Effective Date: October 6th 2023

1. Introduction

AutoCruitment LLC (“AutoCruitment“, we“, ”us“, or our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (our “Privacy Policy”). This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the websites https://trials.autocruitment.com/ (collectively, the “Site(s)”), or otherwise interact with us, and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy applies to information we collect on a Site, or in email, text, and other electronic messages between you and a Site, or by phone or offline method, and additional categories of information, as further detailed below. This Privacy Policy also describes your choices regarding use, access and correction of your personal information.

Our Sites allow you to provide us with information through a screening form (“Form”) which enables us to recruit, screen, and refer participants for clinical trials and specialty procedures (the “Programs”) to hospitals, private practices, cancer centers, pharmaceutical companies, CROs, and biotech or pharmaceutical companies, (collectively, “Research Partners”). If, by filling out a Form, you are matched to a particular Program, Research Partners may contact you. We are not responsible for any direct communications that you may have with any Research Partners or any personal information that such Research Partners may collect from you directly.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Sites and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Please check this Privacy Policy periodically for updates.

2. Controller, Data Protection Officer, and Representative

AutoCruitment is the controller of the personal information you provide via the Sites. AutoCruitment has appointed a Data Protection Officer and a representative in connection with the General Data Protection Regulation. AutoCruitment, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

3. Children’s Data

Parents or legal guardians may provide us with information about their minor children under 13 (or 16, if located in the European Economic Area (“EEA”)). However, our Sites are not intended for children under 13 years of age (or 16, if located in the EEA) to directly enter information about themselves. No one under age 13 (or 16, if located in the EEA) may directly provide any personal information via the Sites. If you are under the age of 13 (or 16 and located in the EEA), your legal parent or guardian must enter information on your behalf, and you must not directly provide any information yourself. We do not knowingly collect personal information directly from children under 13 (or directly from those under 16, if located in the EEA). If you are under 13 (or 16 and located in the EEA), do not use or directly provide any information on our Sites or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information directly from a child under 13 (or directly from a child under 16 and located in the EEA), we will delete that information. If you believe we might have any information directly from a child under 13 (or collected directly from a child under 16 and located in the EEA), please contact us at info@autocruitment.com or using the information set forth in the “Contact Information” Section below.

4. Sources of Personal Information and Server Location.

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we process in aggregated form. This includes information that we collect directly from you or through automated collection technologies, as set out below.

Information we Process

We collect several types of personal information including:

  • Personal details: given name(s); preferred name; and photograph
  • Contact details: correspondence address; telephone number; email address; messenger app details; online messaging details; and social media details.
  • Site data: traffic data, location data, logs, internet connection type, device type, IP address, operating system, browser type, and details of how you use our Sites; and
  • Registration data: We collect or obtain personal information when you use, or register to use, any of our Sites, or services.
  • Content interactions: If you interact with any content on a (including third party plugins and cookies) we receive personal information regarding that interaction.
  • Data provided to us: We obtain personal information when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
  • Data we obtain in person: We obtain personal information during meetings, during visits from sales or marketing representatives, or at events we attend.
  • Relationship data: We collect or obtain personal information in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
  • Data you make public: We collect or obtain personal information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
  • Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
  • Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
  • Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive personal information from the relevant third party provider of that content or advertising.
  • Third party information: We collect or obtain personal information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
  • Health data: information regarding health conditions, treatments and medications, and clinical trials, information provided at the time of registering to use our Sites, filling out Forms on our Sites, inputting information into or through our screeners, in connection with our referral service, or otherwise in connection with our platform, posting material, or requesting further services;
  • Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
  • Views and opinions: any views and opinions that you choose to send to us, your responses to surveys that we might ask you to complete for research purposes, search queries on the Sites, and when you report a problem with our Sites; and
  • Correspondence: records and copies of your correspondence (including email addresses) if you contact us.

We collect this information:

  • directly from you when you provide it to us; and
  • automatically as you navigate through the Sites. Information collected automatically includes Site usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies

The technologies we use for this automatic collection of personal information include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Sites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
  • Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How we Use and Disclose Your Personal Information.
  • Web Beacons. Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit AutoCruitment, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

The technologies we use for this automatic data collection may include:

  • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies” to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as https://policies.google.com/privacy.
  • Google Adwords and Facebook Ads. Our Sites utilize remarketing services through Google Adwords and Facebook Ads to help us better serve our audience and advertise our services across the Internet. Based on information that we automatically collect and information that you provide to us, we may display targeted banner ads tailored to you based on your previous interactions with our Sites. Google and Facebook may also display targeted ads tailor made for you on outside sites based on your previous interactions with our sites. We may also send you an email encouraging you to complete a previously abandoned donation form, or to return to a previously visited website offering events or content, both audio and digital. You may opt out of Google Remarketing Ads and Facebook Ads on their websites;
  • Blog/Forum. Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@autocruitment.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
  • Links to Third Party Sites. Our Sites include links to other websites whose privacy practices may differ from those of AutoCruitment. If you submit personal information to any of those websites, your personal information is governed by their privacy statement. We encourage you to carefully read the privacy policy of any website you visit.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How we Use and Disclose Your Personal Information.

Information we Create

We also create personal information about you in certain circumstances, such as records of your interactions with us. We may also combine personal information from any of our Sites or services, including where those data are collected from different devices or sources.

Server Location

AutoCruitment utilizes servers located in the United States.

Legal Bases for Processing Your Personal Information

The purposes for which we process the categories of personal information identified in Section 4. above, subject to applicable law, and the legal bases on which we perform such processing, are as follows:

Purpose Legal basis Categories of personal information
Provision of our Sites and services: providing our Sites, or services; providing promotional items upon request; and communicating with you in relation to those Sites, or services; enrolling you in Programs; communication with Research Partners. For non-health data:

  • We may process personal information where the processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the processing for the purpose of providing our Sites, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

For health data:

  • We only process health data where we have obtained your prior explicit consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way). However, please note that if you withhold or withdraw your consent to the processing of this personal information then we may be unable to provide the relevant services.
  • Personal details
  • Contact details
  • Demographic information
  • Consent records
  • Health data
  • Site Data
  • Content interactions
  • Views and opinions
Operating our business: operating and managing our Sites, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, or our services; and notifying you of changes to any of our Sites, or our services.
  • The processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the processing for the purpose of operating our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
  • Personal details
  • Contact details
  • Consent records
  • Site Data
  • Content interactions
Planning: organisational planning; succession planning; making changes to the nature and scope of our operations or our business; mergers, acquisitions, dissolutions demergers, liquidations, asset sales, divestitures, reorganisations and similar corporate structuring arrangements.
  • We have a legitimate interest in carrying out the processing for the purpose of planning the future operation of our operations or our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Personal details
  • Contact details
  • Demographic information
  • Site Data
  • Content interactions
  • Views and opinions
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.
  • We have a legitimate interest in carrying out the processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way). However, please note that if you withhold or withdraw your consent to the processing of this personal information then we may be unable to provide the requested services.
  • Personal details
  • Contact details
  • Demographic information
  • Consent records
  • Site Data
  • Content interactions
  • Views and opinions
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
  • The processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Personal details
  • Contact details
  • Demographic information
  • Consent records
  • Site Data
  • Content interactions
  • Views and opinions
Surveys: engaging with you for the purposes of obtaining your views on our Sites, or our services.
  • We have a legitimate interest in carrying out the processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
  • Personal details
  • Consent records
  • Views and opinions
Security: maintaining the electronic security of our Sites (including login records and access details).
  • The processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Personal details
  • Contact details
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • The processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Personal details
  • Contact details
  • Site Data
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
  • The processing is necessary for compliance with a legal obligation.
  • Personal details
  • Contact details
  • Site Data
Improving our Sites, and services: identifying issues with our Sites, or our services; planning improvements to our Sites, or our services; and creating new Sites, or services.
  • We have a legitimate interest in carrying out the processing for the purpose of improving our Sites, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
  • Personal details
  • Contact details
  • Demographic information
  • Consent records
  • Site Data
  • Content interactions
  • Views and opinions
Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.
  • The processing is necessary for compliance with a legal obligation;
  • We have a legitimate interest in carrying out the processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The processing is necessary for the establishment, exercise or defence of legal claims.
  • Personal details
  • Contact details
  • Demographic information
  • Consent records
  • Site Data
  • Content interactions
  • Views and opinions
Protecting health and safety or rights of others: To protect the health, safety, or welfare of you or others or the personal rights of you or others.
  • The processing is necessary for compliance with a legal obligation; or
  • The processing is necessary to protect the vital interests of the data subject or of another natural person or carried out in the public interest
  • Personal details
  • Contact details
  • Demographic information
  • Health data

6. Disclosure of Your Personal Information

We do not share, sell, or otherwise disclose your personal information for purposes other than those outlined in this Privacy Policy. We disclose your personal information to the following third parties:

  • you and, where appropriate, your appointed representatives;
  • our subsidiaries and our affiliates;
  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • accountants, auditors, consultants, lawyers and other outside professional advisors to AutoCruitment, subject to binding contractual obligations of confidentiality;
  • our third-party service providers, contractors, and other third parties we use to support our business, subject to compliance with the requirements of applicable law regarding such disclosures;
  • Research Partners, if you have opted in to be contacted about our programs and services, including for patient referrals for clinical trials and related procedures;
  • any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal claims;
  • any third party, to the extent strictly necessary to comply with our legal obligations; and
  • any other third party, with your prior consent.

We may disclose aggregated anonymized information, from which no individuals can be identified, without restriction.

7. Choices About How we Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with control over your personal information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Sites may then be inaccessible or not function properly.You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may also opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.
  • Disclosure of Your Personal Information for Third-Party Advertising. We will only share your personal information with unaffiliated or non-agent third parties for promotional purposes with your express consent. If you wish to change your choice, you may do so at any time by contacting us using the information set forth in the “Contact Information” Section below.
  • Promotional Offers from AutoCruitment. We will only use your email contact information to promote our own or third parties’ products and services with your express consent. If you do not wish to have your email contact information used by AutoCruitment to promote our or our third parties’ product and services, you may update your email preferences by using the “unsubscribe” link found in emails we send to you or contacting us using the information set forth in the “Contact Information” Section below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

US State residents may have additional personal information rights and choices. Please see the Privacy Addendum for more information.

8. Profiling

We Process personal information for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:

Profiling activity Logic of the Profiling activity Consequences for you
Screening and determining your eligibility for inclusion in a Program. We use automated technology to screen your personal information against a set of criteria provided by the relevant Research Partners in relation to a Program. Based on the personal information you provide to us, our technology may determine your eligibility for inclusion in a Program.

9. Your Rights Regarding Your Personal Information and Accessing and Correcting Your Personal Information

Subject to applicable data protection laws, you may have the following rights regarding your personal information:

  • the right not to provide your personal information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, or services, if you do not provide us with your personal information – e.g., we might not be able to process your requests without the necessary details);
  • the right to request access to, or copies of, your relevant personal information, together with information regarding the nature, processing and disclosure of those relevant personal information;
  • the right to request rectification of any inaccuracies in your relevant personal information;
  • the right to request, on legitimate grounds:
    • erasure of your relevant personal information; or
    • restriction of processing of your relevant personal information;
  • the right to have certain relevant personal information transferred to another controller, in a structured, commonly used and machine-readable format, to the extent applicable;
  • where we process your relevant personal information on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal bases);
  • the right to lodge complaints regarding the processing of your relevant personal information with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EEA, the Data Protection Authority for EEA Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)); and
  • the right at any time to provide us directions regarding the storage, erasure, and sharing of your personal information after your death.

Subject to applicable law, you may also have the following additional rights regarding the processing of your relevant personal information:

  • the right to object, on grounds relating to your particular situation, to the processing of your relevant personal information by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR; and
  • the right to object to the processing of your relevant personal information by us or on our behalf for direct marketing purposes.

How to Exercise Your Rights. You may exercise any of the above rights, where applicable, by contacting us through any of the methods listed under Contact Information below and through the live chat feature of our Sites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your personal information, you may be charged a fee subject to a maximum set by applicable law. Please also note that where your request requires the establishment of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

10. State-Specific Privacy Rights

In addition, the law in certain states may provide their residents with additional rights regarding our use of your personal information. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the section of the Privacy Addendum for your state that is attached to this Privacy Policy, a link to which is provided below.

11. Do Not Track Signals

We do not track you over time and across other third-party websites or services or allow third parties to track you overtime and across our Sites to promote the third parties’ products or services. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

12. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) credentials to enable access to certain parts of our Sites, you are responsible for keeping those credentials confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk.

13. Transfers of Personal Information out of the EEA or the UK

AutoCruitment utilizes servers located in the United States. As such, if you are located in a country outside of the United States, when you provide your personal information to AutoCruitment, you will automatically transfer your personal information to the United States.

In limited circumstances, AutoCruitment may transfer your personal information out of the EEA or the UK, to recipients located in third countries. Such transfers are conducted in accordance with Chapter V of the GDPR / UK GDPR. Where appropriate, AutoCruitment uses contractual arrangements that include, where applicable, the Standard Contractual Clauses adopted by the European Commission, and the relevant UK Addendum (collectively, the “Standard Contractual Clauses”). You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

14. Data Retention Periods

We take every reasonable step to ensure that your personal information are only processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your personal information are as follows:

  1. we will retain personal information in a form that permits identification only for as long as:
    1. we maintain an ongoing relationship with you (e.g., where you are a participant in a Program); or
    2. your personal information are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis (e.g., where your personal information are included in a clinical trial or other Program, and we have a legitimate interest in processing those personal information for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your personal information),

    plus:

  2. the duration of:
    1. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us, or a regulatory investigation into our business or any Program, in connection with your personal information or to which your personal information are relevant); and
    2. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any personal information that are relevant to that claim),

    and:

  3. in addition, if any relevant legal claims are brought, we continue to process personal information for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our processing of your personal information to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

15. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. The date this Privacy Policy was last revised is identified at the top of the page.

16. Defined terms

In this Privacy Policy, the following meanings are assigned to the terms listed in bold below:

  • controller” means the entity that decides how and why personal information are processed.
  • EEA” means the European Economic Area.
  • GDPR” means the General Data Protection Regulation (EU) 2016/679.
  • personal information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  • process”, “processing” or “processed” means anything that is done with any personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Profiling” means any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
  • relevant personal information” means personal information in respect of which we are the controller.
  • UK GDPR” means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time.

17. Contact Information

You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact both us and our representative through the contact information below or through the “Contact Us” page on our Sites.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your personal information pursuant to applicable laws, or otherwise need to contact us, you must contact both us and our representative in the EEA at the contact information below or through the “Contact us” page on our Sites.

To Contact AutoCruitment (Controller)

AutoCruitment

101 6th Ave 8th Floor
New York, NY 10013
United States
(646) 876-9400

info@autocruitment.com

To Contact Our Representative for
GDPR / UK GDPR purposes

DPR Group

Find local address

datainquiry@dpr.eu.com

https://www.dpr.eu.com/datarequest

To Contact Our Data Protection Officer

Ioana Georgescu

(646) 568-2218 (office)

(519) 781-3270 (mobile)

ioanageorgescu@autocruitment.com

AutoCruitment’s patient recruitment platform supports Sponsors, CRO Partners and Research Sites by decreasing time, risk and cost to bring new therapies to market.

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