Science 37 Mobile Application Privacy Policy

Introduction

This Science 37 Platform Privacy Policy (“Privacy Policy”) outlines our data handling practices, and in particular how we collect, use, and disclose Personal Information.  It covers all Personal Information that you affirmatively provide during your interactions with the Science 37 App and information that we automatically collect when you interact with the Science 37 App.  The Privacy Policy is applicable worldwide, and also describes rights you may have to control our use of Personal Information and how to exercise those rights.

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

This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy. If we propose to make any material changes, we will notify you by means of an email notice prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Use by Minors

The Science 37 App is not intended for use by individuals under the age of 18.  Please do not provide any personal information if you are under the age of 18.

Important Information and Who We Are

Science 37 is a data processor for the purposes of the clinical trial.  Science 37 provides the technology platform, the Science 37 App, that facilitates the sponsor’s decentralized clinical trial. Science 37 only processes your data according to the instructions of the sponsor, the data controller, of the clinical trial.

We have appointed a Privacy Officer and if you have any questions about this Privacy Policy, please contact our Privacy Officer.

Contact Details

Science 37, Inc.
Jen Davis, Deputy General Counsel
Privacy@Science37.com
12121 Bluff Creek Drive, Suite 100
Los Angeles, CA 90094

The Information We Collect about You

The Science 37 App may ask you to submit or provide access to Personal Information applicable to your participation in the clinical trial.  We collect the following kinds of Personal Information about you:

  • Science 37 App username
  • Name, physical address, email address, phone number
  • Age, gender, date of birth, race
  • Health information applicable to the clinical trial

We also collect aggregated data such as statistical or demographic information to improve the use of the Science 37 App for current and future clinical trial participants.  Aggregated data could be derived from your personal information but it will not directly or indirectly reveal your identity.  For example, we may aggregate your usage data to identify trends about how Science 37 App users access a specific Science 37 App feature to inform future improvements.

If you contact the Help Desk with questions about the Science 37 App, the privacy information you can find here is also applicable.

How Is Your Personal Information Collected?

We will collect information from you when you complete forms in the Science 37 App.  We may also collect information when you correspond with us (for example, by email or chat) and when you report a problem with the Science 37 App.

  • Information we collect about you and your device. Each time you use the App we will automatically collect personal data including Device, Content and Usage Data.
  • Location Data. We may collect information about your geographic location (country, state, or city level) when you are using the Science 37 App. 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 do not “track” you using location data.

How We Use and Disclose Personal Information

We process your Personal Information for the legitimate interest and business purpose of facilitating  your participation in the clinical trial.

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

  • To manage our relationship with you including notifying you of changes to the Science 37 App;
  • To administer and protect the security of the Science 37 App including troubleshooting, data analysis and system testing;
  • To assess trends so we can improve the Science 37 App; and
  • To comply with applicable law 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 IRB and partners supporting the clinical trial such as a drug shipment vendor.

Science 37 does not sell your Personal Information.

Transfer and Storage of Personal Information

The Science 37 App is generally hosted and operated in the United States (U.S.) through Amazon Web Services (AWS), though 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.  By using the Science 37 App, you agree to the transfer and storage of your Personal Information in the U.S.

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.

If you have any questions about the security of your Personal Information please contact us at Privacy@Science37.com.

Data Retention

All clinical trial data, including Personal Information, will be retained for the length of the clinical trial or as required by the contract with the clinical trial sponsor.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Subject Requests

We do our best to give you reasonable controls over the Personal Information we process about you. Depending on where you reside, you may be entitled to certain legal rights with respect to your Personal Information.

Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process your Personal Information for the purpose of the 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.

You have the right to:

  • Request access to 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 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 erasure 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 the clinical trial which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Information where we are relying on a legitimate interest and you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal 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.
  • Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you withdraw or are withdrawn from the clinical trial, we will not collect or receive any new information from the Science 37 App. However, information already collected, processed, and stored up to the time your withdrawal request is received will not be deleted, and may continue to be used for clinical trial purposes including compliance with regulatory requirements.

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