Last Updated: January 1, 2020

PRIVACY POLICY

Acurian, Inc.’s (“Acurian,” “we,” “our, “us”) mission is to increase awareness about, and facilitate participation in, clinical trials related to the development of investigational drugs and therapies. Individuals entrust us with information of a personal and confidential nature, so we have adopted this Privacy Policy (“Policy”) to inform you about our practices in collecting, using and protecting information we collect through our websites, including www.acurian.comwww.acuriantrials.com, www.acurianhealth.com, and licensed applications (each a “Site,” or collectively, the “Sites”); through our offline interactions; and from third-party sources. It also describes the choices you can make with respect to that information.

This Policy applies to information that Acurian collects when:

  • you use any of our Sites or correspond with us by email;
  • you speak with one of our representatives on the phone;
  • you provide information to us in writing; or
  • we receive information about you from third-party sources.

If you are a resident of the State of California, this Policy also incorporates our Privacy Notice for California Residents, which includes additional information required to be provided under California law.

The Personal Information We Collect and How We Collect and Use It

Depending on how you interact with us, we may collect various types of information from and about you.  This information may include personal information that you provide to us directly, such as through online forms or when you correspond with us by email; information that we automatically collect about you and your device when you use the Sites; and information that we collect about you from other sources such as our data partners and public records.  Below we describe in more detail the information we collect and how we collect it.

  • Contact Information.  We collect your name and contact information, such as your email address and telephone number, when you submit inquiries to us (such as through a “Contact Us” form made available through the Sites), or request to receive resources such as whitepapers and newsletters.  We use this information to respond to your inquiries and to provide the resources you request.
  • Community Registration Information.  When you register to join our community through the Sites, we collect certain personal information that you provide through online forms.  This information includes your first and last name, date of birth, gender, email address, mailing address, phone number, and health conditions that interest you.  We use this information to determine whether you may be eligible for enrollment in a clinical trial, and to contact you regarding particular studies in which we think you might be interested.
  • Clinical Trial Qualification and Enrollment Information. When we believe you may be interested in a particular clinical trial, we may contact you to request that you provide additional information via a questionnaire, including information about your health and medical history, to determine if you satisfy the criteria for that clinical trial. If you are interested in having your minor child participate in a clinical trial, you can also provide your minor child’s date of birth and medical information to verify if your child satisfies the criteria for that particular trial.
  • Inferences. To enhance our ability to provide you with our services, we may compare your Personal Information with aggregated data about groups of people in similar circumstances to make inferences about you. For example, we may infer that there is a 50% chance that you are divorced from the fact that your zip code has a 50% divorce rate.  We use these inferences to help determine whether you might be interested in a clinical trial.
  • Tell-a-friend.  We may allow users to tell their friends about clinical trials using our referral program.  When you use our referral program, we ask you to provide your friend’s name and email address, which we will use to automatically send a one-time email inviting him or her to visit our Sites.
  • Information We Receive from Our Data Partners. Acurian partners with several companies that gather information from consumers, which may include self-reported health information. If you have provided personal information to one of these data partners (including information on your health, purchasing habits, or lifestyle) and indicated an interest in clinical research studies or health information, we may receive your Personal Information from the data partner.
  • Information We Collect from Public Records.  In some circumstances, we may collect information about you from public sources, such as public telephone directories, and link that information to information we collect from you, or that we receive from our data partners.  We use this information to determine whether you may be eligible for enrollment in a clinical trial, and to contact you regarding particular studies in which we think you might be interested.
  • Information We Collect from Third-Party Social Media Platforms.  In some circumstances, we may collect information that you have made available on third-party social media platforms, such as Facebook, Twitter, and LinkedIn, when we interact with you on those platforms.  We use this information to determine whether you may be eligible for enrollment in a clinical trial, and to contact you regarding particular studies in which we think you might be interested.
  • Lifestyle-based Analytics. In some circumstances, we may contact you by mail regarding potential clinical studies where information you voluntarily provided to our data partners or publicly available information suggests, based on our analysis of various demographic and societal trends, that you might benefit from such studies.
  • Professional Contact Information.  If you are a trial sponsor and work with us, or are interested in working with us, we will collect professional contact information that you provide to us, including your first and last name, company, email address, mailing address, and telephone number.  We use this information to administer our relationship with your organization, and to communicate with you about our services, including by sending you updates and information in which we think you may be interested.
  • Career and Employee Recruitment Information.   If you apply for a job with us, we will collect certain personal information from you, including your private contact details, professional qualifications and previous employment history.  We use this information for our recruiting and job candidate evaluation purposes, and to inform our employment decisions
  • Technical Information We Collect Automatically through the Sites.  We automatically collect certain technical information about your device and your use of the Sites.  This information may include network routing information, information about your device and browser, your IP address (which may identify your general geographic location or company), and the date and time of your visit.  We also automatically receive and record information about your interactions with the Sites.  For more information, please see the “Cookies/Tracking Technologies” section below.

In addition to the uses described above, we may also retain and use the personal information we collect about you:

  • as necessary to comply with our legal obligations;
  • as necessary to protect our rights and/or comply with a judicial proceeding, court order or similar legal process;
  • to resolve disputes and to enforce our agreements; and
  • for other purposes with your prior opt-in consent.

How We Share your Personal Information

We may share your Personal Information with the following categories of third parties to accomplish the purposes set out above and for the additional purposes set forth below.

  • Our Affiliated Companies. We may share your personal information with our affiliated companies, who will handle your information in accordance with this Policy.
  • Our Service Providers. We will share your personal information with our vendors, consultants, and other service providers (e.g., call centers, email service providers, and other technology providers) who we engage to perform services on our behalf, and who are not allowed to use personal information they receive from us for any other purpose.
  • Clinical Trial Sites. If we believe you may be qualified to participate in a clinical trial, we will, with your consent, share some of your personal information with the clinical trial site to facilitate your enrollment in the clinical trial.
  • Data Partners. In some cases, your personal information, including your identity and contact details, may be shared with our data partners to update and/or confirm their contact lists.
  • To Protect Our Legal Rights or Comply with Legal Requirements. We may disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Sale or Transfer of Corporate Assets. In the event of a merger, sale, joint venture or other transaction involving a transfer of our business or assets, we may transfer your information to other parties involved in the transaction. Any entity acquiring Acurian’s data assets will do so with the express, written commitment to use the data only for authorized purposes, and to maintain a similar level of privacy and information security protection. You will be notified via email or notice on our website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
  • With Your Consent. We may disclose your personal information to other third parties with your prior opt-in consent.

Cookies / Tracking Technologies

As is true of most web sites and applications, we gather certain information the use of our Sites automatically and store it in log files.  This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We may combine this automatically-collected log information with other information we collect about you. We use this information to analyze the use of our Sites and to improve Site functionality.

We also use cookies.  A cookie is a data file that is placed by a website operator on the hard drive of a visitor’s computer to their site.   First-party cookies (those placed by Acurian) and third-party cookies (those placed by other parties with whom we work) may be placed on your computer when you visit our Sites for the following purposes: to improve the user experience, including by allowing the Sites to remember you and your preferences as you browse through different pages; to allow us to perform site analytics; and to assess whether visitors to the site later become referrals to clinical trials.  One of the ways that we do this is through the use of Google Analytics using data layers listed here.  For more information about how Google Analytics uses and processes data, please visit https://www.google.com/policies/privacy/partners/.

Acurian and third parties with whom we work may also place cookies and use web beacons on our Sites to collect information about your browsing activity, and use that information to deliver content relevant to your interests, including our advertisements, on our Sites and elsewhere on the internet.  We may also use those technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

At this time, we do not respond to browser “do not track” signals, however most browsers will allow a visitor to choose which cookies can be placed on his or her computer, and to delete or disable cookies.  If you choose to disable cookies, you may still use our website, but your ability to use some features or areas of our Sites may be limited.

Social Media Widgets

Our Sites may include social media features, such as the Facebook “Like” button and widgets, such as the “share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets may be hosted by a third party or hosted directly on our sites and applications. Your interactions with these features are governed by the privacy policy of the company providing it.

Your Choices Regarding Your Personal Information

  • When you register to join the Acurian community, or complete a prequalification questionnaire associated with a particular trial, you indicate your consent for Acurian and its affiliates to contact you about clinical trials for which you may be eligible by various means, including telephone, email, and postal mail.  If you do not want to be contacted, you may decline to register or complete the questionnaire, which will limit your ability to participate in clinical trials for which we provide recruitment services.
  • We may sometimes obtain your consent to particular uses or disclosure of your personal information, which we refer to as “opting in.” If you have opted in to a particular use or disclosure, you may revoke your consent (i.e., “opt out”) with respect to further uses or disclosures at any time by contacting us at information@acurian.com. Please note however that the withdrawal of your consent will not affect any uses or disclosures that occurred before the withdrawal.
  • You may opt-out from receiving our communications, including promotional emails and newsletters, by clicking on the “unsubscribe” link located at the bottom of each communication you receive. To completely opt out of receiving communications from us, please send an email entitled “Unsubscribe” to information@acurian.com.
  • You may request that we provide you with information about whether we hold, or process on behalf of a third party, any of your personal information.  To request this information, please contact us at information@acurian.com.
  • You may request to correct your Personal Information or your child’s information, modify your contact preferences, or delete yours or your child’s information at any time by contacting us at information@acurian.com.

Information Security

We maintain information security safeguards that are reasonably designed to protect your Personal Information from unauthorized access, use, and alteration.  Please note however that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

Data Protection Laws 

In jurisdictions with data protection laws, we will ensure that individuals can exercise all relevant informational rights regarding their Personal Information we process, including the rights of access and correction, to prevent direct marketing, block processing, and erase data.

Links to Third Party Sites

Our website includes links to other websites and applications (including but not limited to social networks such as Facebook and Twitter) whose privacy practices may differ from those of Acurian. If you submit personal information to any of those websites and applications, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Inquiries, Complaints, and Requests to Exercise Rights

All communications, queries, requests to informational rights (e.g. access to data) or complaints concerning individuals who reside in the European Union can be addressed:

  • to the attention of Executive Director of Global Privacy, Granta Park, Cambridge, CB21 6GQ. United Kingdom, or
  • emailed to dpo@acurian.com

The Executive Director Of Global Privacy is designated Data Protection Officer for Acurian under the General Data Protection Regulation (GDPR).

All other communications, queries, requests to exercise informational rights (e.g. access to data) or complaints should be addressed:

  • by email to information@acurian.com
  • by fax to (215) 323-9001, Attn: Privacy Officer
  • by regular mail at Acurian, Inc., Attn: Privacy Officer, 2 Walnut Grove Drive, Suite 375, Horsham, PA, 19044.

EU-U.S. and Swiss-U.S. Privacy

Acurian (and its subsidiary, Panoply Health Limited) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Acurian has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: https://www.privacyshield.gov/.

Acurian is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Acurian complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Acurian is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Acurian may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Acurian has put in place measures to ensure that adequate protection is provided to the data where legally mandated.

In compliance with the Privacy Shield Principles, Acurian commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Acurian:

  • by email at information@acurian.com; or
  • by fax to (215) 323-9001, Attn: Privacy Officer; or
  • by regular mail at Acurian, Inc., Attn: Privacy Officer, 2 Walnut Grove Drive, Suite 375, Horsham, PA, 19044.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Children Under 13

Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any personal information to us through the Sites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through our Sites. If we learn we have collected or received personal information from a child under 13 through the Sites we will delete that information.

Changes to the Policy

We regularly review our Policy to ensure that it provides an appropriate level of protection for your Personal Information. From time to time, we may make changes to our Policy to keep it current with industry standards and as required by law. We will post the date of the most recent revisions on this page. Please check back here from time to time to make sure that you are current and up-to-date on our Policy. Please keep in mind that your use of our Web site means that you accept this Policy. For more information, please read our Terms of Use. If we make a material change to this Policy, we will notify you here, by email, or by means of a notice on our home page prior to the changes taking effect.

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