Science 37-privacy policy - CN

Science 37 Web-Based and Mobile Application Platform Privacy Policy

Last Updated: December 14, 2021

Introduction

Science 37, Inc. (“Science 37”), located at 600 Corporate Pointe, Suite 320, Culver City, California, 90230 United States understands the importance of your Personal Information and is committed to protecting your Personal Information. You have been provided access to Science 37’s Web-Based and/or Mobile Application Platform, as operated by ZhenChuang Co., Ltd., East Wing, F3, China World Tower B, No.1 Jianguomenwai Avenue, Chaoyang, Beijing, China] (“Operator”) in the People’s Republic of China (“Platforms”) in order to facilitate your participation in a clinical trial (together, “we”, “our”, “us”).

Sponsors make important decisions on how your Personal Information are used and disclosed and are primarily responsible for ensuring that the rules of applicable data protection and privacy laws are followed. For more information about how your Personal Information is handled in the clinical trial, your data protection rights, and whom to contact with any questions about the clinical trial, please refer to the confidentiality section of the relevant Informed Consent Form.

This Platforms Privacy Policy (“Privacy Policy”) outlines the data processing activities, and in particular how your Personal Information is being collected, use, and disclosed during your interactions with the Platforms. This is separate from the data handling practices outlined by the sponsor in the Informed Consent Form. The sponsor will be your data controller for Personal Information collected from you during the clinical trial.

As used in this Privacy Policy, “Personal Information” means any information that can be used to identify or is reasonably linkable, either directly or indirectly, to a natural person.

Information We Collect About You

With your consent, the following Personal Information may be collected from you to support your access and use of the Platforms:

Your name, email address, and phone number.

Your geographic location (country) may also be collected when you are using the Platforms. We use this information for service-related purposes such as optimizing your user experience, supporting compliance, and providing language preference customizations.

We collect data about your device such as IP address, browser name and version and device OS. This data is used to detect any suspicious access to the Platforms for security purposes and to improve browser and device support based on usage data.

We further collect data about how you use the Platforms, navigate through the eForms in the Platforms and interact with the Platforms for the purpose of allowing you to continue your use with the Platforms and improving the Platforms for current and future clinical trial participants. This data may be derived from your Personal Information, but it will not directly or indirectly reveal your identity. All data used for these purposes will involve aggregated data and will not be analyzed, used or disclosed at an individual level. For example, we may aggregate overall usage data to identify trends about how Platforms users access a specific Platform’s feature to inform future improvements.

How is Your Personal Information Collected?

With your consent, we will collect information from you when you register for an account, download our Platforms, log in to our Platforms, and/or complete forms on the Platforms. We may also collect information when you correspond with us (for example, by email or chat) and when you report a problem with the Platforms.

For more information around how your Personal Information may be collected by the sponsor through the eForms, or by other means when you participate in a clinical trial, we encourage you to review the Informed Consent Form provided by the respective sponsor.

SDK

We use third party software development kits (SDKs) on our Platforms to facilitate video conference calls between clinical trial participants and staff. Details of the SDK is set out below:

SDK Name: Zoom Meeting SDK

SDK Provider: Zoom Video Communications, Inc.

Data Collected via SDK:

Customer Account Information: Company Name, Customer Account Owner Contact Information (Name, Email, Phone), Customer Business Contact Information (Name, Email, Phone), Business Address, Customer Account Type, Customer Account Plan, Scheduled Meetings
User Profile: First Name, Last Name, Phone (optional), Email, Password (if SSO is not used), Profile Picture (optional), Department (optional)
Meeting Metadata: Topic, Description (Optional), Participant IP Addresses, Device/Hardware Information, Meeting Statistics/Metrics, Start Time, Join Time, Leave Time

Link to SDK Provider Privacy Policy: https://explore.zoom.us/en/privacy/

Device permissions

The following device permissions may be applicable to you:

Device Permission	Corresponding Business Function	Description of Function	Whether can be turned off
Microphone	Video calling	Video calling	Yes. When it is turned off, only the corresponding functions will be affected.
Camera	Video calling	Video calling	Yes. When it is turned off, only the corresponding functions will be affected.
Bluetooth	Video calling	Video calling	Yes. When it is turned off, only the corresponding functions will be affected.
Notification	Push notifications	Push notifications	Yes. When it is turned off, only the corresponding functions will be affected.
Network	Core	Read and write data across the internet	No. When it is turned off, the app will not function.
Storage	Offline mode	Read and write data to local storage	Yes. When it is turned off, only the corresponding functions will be affected.
Photos	Upload Photos	Upload photos from mobile device	Yes. When it is turned off, only the corresponding functions will be affected.
Face ID	Authentication	Enables Face ID for authentication	Yes. When it is turned off, only the corresponding functions will be affected.

How We Use and Disclose Personal Information

With your consent, we use the Personal Information that we collect for the legal, contractual, and business purposes associated with your access and use of the Platforms to participate in a sponsor’s clinical trial.

Specifically, we may process your Personal Information for the following purposes:

To manage our relationship with you, including to administrate your user account, to notify you of changes to the Platforms;
To administer and protect the security of the Platforms, including troubleshooting, data analysis and system testing;
To assess trends about utilization of our Platforms so we can improve and upgrade the Platforms according to your requests and feedback; and
To comply with applicable laws or to respond to requests from public and government authorities, or to disclose where permitted by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or any other legal process served on us, in each case anywhere in the world.

Your Personal Information may be shared with third parties for the purpose of facilitating your participation in the clinical trial, and where applicable, in accordance with the instructions of the clinical trial sponsor. These third parties include the clinical trial sponsor, our affiliates or group companies, regulatory authorities, and partners supporting the clinical trial such as the relevant Contract Research Organization who monitor the conduct of the trial.

We may also share your Personal Information with third parties in connection with potential or actual sale of our company or any of our assets, or those of any associated company, in which case Personal Information held by may be one of the transferred assets.

We will put in place appropriate security measures and/or request these third parties to have in place security measures to protect your Personal Information.

Science 37 does not sell your Personal Information.

If we wish to use your Personal Information for purpose other than those stated in this Privacy Policy, we will obtain your consent where required by applicable laws.

Transfer and Storage of Personal Information

The Platforms are operated by ZhenChuang Co. Ltd. in the People’s Republic of China and hosted through Amazon Web Services (“AWS”) and/or its appointed vendors using AWS data centers in China.

With your consent, and where requested by the clinical trial sponsor, we may transfer your Personal Information outside of the People’s Republic of China such as the U.S. for the purposes of processing or storage. Where local law requires, we may store data locally in order to comply with such regulations.

We will only transfer or store your Personal Information outside of the People’s Republic of China where we are satisfied that comparable levels of protection are in place to protect the integrity and security of your Personal Information or adequate security measures are adopted and in compliance with applicable privacy and data protection laws.

Data Security

Science 37 is committed to protecting the Personal Information you share with us.
We adopt appropriate security measures, and/or request our Operator to have in place security measures, and utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure.

Data Retention

We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy and/or in accordance with applicable regional, provincial, or local data retention laws and regulations.

Your Rights

You may be entitled to certain legal rights with respect to your Personal Information that we collect from you when you access or use the Platforms. These may include the right to:

Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request deletion of your Personal Information and your account. This enables you to ask us to delete Personal Information in some circumstances. Note, however, that we may not be able to comply with your request of deletion for specific legal reasons, which we will notify you of, if applicable, at the time of your request.
Request withdraw of your consent. You may limit or withdraw your consent to the processing of your Personal Information at any time.
Request de-registration of your account. You may request us to de-register your account from the Platforms. However, if you request us to de-register your account, you may not be able to access the Platforms anymore. We will inform you more of the consequence if you make such a request.
Request a copy of your Personal Information for yourself or to provide such copy to a third party. We will provide to you, or a third party designated by you, a copy of certain Personal Information where it is technologically possible for us to do so.

To exercise your rights, please contact us at support@appinchina.co. Please note that some of these rights may be limited where we have an overriding contractual or legal obligation to continue to process your Personal Information, or where the Personal Information may be exempt from disclosure due to applicable law or regulatory requirements.

We will acknowledge receipt of your request within 5 business days

If you withdraw or are withdrawn from the clinical trial, we will not collect or receive any new information from the Platforms. However, information already collected, processed, and stored up to the time your withdrawal request is received may not be deleted, and may continue to be used for administrating the Platforms or where applicable, for clinical trial purposes, including compliance with regulatory requirements, unless we are compelled under local law to destroy the information.

We will only be able to process your request if this is relating to your Platforms’ user account. If you have any requests or enquiries in relation to the clinical trial, or information collected by the sponsor about you during the clinical trial, please refer to the relevant section of the Informed Consent Form provided by the sponsor.

Changes to the Privacy Policy

We may make changes to the Platforms in the future and so will need to revise this Privacy Policy to reflect those changes. We will post all such changes on the Platforms, so please review this page periodically. If we make a material change to the Privacy Policy, you will be provided with appropriate notice and we may obtain your consent for such change.

Complaints and Contact Details

If at any time you feel Science 37 or the Operator has violated your privacy rights, you may contact us directly at support@appinchina.co or you may file a complaint directly with any relevant regulatory authority.

To exercise your rights, please contact us at support@appinchina.co.