Effective Date: [Insert Date]
This Privacy Policy describes how TrialCanopy Ltd ("Company," "we," "us," or "our") collects, uses, and discloses personal data when you visit our website or use our services. Your privacy is important to us, and we are committed to protecting your personal data and ensuring its confidentiality.
Alex Garner serves as the Data Privacy Officer for TrialCanopy Ltd. If you have any questions, concerns, or requests regarding the processing of your personal data or this Privacy Policy, please contact Alex Garner at privacy@trialcanopy.com or by mail at:
TrialCanopy Ltd
20-22 Wenlock Road
London, N1 7GU
GB
We collect the following categories of personal data:
We collect and use personal data for the following purposes, with your consent:
We kindly request your consent to collect your personally identifiable information when you register for a TrialCanopy Ltd program or service. By providing your consent, we will clearly explain the purpose of collecting your information and how we intend to use it for that specific program or service. We also provide you with the option to withdraw your consent ("opting out" or "unsubscribing") if you no longer wish to participate in the program or receive further information from us.
In the event that we intend to use your information for purposes that are different from the original collection, we will provide you with an effective method to opt out of such secondary uses. It's important to note that if we share your personally identifiable information with a sponsor or manager of a clinical trial (referred to as a "Sponsor"), the Sponsor may retain access to your personally identifiable information even if you choose to discontinue receiving additional information from us.
We may disclose your personal data to third parties in the following circumstances:
a. Service Providers: We may engage third-party service providers who assist us in providing our services. These providers have access to personal data only as necessary to perform their functions and are obligated to maintain its confidentiality.
b. Legal Obligations: We may disclose personal data if required by law, regulation, or legal process, or in response to a valid request from law enforcement or government authorities.
c. Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, personal data may be transferred as part of the transaction. We will notify you via email or prominent notice on our website before your personal data becomes subject to a different privacy policy.
We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. When personal data is no longer needed, we securely delete or anonymize it.
We implement appropriate technical and organizational measures to protect the security of your personal data and prevent unauthorized access, disclosure, alteration, or destruction.
You have certain rights regarding your personal data, including the right to access, correct, delete, or restrict its processing. You also have the right to withdraw your consent at any time, where applicable. To exercise these rights or make any other privacy-related requests, please contact our Data Privacy Officer using the contact information provided in Section 1.
We encourage you to update the information you provide to us, such as providing us with a new mailing or email address, a name change, or a change in the medical conditions that you have notified us about. This will help us continue to provide information to you that best meets your needs. In addition, TrialCanopy Ltd complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. In addition, to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of the identity of the requesting individual. If you delete your user content from the Site, copies of your user content may remain viewable in cached and archived pages or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including user content, is governed by our Terms of Use.
TrialCanopy Ltd, at all times, follows applicable country, federal, and state laws and legal frameworks in effect to ensure that your personally identifiable information is secure and that your privacy rights are respected and protected.
This covers any collection and processing of your personally identifiable information - see Personally Identifiable Information Collected From You above (including storage, retrieval, use, disclosure/sharing, restriction, blocking, and erasure or destruction).
Depending on your country's specific data laws, you may have the right, without discrimination, at reasonable intervals, to know about your personally identifiable information that TrialCanopy Ltd holds (to make a DSAR). Depending on your country's specific data laws, DSARs may include the right to:
TrialCanopy Ltd has the right and an obligation to ask for a written authorization or other documents supporting your DSAR. This is for the purpose of confirming your identity and DSAR eligibility - and any supporting documentation shall be proportionate and not unduly retained by TrialCanopy Ltd for any other purpose.
TrialCanopy Ltd also has the right to refuse any manifestly unfounded DSARs - and in such circumstances, shall provide you with a written justification for any refusal. You will have the right to make a complaint to your country's supervisory authority at any time.
DSARs are free of charge to you for up to two requests within a calendar year. TrialCanopy Ltd reserves the right to charge you a reasonable administration/postage fee in the following circumstances:
If making more than two of the same category of DSAR within the same 12-month period.
If requesting more than one hard-copy postal mailing per DSAR (including requests for multiple recipients or more than two copies of documents per recipient and/or requests for special courier).
TrialCanopy Ltd is compliant with all US federal and state-specific privacy laws and regulations that govern your personally identifiable information. This includes, but is not limited to:
California: Commencing January 2023, the California Consumer Privacy Act (CCPA) 2018 - as updated by the California Privacy Rights Act (CPRA) 2020 - permits TrialCanopy Ltd users that are California residents to access, rectify, update, restrict processing, delete/withdraw their personally identifiable information or opt-out of services.
Additionally, California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes.
Virginia: Commencing January 2023, the Virginia Consumer Data Protection Act (VCDPA) 2021 permits TrialCanopy Ltd users that are Virginia residents to access, rectify, update, restrict processing, delete/withdraw their personally identifiable information or opt-out of services.
Colorado: Commencing July 2023, the Colorado Privacy Act (CPA) 2021 permits TrialCanopy Ltd users that are Colorado residents to access, rectify, update, restrict processing, delete/withdraw their personally identifiable information or opt-out of services.
If you have any questions/requests related to your USA privacy rights, please send an email to: privacy@trialcanopy.com.
In accordance with the GDPR; General Data Protection Regulation (EU) 2016/679, citizens of the EU may access, rectify, update, or delete/withdraw their personally identifiable information by sending an email to our European Representative DataRep.
In accordance with the UK Data Protection Act 2018, the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC), the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), and the European Union (Withdrawal) Act 2018, citizens of the UK may access, rectify, update, or delete/withdraw their personally identifiable information by sending an email to privacy@trialcanopy.com.
Our UK Data Protection Officer (DPO) may be contacted directly via post or email: The Data Protection Officer, TrialCanopy Ltd, 20-22 Wenlock Road, London, N1 7GU, GB – email: privacy@trialcanopy.com.
If you have any questions about our Privacy Policy or for any complaints, please email us at: privacy@trialcanopy.com.
TrialCanopy Ltd's website is not intended for children under 13 years of age. No one under age 13 may provide any personally identifiable information to or on the Site. We do not knowingly collect personally identifiable information from children under 13. If you are under 13, please refrain from using or providing any information on this Site or through any of its features, and do not provide us with any information about yourself. If we become aware that we have collected or received personally identifiable information from a child under 13, we will promptly delete that information.
If located in California or the European Economic Area, the same restrictions apply to children under the age of 16 years.
Any information entered on behalf of a child under 13 years of age (or 16 years if located in California or the European Economic Area, or 18 years if located in Asia) must be strictly provided by a parent or legal guardian.
If you believe that we might have any information from or about a child, please contact us at info@trialcanopy.com.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website or through other means of communication.
Please read this Privacy Policy carefully and contact us if you have any questions or concerns.
