Science 37 Mobile Application Privacy Policy

Science 37 Web-based and Mobile Application Platform Privacy Policy

 Last Updated: October 2, 2020

 Introduction

Science 37, Inc. (“Science 37”) takes compliance with data protection laws very seriously and is committed to protecting your Personal Information. You have been provided access to Science 37’s Web-based and/or Mobile Application Platform (“Platform”) in order to facilitate your participation in a clinical trial.  This Science 37 Platform Privacy Policy (“Privacy Policy”) outlines our data handling practices, and in particular how we collect, use, and disclose Personal Information that you provide during your interactions with the Platform.  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 your Informed Consent Form.

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

We collect the following Personal Information about you in the Platform to support the clinical trial:

  • Platform username
  • Your name, physical address, email address, and phone number
  • Your age, gender, date of birth, and race/ethnicity
  • Health information about you applicable to the clinical trial

We may also collect information about your geographic location (country) when you are using the Platform. We use this information for service-related purposes (such as optimizing your user experience), supporting compliance (your location can determine what laws or regulations apply to you), and providing language preference customizations.

We further collect data about how individuals use our Platform to improve the use of the Platform 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 Platform users access a specific Platform feature to inform future improvements.

 How is Your Personal Information Collected?

We will collect information from you when you complete forms on the Platform. We may also collect information when you correspond with us (for example, by email or chat) and when you report a problem with the Platform.

 How We Use and Disclose Personal Information

We use the Personal Information that we collect for the legal, contractual, and business purposes associated with your participation in the clinical trial.

We may also process your Personal Information for the following business purposes:

  • To manage our relationship with you, including notifying you of changes to the Platform;
  • To administer and protect the security of the Platform, including troubleshooting, data analysis and system testing;
  • To assess trends about utilization of our Platform so we can improve the Platform; and
  • To comply with applicable laws or to respond to requests from public and government authorities.

Your Personal Information may be shared with third parties for the purpose of facilitating your participation in the clinical trial. These third parties include the clinical trial sponsor, regulatory authorities, the Institutional Review Board (“IRB”) and partners supporting the clinical trial, such as drug shipment vendors.  Details on the use of your Personal Information for the purposes of the clinical trial can be found in the Informed Consent Form.

Science 37 does not sell your Personal Information.

Transfer and Storage of Personal Information

The Platform is operated in the United States and hosted through Amazon Web Services (“AWS”) using AWS data centers in the U.S. and EU, although data may be collected from wherever clinical trial participants are located. We may transfer your Personal Information to 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.

 

For EU and Swiss Residents

Science 37 will transfer Personal Information from the EU and/or Switzerland in accordance with the European Commission-approved Standard Contractual Clauses. If you have any privacy-related questions about the transfer or storage of your Personal Information, please contact us at Privacy@Science37.

 Data Security

Science 37 is committed to protecting the Personal Information you share with us.

We 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 federal, regional, country, state, provincial, or local data retention regulations.

Your Rights

Depending on your jurisdiction, you may be entitled to certain legal rights with respect to your Personal Information. These may include the right to:

  • Request accessto your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correctionof the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure (right to be forgotten)of your Personal Information. This enables you to ask us to delete or remove personal data in some circumstances. Note, however, that we may not be able to comply with your request of erasure for specific legal reasons related to a clinical trial, which we will notify you of, if applicable, at the time of your request.
  • Object to processingof your Personal Information where we are relying on a legitimate interest and you feel it impacts your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
  • Request restriction of processingof your Personal Information. You can ask us to restrict the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of that Personal Information or you object to us processing your Personal Information.
  • Request the transferof your Personal Information to you or to a third party. We will provide to you, or a third party designated by you, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use, or where we used the information to perform a contract with you.

To exercise your rights, please contact us using the contact information available at the end of this Privacy Policy. 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 for the purpose of a clinical trial, or where the Personal Information may be exempt from disclosure due to applicable law or regulatory requirements. We will respond to your request within a reasonable timeframe and provide you with an explanation if we are unable to fulfill your request.

If you withdraw or are withdrawn from the clinical trial, we will not collect or receive any new information from the Platform. 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 clinical trial purposes, including compliance with regulatory requirements, unless we are compelled under local law to destroy the information.

Changes to the Privacy Policy

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

Complaints

If at any time you feel Science 37 has violated your privacy rights, you may contact us directly at Privacy@Science37.com or you may file a complaint directly with any relevant Supervisory Authority.

To exercise your rights, please contact us at Privacy@Science37.com

 

Contact Details

Science 37, Inc.

Jen Davis, Deputy General Counsel and Privacy Officer

Privacy@Science37.com

12121 Bluff Creek Drive, Suite 100

Los Angeles, CA 90094