Privacy Policy – AutoCruitment

Datum účinnosti: 6. listopadu 2020

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Effective Date: 1st March, 2021

1. Introduction

This Privacy Policy describes how AutoCruitment collects and uses Personal Data about you through the use of our Websites, and through email, text, and other electronic communications between you and AutoCruitment.

AutoCruitment LLC (“AutoCruitment” or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. We adopt this Privacy Policy to comply with the EU General Data Protection Regulation (“GDPR”) and other privacy laws that may be applicable to AutoCruitment or our customers.

This Privacy Policy (our “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 or https://autocruitment.com (each, a “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

on our Websites; and
in email, text, and other electronic messages between you and our Website

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by AutoCruitment or any third-party;
us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
any third party, including through any application or content (including advertising) that may link to or be accessible from the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using these Websites, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of these Websites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Data Controller, Data Protection Officer, and Representative

AutoCruitment is the data controller of the Personal Data you provide on the Websites. AutoCruitment has appointed a Data Protection Officer and a representative in connection with the General Data Protection Regulation.

AutoCruitment is the data controller of your Personal Data. AutoCruitment has appointed a Data Protection Officer and a representative in the European Union in compliance 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 Under the Age of 13; Children Over the Age of 13 but Under the Age of 16

Our Websites are not intended for children under the age of 13, and children under the age of 13 are not permitted to use our Websites. We will remove any information we learn about of a child under the age of 13. Further, if you are over the age of 13 but under the age of 16, your legal parent or guardian must provide the information on your behalf (you must not provide such information yourself).

Parents or legal guardians may provide us with information about their minor children under 13 (or 16, if located in California or the European Economic Area). However, to comply with applicable law, our Websites are not intended for children under 13 years of age (or 16, if located in California or the European Economic Area) to directly enter information about themselves. No one under age 13 (or 16, if located in California or the European Economic Area) may directly provide any personal information to the Websites. If you are under the age of 13 (or 16 and located in California or the European Economic Area), 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 Data directly from children under 13 (or directly from those under 16, if located in California or the European Economic Area). If you are under 13 (or 16 and located in California or the European Economic Area), do not use or directly provide any information on our Websites 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 user name you may use. If we learn we have collected or received Personal Data directly from a child under 13 (or directly from a child under 16 and located in California or the European Economic Area), 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 California or the European Economic Area), please contact us at info@autocruitment.com or using the information set forth in the “Contact Information” Section below.

4. Information We Collect About You and How We Collect It

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 combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Websites (“Personal Data”):

by which you may be personally identified, such as name, postal address, e-mail address, telephone number, date of birth, medical history, any other identifier by which you may be contacted online or offline;
that is about you but individually does not identify you, such as traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites; and/or
about your internet connection, the equipment you use to access our Websites and usage details.

We collect this information:

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

Information You Provide to Us

The information we collect on or through our Websites are:

information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, filling out forms on our Websites, 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. We may also ask you for additional information when you enter a promotion sponsored by us, and when you report a problem with our Websites;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys that we might ask you to complete for research purposes; and
your search queries on the Websites

The Personal Data we collect from you is required to enter into a contract with AutoCruitment, for AutoCruitment to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

details of your visits to our Websites. We collect traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites; and
Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Websites according to your individual interests;
speed up your searches; and
recognize you when you return to our Websites.

The forms of technologies we use for this automatic data collection may 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 Websites. 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 Websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. 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 Information.
Web Beacons. Pages of our Website 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 Websites. Our website includes links to other websites whose privacy practices may differ from those of AutoCruitment. If you submit personal information to any of those websites, your 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 Website 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 website. 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.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

5. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

Consent. By using our Websites, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Websites;
Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between AutoCruitment and you; facilitate communication between you and a third party, for our third-party clinical research partners’ direct marketing purposes, to detect and correct bugs and to improve our Websites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; and promote and market our business; check your credit and perform risk assessments;
To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you; and
As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. Special Categories of Information

We may process some Personal Data considered sensitive with your explicit consent or when necessary to carry out our obligations under the law or to protect our legitimate interests.

Some Personal Data processed by AutoCruitment may be considered sensitive, including personal data that reveals your racial or ethnic origin, or personal data concerning your health. AutoCruitment processes this information only with your explicit consent, or to the extent necessary to carry out its obligations under the law or to the extent necessary to protect AutoCruitment’s legitimate interests.

7. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

provide our Websites to you;
provide you with information you request from us;
enforce our rights arising from contracts; and
notify you about changes

We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Websites and their contents to you;
to provide you with information, products, or services that you request from us;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Websites or any products or services we offer or provide though them;
in any other way we may describe when you provide the information;
to fulfill any other purpose for which you provide it; and
for any other purpose with your consent.

8. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

our subsidiaries and our affiliates;
our third-party service providers, contractors, and other third parties we use to support our business;
our clinical 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;
a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and
with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services;
our clinical research partners if you have opted in to be contacted about our programs and services, including for our patient referrals program involving referrals for clinical trials and related procedures;
to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AutoCruitment’s’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by AutoCruitment about our Websites’ users is among the assets transferred;
to third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information
to fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Websites, we will transmit the contents of that email and your email address to the recipients;
for any other purpose disclosed by us when you provide the information; and
with your consent

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our terms of use and other agreements; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AutoCruitment, our customers, or others

9. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, and our advertising to you.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

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 Websites may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. We will only share your Personal Data 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 contact information to promote our own or third parties’ products and services with your express consent. If you do not wish to have your 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.

California residents may have additional personal information rights and choices. Please see the Your California Privacy Rights Section for more information.

10. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

Access and Update. You can review and change your Personal Data by contacting us using the Contact Information below. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide AutoCruitment is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
Post-Mortem Rights. You have the right at any time to provide us directions regarding the storage, erasure, and sharing of your Personal Data after your death.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below and through the live chat feature of our Websites. 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 Data, you may be charged a fee subject to a maximum set by applicable law.

11. State-Specific Privacy Rights

The law in certain states may provide their residents with additional rights regarding our use of your Personal Information

The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Policy.

Your California Privacy Rights
If you are a resident of California, you have the additional rights described in the California Privacy Notice.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g., requests made this year will receive information regarding such activities for last year). You may request this information once per calendar year. To make such a request, please contact us using the Contact Information Section below.

12. Do Not Track Signals

We do not track you over time and across other third-party websites or services. We currently do not honor do-not-track signals that may be sent by some browsers.

We do not track you over time and across third-party websites or other online services for any purpose. 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.

13. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.

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

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password 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 Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Websites.

14. Consent to Processing of Personal Data in Other Countries Outside the European Economic Area

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

If you are a resident of the European Economic Area (“EEA“), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by AutoCruitment to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Websites, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Websites. To ensure your Personal Data (other than Personal Data you provide directly to us on our Websites) is treated in accordance with this Privacy Policy, AutoCruitment uses Data Protection Agreements between AutoCruitment and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third country. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

15. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and
and to comply with other legal requirements.

AutoCruitment will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:

for as long as necessary to comply with any legal requirement;
on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

16. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

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. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account or through a notice on the Websites’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.

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 Websites.

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

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

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

COMPLIANCEhead

Measurement
Management will verify compliance
Exceptions
Any exception to the policy
Non-Compliance
An employee found to have violated this

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