Last Updated: September 16, 2021
1 Information Collection and Processing
1.1 Information you provide to us directly
We collect and process information you provide directly to us. For example, we collect information when you access or participate in any interactive features of the Services, fill out a form, request whitepapers, brochures, PDFs or case studies, or otherwise communicate with us. We also collect your information if you use the VCT Registry as an “Authorized User”, which is an employee, freelancer or other personnel authorized to use the VCT Registry by VCT and one of our customers.
We collect and store the following personal information and use it for typical business purposes (including providing, maintaining, and improving our Services, for security and anti-fraud purpose, for legal obligation compliance, and to enforce any terms governing use of our Services) and as described more specifically below:
- Personal Identifiers. We collect personal identifiers (such as your name, registration or log-in information for your use of our website , email address, telephone number, or similar identifiers) and use them to respond to your comments, questions, calls, messages, emails and other requests; to provide you with free demos of the VCT Registry and other products or services we offer; to send you whitepapers, brochures, PDFs or case studies that you ordered; and to send you marketing communications.
- Business-Related Information. We may receive business-related information (such as your company’s name) and use this information to provide you with free demos of the VCT Registry and other products or services we offer and for marketing purposes.
- Preferences. We collect preference information (such as your choices and preferences in receiving information about the Services and other marketing, as well as your communication preferences) and use it to respond to your request, or for marketing purposes.
- Communications Content and Information. We receive communications you submit, which includes your questions or comments that you send us, messages or email content that you send us, or our conversations over the phone. We use this information to respond to your comments, questions, messages, emails, and other requests, or when you contact us by phone or physical mail; to provide you with free demos of the VCT Registry and other products or services we offer; and to send you whitepapers, brochures, PDFs or case studies that you ordered.
- Authorized User Information. If you are an Authorized User, we collect personal identifiers (such as your name, title, email address, user name, password, country, and the name of the relevant study site, site location, including zip code and address, work phone, mobile phone) as well as logs and usage meta data, your preferences (such as language preferences when you conduct the Authorized User training), information on your training success, and use them to register, administer, and secure your account as an Authorized User; to provide you with the VCT Registry and training regarding the use of the VCT Registry; and to send you technical notices, updates, security alerts and support and administrative messages.
- Inferences. We may draw inferences from the categories of information described above, , preferences and aptitudes. This information may be used so that we can improve future user experiences with us and to provide a more personalized experience.
1.2 Information collected from job applicants
Job application information (such as professional and employment-related information and education information) may be collected by us directly through the website, by email, or at one of our locations, or job application information may be collected on our behalf by our contracted third-party administrator(s) for applicant tracking purposes and by background check providers. These third-party administrators are permitted to process the information you provide only for purposes of providing services to us. We process the information to review your job application and for other employment-related purposes consistent with applicable law, including to contact you regarding your application and/or to contact you about other job openings that we believe may be of interest to you.
1.3 Information automatically collected
When you access or use our Services, we automatically collect through cookies and similar technology and process further information about you, including personal identifiers (such as your IP address, MAC address, and device identifiers (such as information about the computer or mobile device you use to access our Services)) and information concerning your usage activity on the Services (such as log information about your use of the Services, including the type of browser you use, access times, and pages viewed) (collectively, “Technical Information”). We use this information to deliver our Services and its content to you; for IT security, in particular, to detect investigate, and prevent fraud and other illegal activities and protect the rights of VCT and others; and to enforce, or otherwise use in connection with, any term governing use of our Services. For more information about Cookies and how to configure your cookie choices, please see Section 3 below.
2 Sharing of Information
We may provide third parties with personal information we collect (as described above) for our business and commercial purposes to assist us in providing products and services to you, including to process transactions, deliver products at your request, to help us communicate marketing, and as more specifically described below.
- To Provide and Improve our Products and Services, including the VCT Registry. We share personal information as necessary to operate our business, such as with vendors, consultants and other service providers who need access to such information to carry out work on our behalf. For example, we may provide your name and contact information to scheduling service providers to schedule a demo of our services and products. We require that third-party providers use personal information only for that purpose for which we provided it them, and we also require assurances that they will appropriately protect personal information entrusted to them.
- To Comply with the Law and Legal Process. We may access, preserve, and share personal information concerning you in response to a request for information if we reasonably believe, in our judgement, disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- To Protect our Products and Services, including the VCT Registry. We also may access, preserve, and share personal information if we believe, in our judgment, your actions are inconsistent with our user agreements or policies, or to comply with a legal obligation to protect the rights, property and safety of VCT or others. For example, we may provide information, including IP address information, to our service providers to protect the Services, such as for fraud detection purposes.
- Sales, Mergers, and Acquisitions. In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide personal information and transaction history associated with each such business unit to the persons and/or entities assuming control of such business unit or as otherwise necessary to complete the transaction as permitted by law or contract.;
- Authorized Users. If you are an Authorized User, we will also share your information with other Authorized Users and your study site as necessary to provide the VCT Registry to you and/or them or with your consent.
3 Cookies and Similar Technologies
4 Data Retention
We store the personal information we collect and process about you for as long as is necessary to fulfill the purpose(s) for which it was collected or as permitted or required by law. Specifically, we store your information:
- For the purpose of providing the services that you requested, including the services that are available to Authorized Users only – as long as necessary to perform our contractual obligations and provide the VCT Registry to you;
- For the purpose of responding to your comments, questions, messages, and other requests – as long as is necessary to process your request;
- For the purpose of sending you any whitepapers, brochures, PDFs, or case studies, or providing you with free demos – as long as necessary to comply with your request;
- For the purpose of sending you any marketing communications – as long as you show an interest in our products or services, or until you withdraw your respective consent in receiving these communications or object to receiving it;
- For the purpose of detecting, investigating, and preventing fraud and other illegal activities and protect the rights and property of VCT and others – as long as is necessary based on any terms governing use of our Services, legal provisions, or until the investigations are settled; and
- For the purpose of sending specific technical notices, updates, security alerts, and support and administrative messages to Authorized Users only – as long as necessary to perform our contractual obligations and administer the respective Authorized User account.
Apart from the above, we store your information only for the assertion of or defense against legal claims, including any terms governing use of our Services, or as long as a legal obligation to store exists.
5 Transfer of Information to the United States of America and Other Countries
VCT is based in the United States of America (“U.S.”) and we process and store information in the U.S. (however, if you are an Authorized User in the EU/EEA your Authorized User Information will be hosted in within the EU). As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide an equivalent level of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Please contact us as described in Section 9 if you want further information on or a copy of the specific mechanism used by us when transferring your personal information out of the EU or the EEA. VCT participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. While we acknowledge that the Privacy Shield Framework is no longer a means for satisfying the adequacy requirement as to transfers of personal information from the member states of the EU or EEA to the U.S., VCT remains committed to handling all personal information received about data subjects in member states of the EU or EEA in accordance with the Principles of the Privacy Shield Framework.
6 Privacy Rights - Generally
Certain jurisdictions impose specific legal requirements and privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You may be able to use the Services to access and update the information that you have provided to us through your use of the Services or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, please send an email to us at: info@VerifiedClinicalTrials.com.
When you make a request, we may require that you provide information and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event.
If you are a subscriber to promotional emails from VCT, you may opt out of receiving promotional emails from VCT by following the instructions in those emails or by emailing us at info@VerifiedClinicalTrials.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
If you are an Authorized User and wish to deactivate your Authorized User account, please email us at info@VerifiedClinicalTrials.com, but note that we may retain certain information as required by law.
7 Users in the European Union and the European Economic Area
If you are a user in the European Union (“EU”) or the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data (also referred to as “personal information” above):
7.1 Controller and Data Protection Officer
The company referred to in Section 9 is responsible for the processing of your personal data (the data controller).
You can contact our data protection officer at any time:
- by phone at +1 (888) 960-3099 or at +1 (516) 998‑7499 or at +353 1 571 9209 or at +886 0801127903;
- by email at email@example.com; or
- in writing to Verified Clinical Trials LLC, 1305 Franklin Avenue, Suite 150, Garden City, New York 11530, USA.
7.2 Legal Basis for Processing
If you are a resident of the EU or the EEA, when we process your personal data as described in Sections 1-3 above, the processing is based on the following legal grounds:
7.2.1 Making the Services available to you
We process your personal data (Technical Information) to deliver the Services and its essential content based on our legitimate interest in offering the Services and its functionalities to you (Article 6(1)(f) GDPR).
7.2.2 Contract Performance, in particular Processing in Context of the Provision and Administration of Authorized User Accounts
We process your personal data (Authorized User Information) to perform our responsibilities under our contract with you, such as, for example, the End User License Agreement for your Authorized User account, and to provide you with training regarding the use of the VCT Registry (Article 6(1)(b) GDPR).
7.2.3 Responses to your Requests
On our website, we offer you different contact options, such as the contact form for comments or questions, the form to schedule a free demo (see Section 7.2.4 specifically), our chat (see our cookie management tool), the option to call us, send us an email or contact us by physical mail). We are striving to respond to any query that we receive to your satisfaction and seek to understand your needs and specific questions concerning our products and Services. Therefore, we ask you to provide us with certain personal data in so-called mandatory fields, depending on the contact option that you chose. According to our experience, the respective data is necessary for the satisfactory response to your request.
Please review which contact option fits to your request best. For instance, if you are of the opinion that none of the convenient contact functionality on our website fits to your request, you can call us or send us an email. In any case, we process your personal data in conjunction with your request to respond to it and any potential follow-up questions only, as further described below.
When we respond to your comments, questions, messages, emails or other requests, or when you contact us by phone or physical mail, we process your personal data (Personal Identifiers, Business-Related Information, Preferences, Communications Content and Information) based on Article 6(1)(b) GDPR if our communication results in a contract with you. If our communication does not result in the conclusion of a contract, our processing is based on our legitimate interest in responding to your queries (Article 6(1)(f) GDPR). If you contact us in order to execute your statutory data subject rights, the legal basis is Article 6(1)(c) GDPR.
7.2.4 Free Demos and the Provision of other Services that you requested
When we provide you other services that you requested, such as, for example, free demos, we process your personal data (Personal Identifiers, Business-Related Information, Preferences, Communications Content and Information) under Article 6(1)(b) GDPR if our communication results in a contract with you. If our communication does not result in the conclusion of a contract, our processing is based on our legitimate interest in offering convenient functionality, such as our free demos, that helps you to learn more about us and our products or Services (Article 6(1)(f) GDPR).
7.2.5 Whitepapers, Brochures, PDFs or Case Studies
On our website, you can request material such as whitepapers, brochures, PDFs or case studies about detecting and preventing professional research subjects and preventable protocol violations in clinical trials (collectively, the “Material”).
- Material: We process your email address to send you the email that contains the download link to the respective Material. We process your name and company name to address this email to you and your company. This processing is based on Article 6(1)(b) GDPR.
- Verification email: We process your email address to send you a verification email so that we can verify that the owner of the email address that has been entered in the online form on our website belongs to you and that you have consented (so-called double-opt in procedure). We also collect meta data (such as the information that you verified your email address and a time stamp) when you clicked on the verification hyperlink. This processing is based on Article 6(1)(c) GDPR.
- News, specific offers, information material by phone or email: The Materials are an advertising-financed offering by VCT. This means that you may download the Materials only if you agree to receiving marketing communications from VCT, and that we process your personal data also for the purpose of informing you about our products or services or to provide you with further material similar to the Material by email and, if you have indicated your phone number, by phone. We address you and your company personally in these communications and, therefore, process your name and company name for this purpose. The legal basis for this processing operation is Article 6(1)(a) GDPR – your consent. You can withdraw your consent at any time with future effect. You may keep all Material that you have received at the time of such withdrawal of consent.
- There may be some other scenarios where we will ask you for your consent if necessary under the GDPR. Such consent will be collected separately with additional information.
7.2.6 IT security
We process your personal data (Technical Information as well as copies of your Personal Identifiers, Business-Related Information, Preferences, Communications Content and Information) to detect, investigate, and prevent fraud and other illegal activities and protect the rights of VCT. This is our legitimate interest. The processing is based on Article 6(1)(f) GDPR.
7.2.7 Enforcement of rights and obligations
We process your personal data (Technical Information as well as copies of your Personal Identifiers, Business-Related Information, Preferences, Communications Content and Information) to enforce any terms governing the use of our Services. This is our legitimate interest. The processing is based on Article 6(1)(f) GDPR.
We process your personal data (Technical Information as well as copies of your Personal Identifiers, Business-Related Information, Preferences, Communications Content and Information) to comply with our legal obligations. If the respective legal obligations are based on law of the European Union or of a member state of the European Union, the legal basis for this processing is Article 6(1)(c) GDPR. In any other cases, it is our legitimate interest to comply with our legal obligations and the processing is based on Article 6(1)(f) GDPR.
7.3 Data Subject rights
If you are located in the EU or the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or received in a structured, commonly used and machine-readable format if the statutory requirements are met. You may also have the right to object to, or request that we restrict, certain processing, and to withdraw your consent at any time with effect for the future. In the case of direct marketing, as the data subject, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising, including profiling insofar as it is linked to such direct marketing. If you would like to exercise any of these rights, you may contact us as indicated below.
7.4 EU and UK representatives
- For the European Union: Linda Brandt, Senliser Straße 46 D-40764 Langenfeld, Germany, phone: +49 (0)217 3993 5930, email:firstname.lastname@example.org.
- For the United Kingdom: Reed Smith LLP, The Broadgate Tower, 20 Primrose Street, London EC2A 2RS, United Kingdom, email: email@example.com.
Linda Brandt and Reed Smith LLP are authorized to receive communications, on our behalf, relating to our European and UK personal data practices.
7.5 Questions or complaints
If you are a data subject located in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside. For contact details of your local data protection authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
8 Users in California
8.1 CCPA rights
California consumers have the following rights under the California Consumer Privacy Act (“CCPA”):
8.1.1 Right to know
California consumers have the right to request that we provide additional information about our data collection, use, and disclosure practices in connection with the consumer’s personal information. California consumers also have the right to request the specific personal information collected about the consumer over the past 12 months.
8.1.2 Right to delete
California consumers have the right to request that we delete their personal information that we collected from them and retained, subject to certain exceptions.
8.1.3 Right to opt-out of sale
California consumers have the right to opt out of the sale of their personal information to third parties. However, we do not “sell” personal information for money or other consideration.
8.1.4 Right to non-discrimination
California consumers have the right to not be discriminated against for exercising any of these rights list above.
8.2 Additional information
California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. Such authorized agent must be registered with the California Secretary of State. An authorized agency must follow the process described below to make a request, and we will additionally require the authorized agent to verify his/her own identity and we will confirm the agent’s authority with the California consumer about whom the request was made.
To make requests, California consumers may call us at 1-888-960-3099, email us at firstname.lastname@example.org, or contact us through the web page located at www.verifiedclinicaltrials.com. Consumers may be required to submit name, email address, and/or zip code so that we can verify the request.
Please see our cookie management tool for information about the collection and use of personal information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Services.
8.3 Do not track
At this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
8.4 Shine the light
Additionally, California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. However, we do not share personal information with third parties for their direct marketing purposes.
9 Contact us
Our EU representative is Linda Brandt, Senliser Straße 46 D-40764 Langenfeld, Germany, phone: +49 (0)217 3993 5930, email: email@example.com.
Our UK representative is Reed Smith LLP, The Broadgate Tower, 20 Primrose Street, London EC2A 2RS, United Kingdom, email: firstname.lastname@example.org.
Our Grievance Officer for India pursuant to the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is Kerri Weingard, Verified Clinical Trials LLC, 1305 Franklin Avenue, Suite 150, Garden City, New York 11530, USA, phone: +1 (516) 469-3197, email: email@example.com