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.

• 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.

• 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.

• 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.

• 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.

• California
• Virginia

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.

• “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.