PRIVACY POLICY

Valid as of 18 February 2022, v1.2

https://clinicalaccelerator.com/ website (the “Website”) is operated by Clinical Accelerator Ltd and its subsidiaries (depending on the context, referred to as “Clinical Accelerator”, “We”, “Us”, etc.), which is the controller of Your personal data (“Personal Data”) collected when visiting our Website or communicating electronically with us via email or social networks (collectively “services”) or that You voluntarily provide to Us.

We undertake to ensure the privacy of the visitors to the Website, the legal entities they represent (business partners) and their authorized representatives (hereinafter referred to in this Privacy Policy as the “You”, “Your”).

We process Personal Data in accordance with the legal acts of the European Union, the Isle of Man and this Privacy Policy. The Website applies technical and organizational measures to protect the collected Personal Data from unauthorized processing (loss, alteration, disclosure). The terms used in the Privacy Policy shall be understood as defined in the General Data Protection Regulation No. 2016/679.

We may unilaterally without advance notice update this Privacy Policy, so please review this policy regularly. Any changes to this Policy will be noted here. If the changes significantly affect Your privacy, We will also let you know about such changes by contacting You via email (if We have it) and, if such changes are not acceptable for You, You will have the right to refuse further use of Website or services.

WHOM IS THIS PRIVACY POLICY APPLIED TO?

The Privacy Policy applies to the processing of all Your Personal Data when and is legally binding on You from the moment You start to use the Website or services. By using the Website or services, You acknowledge that You have read and agree to abide by the Privacy Policy. If You do not agree to the terms of the Privacy Policy, please do not visit (log out of) the Website or services.

If You are under the age of 18, please ensure that You have the permission of a parent / legal representative before providing us with Personal Data. Upon Our request, You will need to prove that such consent has been given.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

In operating Our Website and providing services, We collect and process the following Personal Data about You:

  1. Information (communication content, contact requisites) that You provide to Us when You electronically communicate with Us by any means and for any reason;
  2. Information that You provide by filling in forms on our Website, such as when You register and account to access or receive Our services (e.g. newsletter);
  3. Information on how You use the Website or services. When You visit the Website, We collect information that reveals the features of Your use of our services or automatically generates visit statistics. We may receive information from third parties such as social networks LinkedIn or Twitter based inside or outside the EU, or search information providers such as Google based outside the EU.For more, see privacy Policy “Cookies” section.
  4. We may also receive information from publicly available sources such as Companies House based inside the EU or from publicly available registries such as Clinicaltrials.gov based outside the EU. The information we collect is generally restricted to your name (company name), contact details, registration details. We proactively capture information that is strictly necessary to provide Our services, including commercial ones, in a practical and legally compliant way.

All of Your Personal Information requested by Us (if any) is necessary to ensure proper use the services or the Website. You may choose not to provide Us with certain information in specific cases.

WHERE DO WE GET YOUR PERSONAL DATA FROM?

We obtain Your Personal Data directly from You, generate it while You use our Website or services and / or We may obtain it from such third parties as the competent state or law enforcement authorities, which oblige us to take certain actions with respect to You or Your Personal Data.

HOW WE USE YOUR PERSONAL DATA?

The information that We collect and store relating to You is primarily used to enable Us to provide Our services to You. In addition, We may use the information for the following purposes:

  1. To provide You with information requested from Us, relating to Our services and to provide information on other services which We feel may be of interest to you, where You have consented to receive such information or We have other legal basis to provide such information;
  2. To meet Our contractual commitments to You;
  3. To notify You about any changes to Our website, such as blog posts, company’s news, improvements to Our services, etc.

WHAT IF I DON’T PROVIDE SOME OR ALL OF THE INFORMATION REQUESTED?

The impact of this will depend on what information you withhold, but the main impacts may be:

  • Clinical Accelerator is unable to provide You with services;
  • Clinical Accelerator is unable to contact You to let You know of issues with the services provided;
  • Clinical Accelerator will not be able to respond fully to requests and queries You may have.

TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION?

We undertake not to transfer Your personal data to any unrelated third parties, except in the following cases:

  • If You have consented to the disclosure of Your Personal Data to third parties;
  • When We provide services in partnership with partners – Our partners acting as data processors (e.g. data hosting, IT systems support services, marketing agencies that assist us in analyzing how our services are used) or independent data recipients (legal advisers). We will only provide to these service providers as much of Your Personal Data as is necessary to provide a particular service;
  • When Personal Data is provided to the competent state or law enforcement authorities or other entities in accordance with applicable law or in order to comply with any legal or regulatory obligation.

In such circumstances we may share your personal data with these third parties only to perform specific tasks on our behalf, and only once they have agreed to respect the security of your personal data and to treat it in accordance with the law.

We may engage Personal Data processors. The activities and obligations of the data controller shall be governed by an agreement between the controller and the processor, unless the processing is carried out on behalf of the controller in accordance with a legal act binding on the controller or where it is not possible to conclude a separate data processing agreement with the specific service provider (data controller) – in accordance with its publicly available rules (e.g. privacy policies available on the website of a particular service provider). The same rules apply to the processing of data where the processor uses a subsidiary processor.

Personal Data may only be transferred to other persons in accordance with the procedures laid down in the General Data Protection Regulation, other applicable legislation and to the extent specified in the Privacy Policy. Personal data shall be transmitted only to the extent necessary for that purpose. Whenever We transfer Personal Data outside the European Economic Area (EEA) / or store Personal Data in non-EEA countries, We will apply appropriate safeguards to ensure an adequate level of protection of personal data in the EEA (e.g. by signing EU standard contract clauses or other standardized terms legitimising the transfer outside the EEA). The processing of Your Personal Data outside the EEA will be notified to You in accordance with applicable laws.

WHAT DO WE DO TO PROTECT YOUR INFORMATION?

Personal Data is protected against loss, unauthorized use and alteration. We have put in place physical and technical safeguards to protect all information We collect and process in accordance with this Privacy Policy.

HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will only hold your Personal Data for as long as it remains relevant to the services that We provide to You.

Some of the information You provide to Us (e.g. Personal Data in the email or in the communication) will be necessary to carry out repeated tasks or our services, We will keep such information for as long as you remain a client. After this time, we may need to retain Personal Data in order to meet legal and regulatory obligations on record retention or identify or resolve issues or causes of action (depending on the jurisdiction this term varies from 7 to 10 years). In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as it is required.

For enforcement of Our rights Personal data is stored during the dispute and for 10 years after the final court decision takes effect.

For the purpose of improving our services on our Website, Personal Data, if collected through cookies, will be processed for the period specified in the “Cookies” section of the Privacy Policy and then deleted or depersonalized.

At the end of the specified period, the Personal Data will be securely deleted so that they cannot be reproduced.

YOUR RIGHTS

The data subject (You) whose data is processed by the Data Controller has the following rights:

  • Know (be informed) about the processing of Your data (right to know);
  • Access to Your data and how it is processed (right of access);
  • Require the rectification or, depending on the purposes of the processing of Personal Data, the addition of incomplete Personal Data (right of rectification);
  • Delete or suspend the processing of Your data (excluding storage) (right to delete and right to be “forgotten”);
  • The right to require the controller to restrict the processing of Personal Data for one of the legitimate reasons (right to restrict);
  • You have the right to receive the Personal Data You have provided to the data controller in a structured, commonly used and computer-readable format and to transfer that data to another data controller under certain conditions (right of portability);
  • To object to the processing of Personal Data where such processing is being or is intended to be carried out with the consent or legitimate interest (except in exceptional cases), including the right to object to the processing of Personal Data for the purpose of direct marketing;
  • If You believe that We are violating Your rights, You will be able to file a complaint with the State Data Protection Inspectorate in accordance with the procedure established by legal acts.

In order to exercise Your rights as a data subject, You must provide clear and precise request. You can 1) sign it as usual and submit it to our office (upon arrival We will ask You to submit the original signed application and Your identity document for verification of identity) or 2) You can sign the request with qualified e-signature and e-mail it to Us via email (addresses are provided in the privacy Policy section „Contact Us“ below). Only requests submitted in this way are considered, evaluated and implemented. This is how We verify Your identity and We can prevent unauthorized processing of Your Personal Data. We start counting the term provided by legal acts for the implementation of the data subject’s rights from the submission of the request in one of the above-mentioned ways.

Upon receipt of such a request, We will provide a response no later than one month from the date of the request. If necessary, this period may be extended by a further two months, depending on the complexity and number of applications. In that case, We will notify You of such an extension within one month of receiving the request, together with the reasons for the delay.

THIRD PARTY SITES, SERVICES AND PRODUCTS ON OUR WEBSITE

Our Website may contain third-party billboards, links to their sites and services over which We have no control of. We are not responsible for the security or privacy of information collected by third parties. In this case, if You are directed to a third-party website by clicking on a link or panel, We recommend that You read the rules and privacy policies applicable to such website before using it.

SOCIAL NETWORK ACCOUNTS

The Website may contain links to Our social networking accounts. We may offer You to publish graphic and / or other information about You on them. We process this information in accordance with Our legitimate interest to raise awareness about Our goods and services.

The Privacy Policy does not apply to the processing of Personal Data on Our social network accounts for which We have obtained Your consent.

The Personal Data You post on Our social network account is public and accessible to anyone with an Internet connection until We fulfil Your request to remove Your personal data from Our social network account.

When You post Your Personal Data on our social network account, the social network operator (e.g. Twitter International Company, LinkedIn Ireland Unlimited Company, etc.) may have access to them.

For more detailed information about the processing of Your Personal Data published in our accounts on a particular social network, please refer to the privacy policy of the relevant social network.

COOKIES

When You visit our Website, We want to ensure smooth operation of the Website. We use cookies for this purpose.

Once you enter Our Website, as the Website administrator, We install cookies in Your browser (computer, tablet, phone, etc.). Only the cookies (technical and functional) necessary for the operation of the Website, for which We do not require Your consent, will be installed on Your device.

A cookie is a small alphanumeric file that, if You agree, will be stored by Us in Your browser or on Your computer’s hard drive.

Our Website uses the following types of cookies:

  • Technical (mandatory) cookies. Technical cookies are necessary for the proper functioning of our Website. Technical cookies help us display the content of our Website on Your device. Without them, it is not possible to use our Website in full. Technical cookies also ensure that You do not have to do so repeatedly each time You visit our Website.
  • Functional (mandatory) cookies. Functional cookies are designed to improve the functionality of the Website, make the Website convenient and efficient for Your use.
  • Analytical cookies. Analytical cookies used to generate statistical analysis of navigation methods for visitors to our Website; the data collected by these cookies is used without Your identification, i.e. We receive depersonalized statistical information;
  • Marketing and re-advertising cookies. These are cookies that collect information about Your visit to our Website, which is then used to display re-advertising on the Internet (including various social networks (Facebook, etc.), to run e-marketing campaigns, and to measure the success of our marketing efforts. Most of these cookies are third party cookies (read about them below) that We use for marketing / re-advertising purposes.
  • Session cookies – cookies used while a visitor is browsing the Internet and deleted automatically when the browser is closed;
  • Persistent cookies are stored in the visitor’s browser until the cookie expires or is deleted by the visitor.
  • In addition to cookies, We use other similar technologies that perform cookie functions, such as local data storage technology).
  • First-party cookies: these are our own cookies.
  • Third Party Cookies: These cookies are provided by third parties in accordance with our agreement with us.

How to delete cookies?

You control cookies. You can delete them by adjusting Your Web browser settings. In the browser options, You can check which cookies have been saved, delete cookies, and block cookies from being saved in the future. For information on how to change Your browser’s cookie settings, see: Internet Explorer / Firefox / Google Chrome / Safari / Opera

If You do not agree to the storage of cookies on Your device, You can revoke Your consent to use them by changing Your browser settings and deleting the stored cookies. If You choose to delete Your cookies, all Your site options will also be removed. If You block cookies completely, the Website may not work properly.

More information about cookies: www.AllAboutCookies.org and http://www. Youronlinechoices.eu .

For more information about the individual cookies, We use and the purposes for which We use them, see the table below:

NameSourceTypePurposeMoment of creation / Expiry date
wp_apipublic-api.wordpress.comTechnical (mandatory), permanent, third partyTo ensure secure connectionUpon entering Website / until deleted
wp_api_secpublic-api.wordpress.comTechnical (mandatory), permanent, third partyTo ensure secure connectionUpon entering Website / until deleted

DIRECT MARKETING

With Your consent and in cases permitted by law (i.e. when You are already Our customer and when We have a legitimate interest in notifying You of similar goods and services purchased or used by You), We will send You e-mail marketing communication. We may send You newsletters, offer Our products (including provided in cooperation with Our partners), ask Your opinion about Our services.

By entering Your e-mail address in the „Follow“ pop-up window on the Website and clicking “sign me up“, You choose to receive our newsletter and grant Your consent for Us, as the Data Controller, to contact You by e-mail for direct marketing purpose. For this purpose, We process Your e-mail address We received from You.

You can revoke Your consent to receive newsletter at any time without adverse consequences. You can do this by contacting Us (see privacy Policy sections „Your rights“ and „Contact Us“). If You no longer wish to receive notifications from Us, You may unsubscribe at any time by using the unsubscribe link provided in each of the newsletters You receive ori n the settings panel available via the „Follow“ pop-up window on the Website.

You have the right to object to receiving our newsletters, in which case We will not be able to provide You with relevant information.

Upon receipt of a request to revoke Your consent to receive Our newsletter, We will immediately terminate the processing of Your Personal Data on the basis of consent, but the revocation of consent will not affect the lawfulness of consent-based processing of Personal Data prior to the revocation.

For direct marketing purpose We process Your Personal Data in digital form by any means that ensure secure processing. We may use auxiliary data processors (a company that provides a newsletter service, such as wordpress.com) to process Your personal data.

Based on Your consent to receive notifications about Our Services, We will send You notifications for 3 years from the end of the calendar year in which You gave Your consent or until You withdraw this consent in the manner described in this Privacy Policy (whichever comes first). Upon expiry of consent period, we may remind you to prolong the consent.

CONTACT US

If You have any questions about the information contained in this Privacy Policy, contact us:

  • via email:to Clinical Accelerator Data Protection Manager at dp@clinicalaccelerator.com;
  • In person at Our offices:
    • London BioScience Innovation Centre (LBIC), 2 Royal College St, London, NW1 0NH, the UK;
    • Clinical Accelerator, Third Floor, 10-12 Prospect Hill, Douglas, Isle of Man, IM1 1EJ, the UK;
    • Clinical Accelerator, Sepapaja tn 6, Tallinn, 15551, Estonia.

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