Privacy & Legal
Privacy Shield
Privacy Shield Framework
CMI complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries, the United Kingdom and Switzerland to the United States in reliance on Privacy Shield. CMI has certified that it adheres to the EU-U.S. Privacy Shield Framework and the Swiss- U.S. Privacy Shield Framework and the Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability, as set forth by the US Department of Commerce. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.
This Policy applies to the processing of Personal information that CMI receives in the United States concerning individuals who reside in Switzerland and the EEA. This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes to prevent identification of individual persons).
If there is any conflict between the provisions in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.Scope
Definitions
For the purposes of the Policy, the following definitions shall apply:
- “Data Processor” means any third party processing personal information on behalf of, and under the instruction of CMI.
- “European Union” or “EU” means for the purposes of this Policy all countries within the European Economic Area (EEA).
- “Clinical Trial Participant” means an individual participating in a clinical trial in the EU and providing personal information to third parties CMI has contracted with to conduct the study. Clinical Trial Participant has the same meaning as “Data Subject” under Article 4 of the GDPR.
- “Pseudonymised Data” means Personal Data that can no longer be attributed to a specific individual in the EU without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an individual. CMI will protect Pseudonymised Data subject to the GDPR with the same care and high standards as Personal Data.
- “Anonymous Data” is information which does not relate to an identified or identifiable natural person or personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. The GDPR does not concern the processing of Anonymous Data.
- “Clinical Trial Data” is the data collected and processed by CMI for clinical trial purposes. It includes Pseudonymised Data received from third parties as well as new data generated by CMI and third parties based on data collected for the clinical trial. These new data may not relate to an identified or identifiable natural person.
- “Principle”: the Department of Commerce is issuing these Privacy Shield Principles, including the Supplemental Principles (collectively “the Principles”).
- “Personal data” and “Personal Information” means data about an identified or identifiable individual that are within the scope of the Directive, received by CMI in the United States from the European Union, and recorded in any form. It does not include personal information that has been anonymized or that is publicly available, that has not been combined with non-public personal information.
- “Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
- “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns health or sex life. In addition, CMI will treat as sensitive, any information received from a third party where that third party treats and identifies the information as sensitive.
Privacy principles
Notice
Where CMI collects Personal Information directly from individuals in the EU, the United Kingdom or Switzerland, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to whom CMI discloses that information, and the choices and means, if any, that CMI offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language, when individuals, are first asked to provide Personal Information to CMI, or as soon as practical thereafter, and in any event before CMI uses the information for a purpose other than that for which it was originally collected.
Where CMI receives Personal Information from its subsidiaries, affiliates or other entities in the EU, the United Kingdom or Switzerland, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to who such Personal Information relates.During the conduct of its operations, Concept Medical Inc. (CMI) may collect and process personal information relating to:
- Study participants: The collection of Personal Information such as contact information, qualifications, debarment status, and account information is to facilitate the proper conduct of research studies and to carry out other study-related services. Information collected may be transferred to third-party service providers performing study-related duties and may furthermore be transferred to regulatory authorities.
- Customers, vendors, and consultants: CMI keeps contact information, account numbers, and information relating to billing, together with other information necessary for the daily operation of CMI’s services. This includes conducting customer, product, and service surveys; direct marketing of products and services; handling customer complaints and enquiries; making disclosures under the requirements of applicable laws; and addressing any other directly related matters.
- Human resources data: Information such as curriculum vitae, contract information, residential address, date of birth, gender, government identification number, account information, qualifications, training records, debarment status, and performance reviews is processed to support CMI’s human resources functions. These include the administration of employee benefits, compensation, management of employee performance, business planning, disciplinary procedures (including the investigation and reporting of complaints), and compliance with legal obligations, policies, and procedures.
Clinical Trial
- Keeping your Personal Data confidential and secure.
- Using and disclosing your data for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation.
Categories of Third Parties Engaged by CMI for Clinical Trials
- Wholly owned subsidiaries/Affiliates of CMI
- Contract Research Organisations (CROs)
- Statistical Research Analysts
- Clinical advisors
- Technical providers for hosting and software services
- Safety boards
Choice
Accountability for onward transfer
(i) transfers such data only for limited and specified purposes; (ii) has ascertained that the Data Processor is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) takes reasonable and appropriate steps to ensure that the Data Processor effectively processes the Personal Information transferred in a manner consistent with the CMI’s obligations under the Principles; (iv) requires the Data Processor to notify CMI if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), CMI will take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) will provide a summary or a representative copy of the relevant privacy provisions of its contract with that Data Processor to the Department of Commerce upon request.
Security
Data integrity and purpose limitation
Access and correction
Verification
Recourse, enforcement and liability
Limitation on scope of principles
Changes to this policy
Contact information
Attention: Privacy department
Concept Medical B.V.
Hogebrinkerweg 33, 3871KM Hoevelaken, The Netherlands.
privacy@conceptmedical.com.
Privacy Policy
- Purpose: Your privacy is very important to us. This Notice sets out the way in which we process your information when you use our Website or other digital platforms in accordance with data protection laws.
- Applicability: This Notice applies to individuals visiting our Website. It applies only to the information we collect through our Website, in email, text, forms, and other electronic communication received through or in connection with our Website.
Information We May Process (“Personal Data”)
We may collect your personal data including but not limited to
- Various usage and user metrics when you visit and use our Website including but not limited to cookies, IP addresses, device and software identifiers, referring and exiting URLs, onsite behaviour and usage information, feature use metrics and statistics, usage history, and location data. While some of this data is captured directly from you, for example, by way of web forms and web log servers, others can be captured indirectly from third parties, for example, tracing organization details, preferences, and interests on the basis of IP address and browsing history respectively.
- Information that you provide to us for the purpose of registering to use the Website, subscribing to the Company’s service, posting material, requesting further services and/or applying for a position of employment with us, including but not limited to your job title, name, address, telephone number, e-mail address, social media profile, curriculum vitae / resume, skillset, preferences, and interests.
- Information that you provide to us by completing any other forms on the Website or if you contact us with comments or specific requests (including but not limited to your name, address, telephone number, and e-mail address). We may also ask you for information when you report a problem with the Website.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Means of Processing Data
We may process your Personal Data through the following means:
- Cookies
- Web job application forms/careers applications
- Web forms
- Newsletter sign-ups
- Registration for an event/activity
- Information request mechanism (for example, Contact Us).
COOKIES
Our Website uses these cookies to collect information and to improve our Service by making your interaction with us faster and more secure. They may be used for the purposes of managing your preferences, maintaining and optimizing security, marketing, communication, analytics, and research.
- Essential Cookies or Strictly Necessary Cookies: These cookies are essential to the functioning of our Website and for you to move around the Website. Without these cookies, certain features could not function. No information about your browsing habits is gathered by these cookies.
- Functional Cookies: These cookies remember how you prefer to use our Website and improve the way our Website works. These are persistent cookies that help us recognize you as an existing user, so it’s easier for you to return to our Website without signing in again. After signing in, the persistent cookies stay on your browser and will be read when you return to our sites. These remain on your computer/device for a pre-defined period of time.
- Performance Cookies: Some cookies help us with the performance and design of our Website. For example, these cookies show us statistics, which are the most frequently visited pages on the Website, help us record any difficulties you have with the Website, and whether our advertising is effective or not.
- Targeting or Tracking Cookies: On certain pages of our Website, we use cookies to help us understand your interests as you browse the Website, so we can tailor and deliver to you a more personalized service in the future. This assists us in delivering relevant, interest-based ads to you.
Grounds for Lawful Processing of Personal Data
Use of Personal Data
- Communication: We may use your information to administer and provide services you request or have expressed an interest in, to communicate with you in case of any inquiry or support, for sending newsletters, updates and promotional materials, for seeking your opinion and feedback, to notify you about changes to our service, and/or tailor any communications that we may send you.
- Career Offering: We provide career options on our Website for the users. They can apply to them using our online forms/links by registering with us. Once you are registered with us, we may use your personal data for various job openings that we have in our company and for sending you communication in case of job vacancies.
- Advertising: We may use your information to carry out advertising and market research based on behavioural metrics, geo-location data, demographic data, and marketing preferences we capture. We may permit certain third-party companies to help us tailor advertising based on use.
- Activity Tracking: We may use your information to track your activity on our digital platforms and personalize and improve your experience. This can be used to create an individual profile for you so that we can understand and respect your preferences or for profiling purposes to enable us to personalize and/or tailor any marketing communications that you may consent to receive from us.
- Optimization: We may use your information to operate, improve, and maintain our site, and to prevent fraud and abuse.
- Information Sharing: We may use and share your information with third parties with whom we have a contractual relationship.
Transferring Your Personal Data
Children’s Privacy
Security: How Secure is Your Information With Us?
Changes to the Notice
Third Party Websites
Your rights and your personal data
- The right to access information: At any point, you can contact us to request the information we hold on you, as well as why we have that information, who has access to the information, and where we obtained the information from. Once we have received your request, we will respond within one month.
- There are no fees or charges for the first request, but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information: If the data we hold on you is out of date, incomplete, or incorrect, you can inform us and your data will be updated.
- The right to have your information erased: If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (e.g., because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing: You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability: You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent: You can withdraw your consent to the processing of data at any time for any processing to which consent was sought. You can withdraw your consent easily by telephone, email, or by post (see Contact Page).
- The right to object to the processing: You have the right to object to the processing of personal data where applicable.
- The right to lodge a complaint: You can lodge a complaint with the Data Protection Officer at privacy@conceptmedical.com.
- How long do we keep your personal data?
FAQs
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