (GDPR) and UK General Data Protection Regulation (retained from EU Regulation 2016/679 EU) (UK GDPR) as follows:
- Processing PD only where this is strictly necessary for legitimate organizational purposes.
- Collecting only the minimum PD required for these purposes and not processing excessive or unnecessary PD.
- Providing clear information to individuals about how their PD will be used and by whom.
- Only processing relevant and adequate PD.
- Processing PD fairly and lawfully.
- Maintaining an inventory of the categories of PD controlled and processed by ProSciento.
- Keeping PD accurate and, where necessary, up to date.
- Retaining PD only for as long as is necessary for legal or regulatory reasons or, for legitimate organizational purposes.
- Respecting individuals’ rights in relation to their PD, including their right of subject access.
- Keeping all PD secure.
- Only transferring PD outside the EEA in circumstances where it can be adequately safeguarded.
- The application of the various exemptions allowable by data protection legislation.
This Policy is expressly for website visitors only. ProSciento Employees should refer to the ProSciento Corporate Data Protection Policy.
A. Types of Personal Information Collected
We may collect information about individuals via this website, email or in a database in the following ways:
Information you provide to us, which may include:
- Business and personal contact information, such as your name, professional title, company name, phone number, mailing address and e-mail address.
- 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 behaviour, and certain medical conditions or treatments.
- Other information that you provide to us voluntarily.
- Cookies and Other Information Collected by Automated Means. We may automatically collect information about you, your computer or mobile device, and activity occurring on or through the website using web beacons, and other technologies. 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.
- 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 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.
First-time visitors to the website will be given information about the technologies in use and requested to set their consent preferences using a third-party WordPress plug-in known as GDPR Cookie Compliance. Visitors may review this information and change their consent preferences at any time thereafter. Visitors may reject the use of tracking technologies in part or in full.
B. Use and Sharing of Information Collected
- To provide our services. We use personal data 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 data from individuals who submit their information to us in connection with a clinical research. We currently do not request information from individuals in the European Economic Area (EEA) 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 comply with law. We 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, and safety. We may use personal data and disclose it to law enforcement, government authorities, and private parties 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; 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 data and other individuals whose personal data we collect. We make personal data 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.
- Service Providers. We may share personal data with certain companies and individuals pursuant to contracts or arrangements that we have with such companies in order to fulfil our business purposes. Examples include conducting clinical trials and research, website hosting, and email delivery. We authorize these parties to use personal data only as necessary to carry out their specific business obligations to ProSciento. When we share this personal data with a service provider, ProSciento has taken reasonable steps to ensure that the third parties with which we share data undertake to comply with relevant data protection legislation.
- Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal data, 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 data for the compliance, fraud prevention and safety purposes described above.
- To provide our services. We use personal data to:
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.
PD relating your job application is retained for the period of your employment and thereafter in accordance with the ProSciento Archiving Policy.
D. Your Choices
In this section, we describe the rights and choices available to all users. Users who are located in California or the EEA can find additional information about their rights below:
- Opt out of marketing communications. You may opt out of marketing-related emails at any time 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 & other tracking technologies – you may review and set preferences for Cookies and other tracking technologies at any time. 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.
E. 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.
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 as follows:
|Business and personal contact information||Up to 25 years|
|Feedback or correspondence||Up to 25 years|
|Information about clinical trial investigators||Up to 25 years|
|Information about actual and prospective clinical research study participants||Up to 25 years|
|Other information that you provide to us voluntarily.||Up to 25 years|
|Cookies and Other Information Collected by Automated Means||Up to 26 months|
|Information about your device’s hardware||Up to 26 months|
|Information about the software on your device||Up to 26 months|
|Information about the network to which you are connected and inferences we may draw from it||Up to 26 months|
|Information about your use of and actions on the website||Up to 26 months|
|Information about your interaction with our emails||Up to 26 months|
|Job applications||Successful candidates – for the duration of employment plus any national statutory requirements thereafter Unsuccessful candidates – 3 years or per national statutory requirements, whichever is the longer|
G. 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.
I. Contacting Us
2. Information for Visitors Resident in the EEA
The information provided in this “Notice to European Users” section applies only to individuals that are located in the European Economic Area (EEA).
Terms used in this section of the Policy are consistent with the definitions in The General Data Protection Regulation (EU) 2016/679 (GDPR).
|Processing purpose (click link for details)|
Details regarding each processing purpose listed below are provided in the section above titled “Use of Personal Data”.
|To provide our services||Processing 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.
|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 law||Processing is necessary to comply with our legal obligations.|
|With your consent||Processing 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.|
GDPR gives Data Subjects resident in the EEA certain rights regarding their personal data. If you are located within the EEA you may submit a request to exert your right(s) in relation to your personal data for which ProSciento is the Data Controller, as follows:
1. Right to be informed
The right to be informed allows individuals to know what personal data is collected about them, why, who is collecting data, how long it will be kept, how they can file a complaint, and with whom will they share the data.
2. Right to access
Individuals have a right to submit subject access requests and obtain personal data an organization has about them.
3. Right to rectification
The right to rectification allows the individuals to ask the organization to update any inaccurate or incomplete personal data.
4. Right to Erasure
Also known informally as the ‘right to be forgotten’. This right allows individuals to ask for their personal data to be deleted if:
- the personal data is no longer necessary
- an individual withdraws consent
- the personal data have been unlawfully processed
- Individual objects to the processing and the data controller has no reason to continue processing
- data erasure is necessary for compliance with a legal obligation (EU law or national law)
5. Right to restrict processing
Individuals can request that an organization limits the way it uses their personal data.
6. Right to data portability
Individuals can also request for their data to be transferred directly to another organization.
7. Right to object to processing
The right to object allows individuals to object to the processing of personal data at any time or certain circumstances (e.g. for marketing purposes).
8. Rights in relation to automated decision making and profiling
The data subjects now have the right not to be subject to automated decision-making if it is producing a legal effect that significantly affects them. Please note that ProSciento does not engage in this activity and does not control or process data for this purpose.
Data Protection Officer
855 3rd Avenue,
Chula Vista CA 91911 USA
ProSciento is established in the European Union at:
ProSciento Europe B.V.
6222 PH Maastricht
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 or not fully meet your request. If we decline or not fully meet your request, we will tell you why, subject to legal restrictions.
If you wish a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact the data protection Supervisory Authority in your country. 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, or Binding Corporate Rules
- Pursuant to the consent of the individual to whom the personal data 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.
3. Information for Visitors Resident in California
California Consumer Protection Act Privacy Notice
This California Consumer Protection Act Privacy Notice (“CCPA Notice”) applies to all Personal Information collected and/or received by ProSciento from consumers residing in California. This CCPA Notice explains how ProSciento collects, manages, uses and protects Personal Information and how it may also be used in conjunction with other ProSciento privacy notices located here:
For purposes of this CCPA Notice, the following definitions shall apply:
- California Consumer Protection Act of 2018 (“CCPA”) is a data privacy law passed by the state of California on June 28, 2018 and went into effect on January 1, 2020. It outlines new standards for data collection, new consequences for businesses that fail to protect user data, and new rights that California consumers can exercise over their data.
- “Consumer” under the CCPA, a consumer is defined as a California resident.
- “Business” is a for-profit entity that collects “consumer” data and meets at least one of the following thresholds: (i) annual gross revenue over $25 million; (ii) annually buys, receives, sells or shares the personal information of 50,000 or more consumers, households, or devices for commercial purposes; or (iii) derives 50% or more of its annual revenue from selling consumer personal information.
- “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
What Personal Information Does ProSciento Collect?
The CCPA lists the following categories of Personal Information:
- Identifiers and Personal Records (i.e. real name; alias; signature; postal address; email address; telephone number; unique personal identifier; online identifier; Internet Protocol address; device identifiers; email address; account name; Social Security number; driver’s license or other state identification number; passport number; insurance policy number; insurance claim number; financial information, including bank account, credit card numbers, bank routing details; employment, including current and historical; association membership; other device identifiers including the operating system, browser type, network information; or other similar identifiers)
- Protected legal characteristics (i.e. age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, or veteran or military status)
- Commercial information (i.e. records of personal property; products or services purchased, obtained, or considered, including data related to insurance policies; or other purchasing or consuming histories or tendencies)
- Biometric information (i.e. Items related appearance including, but not limited to, height, weight, eye color, hair color; NOT including any genetic data or data that could alone be considered Personal Information when not combined with other information (i.e. fingerprint or genetic data))
- Internet activity
- Geolocation data (i.e. Physical location of users, generally and specifically)
- Audio, electronic, visual, thermal, olfactory, or similar information
- Employment information
- Education information
- Inferences about personal preferences and attributes drawn from profiling (e.g. via cookies)
Sources of Personal Information
- Information you give ProSciento. You may give ProSciento such information directly by registering with ProSciento, by participating in a clinical trial, completing forms, corresponding or speaking with ProSciento by phone, email, letter or otherwise, submitting a query, providing ProSciento with feedback about a product, visiting our website, requesting that ProSciento provides you with services / communications, or when ProSciento appoints you as a service provider.
- Information ProSciento collects about you. When you visit ProSciento’s website and receive e-mails from us, ProSciento may automatically collect technical information about your equipment, browsing actions and patterns. ProSciento collects this by using cookies.
- Information provided by cookies.
- Cookies are small files saved to the user’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows ProSciento’s website, through its server, to provide users with a tailored experience.
- If you wish to prevent the use and saving of cookies from the website on to your computer’s hard drive you should take necessary steps within web browser’s security settings to block all cookies from ProSciento’s website.
- Other cookies may be stored on your hard drive by external vendors when ProSciento’s website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
- If you would like further information about cookies and how they are used, you can visit http://www.allaboutcookies.org/.
- When ProSciento e-mails you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
- Information ProSciento receives about you from other sources. ProSciento may receive information about you if you use any of the other websites ProSciento operates or the other services that ProSciento provides. In this case, ProSciento will have informed you when collecting that data that it may be shared internally and combined with data collected on this site.
- ProSciento also works with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from the third parties.
- ProSciento may receive information if you have provided permission to other organizations to share it with ProSciento. Before providing permission to such third-party organizations to share your personal information, you should check their privacy notices carefully.
- ProSciento may take information from publicly available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database or any professional registration database.
- ProSciento may receive information about you if you apply for a vacancy at ProSciento.
How ProSciento Might Use your Information
ProSciento may use or disclose the personal information ProSciento collects for one or more of the following business purposes:
- To manage and administer our relationship with you
- To conduct and support on clinical trials
- To carry out our obligations arising from any contracts entered into between you and us
- To respond to your requests
- To provide you with information about our activities or tailored information about a program that you have signed up to
- To improve our level of service
- To notify you about changes to our service and notify you of new services
- To seek your views on our services
- To consider your application for employment
- For administrative and quality assurance purposes
- To ensure that content from our website is presented in the most effective manner for you and for your computer
- For the purposes of the establishment, exercise or defense of legal claims.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure
- Information ProSciento receives from other sources. ProSciento may combine this information with information you give to us and information we collect about you. ProSciento may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply any agreements, including for billing and collection purposes.
- If ProSciento believes disclosure is necessary or appropriate to protect the rights, property, or safety of ProSciento, its customers, or others. This includes exchanging Personal Information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Sale of Personal Information
ProSciento does NOT “sell” Personal Information that is collected from you, in accordance with the definition of “sell” in the CCPA, and will treat Personal Information ProSciento collects from you as subject to a do not sell request.
Personal Information Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information. If you would like to exercise any of these rights, please contact ProSciento using the details set out below in the ‘Contact ProSciento’ section. If you exercise any of these rights, ProSciento may ask for proof of identity and sufficient information about your interactions with ProSciento so that we can locate your personal information. If ProSciento agrees that we are obliged to provide personal information to you (or someone else on your behalf), ProSciento will provide it to you or them free of charge except in exceptional circumstances.
(1) Access to Personal Information
You may access, update, correct or extract any and all Personal Information directly from ProSciento by contacting us using the details set out below in the ‘Contact ProSciento’ section.
For both Personal Information relating to users and the third parties about which you inputted Personal Information, you have the right to request that ProSciento disclose certain Personal Information to you about our collection and use of the Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable individual request, we will disclose to you:
- What Personal Information has been collected;
- The sources from which that Personal Information was collected;
- The business purposes for collection;
- Whether that Personal Information is sold, and for what business purpose; and
- The third-party recipients of the Personal Information.
(2) Deletion Request Rights
ProSciento will hold your personal information on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements.
By law, ProSciento is required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, ProSciento will 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 are processing your personal information and whether ProSciento can achieve those purposes through other means.
Therefore, some information may be kept for more or less time depending on how long ProSciento reasonably feels it is required for.
ProSciento reviews our retention periods for personal information on a regular basis.
If you ask ProSciento to delete your information in accordance with your rights set out below, ProSciento will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
(3) Exercising Your Rights
To exercise the access and deletion rights described above, please submit a verifiable request to ProSciento using the details set out below in the ‘Contact ProSciento’ section. Only you may make a verifiable request related to Personal Information that we collected from you.
You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are either (i) the person about whom we collected Personal Information or (ii) an authorized representative which inputted the Personal Information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
ProSciento cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or an individual about which you inputted Personal Information.
ProSciento will respond to a verifiable request within forty-five (45) days of its receipt. If ProSciento requires more time (up to 90 days), ProSciento will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the date of the request’s receipt. The response ProSciento provides will also explain the reasons we cannot comply with a request, if applicable.
ProSciento will not discriminate against you for exercising any of your Personal Information rights. Unless permitted by applicable regulations, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
ProSciento has implemented reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Details of these measures can be obtained on request.
Third parties will only process your Personal Information on ProSciento’s instructions and where they have agreed to treat the information confidentially and to keep it secure.
ProSciento also has procedures in place to deal with any suspected data security breach. ProSciento will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
ProSciento’s security measures are regularly reviewed.
If you have any questions regarding this Policy or about our privacy practices, wish to exercise any of your rights or wish to file a complaint, please contact ProSciento’s Data Protection Officer at:
- E-mail: DPO@ProSciento.com
- Post: ProSciento, 855 3rd Avenue, Suite 3340, Chula Vista, CA 91911 U.S.A and marking your query for the attention of The Data Protection Officer.
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.
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.
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.
First-time visitors to the website will be given information about the technologies in use and requested to set their consent preferences using a third-party WordPress plug-in application known as GDPR Cookie Compliance. Visitors may review this information and change their consent preferences at any time thereafter. Visitors may reject the use of tracking technologies in part or in full.
Information about the cookies we use may be updated from time to time.
Last modified February 1, 2022.