Privacy Policy

This Privacy Policy was last updated on 12/17/2021

At Versiti, Inc. d/b/a Versiti Clinical Trials your privacy is important to us. Our Privacy Policy describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Policy also describes the choices you have with the information we collect, including how you can manage, update, or request to delete information.

Please take a moment to review this Privacy Policy. You may scroll through this Privacy Policy or use the headings below. It is important that you understand this Privacy Policy. By using our Platform, you are agreeing to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, you may Contact Us at any time.

It is helpful to start by explaining some of our key terms and definitions used in this Privacy Policy.

When does our Privacy Policy apply?

This Privacy Policy describes the types of information we may collect from you when:

• You visit or use our Platform, including our Website and/or respond to surveys;
• We communicate in email and other electronic messages between you and us; and
• We communicate in person, such as at trade shows or conferences, on the phone, or through video interaction.

When does our Privacy Policy not apply?

This Privacy Policy does not apply to information collected by any other website operated either by us or by a third party, unless the website is listed above or links to this Privacy Policy. It also does not apply to any website that we may provide a link to or that is accessible from our Platform.

Our Privacy Policy and Terms of Use.

This Privacy Policy is incorporated into our Terms of Use, which also apply when you use our Platform.

What is Personal Information?

Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. For example, your name and email address are personal information. See Categories of Personal Information below for additional details.

What types of Personal Information do we collect?

We may collect and use the following personal information (hereinafter, collectively referred to as “Personal Information”):

How do we collect your Personal information?

We collect most of this Personal Information directly from you. For example, when we speak to you in-person, by phone, and email. Additionally, we will collect information from you when you visit our Website, fill out forms on the Website, use our Services, or purchase our Products.

We may also collect Personal Information in the following ways:

• From your mobile device.
• From a survey. Versiti Clinical Trials conducts surveys. When you participate in a Versiti Clinical Trials survey, we store the information you provide to us and may use it for any business purposes as described in this Privacy Policy or as described in the survey.
• When you contact us. When you contact Versiti Clinical Trials directly, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.

We will also collect information automatically as you navigate through our Platform. We use the following technologies to automatically collect data:

• Cookies. We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Platform or Services through your computer or mobile device. A “cookie” is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Website and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Platform and/or the Services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Platform or the Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
• Facebook Pixel and Instagram. We use Facebook Pixel and Instagram, a web analytics and advertising service provided by Facebook Inc. (“Facebook”) on our Platform. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel and Instagram is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel: https://www.facebook.com/settings/?tab=ads#_=_.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies to help our Platform analyze how users use our Website. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• Google Ads (AdWords). Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
• Other third party tools. We use other third party tools which allow us to track the performance of our Platform. These tools provide us with information about errors, Website performance, and other technical details we may use to improve our Platform and/or the Services.

How do we use your Personal Information?

We may use your Personal Information for the following purposes:

• Operate, maintain, supervise, administer, and enhance our Platform or the Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Services.
• Provide our Products and Services to you, in a custom and user-friendly way.
• Provide you with information, Products, or Services that you request from us.
• Promote and market our Platform and/or the Services to you. For example, we may use your Personal Information, such as your email address, to send you news or to otherwise contact you about Products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these emails at any time as described below.
• To provide you notices about your account.
• Contact you in response to a request.
• To notify you about changes to our Platform and/or the Services or any Products we offer or provide through them.
• Fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Anonymize and aggregate information for analytics and reporting.
• To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
• Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
• To administer surveys and questionnaires.
• Any other purpose with your consent.

How do we share your Personal Information?

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

• Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
• With your consent. We may share your Personal Information if you request or direct us to do so.
• Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• Business transfer. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
• To enforce our rights. We may share your Personal Information to enforce any applicable terms and conditions and Terms of Use, and to ensure the safety and security of our Services and our users.
• De-identified information. We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
• To market our products and services. We may share your Personal Information with affiliates to market our products and services.
• To market affiliates’ products and services. We may share your Personal Information with affiliates to market their products or services to you if you have not opted out of these disclosures. For more information on opting out, see Your Choices about how we share your Personal Information.
• Third party analytics. We use Google Analytics and other data analytics tools to understand and evaluate how visitors interact with our Platform and/or the Services. These tools help us improve our Platform and/or the Services, performance, and your experience. For more information related to these third party analytics providers please review How do we collect your Personal Information?.

Your choices about how we share your Personal Information.

This section of our Privacy Policy provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

If you do not wish to have your email address used by Versiti Clinical Trials to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Versiti Clinical Trials as a result of a Product purchase, or your use of our Platform and/or the Services. You may have other options with respect to marketing and communication preferences through our Platform.

You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests.

How do I access and correct my Personal Information?

You may Contact Us to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your Personal Information except by also deleting your account with us. 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.

This Privacy Policy applies to all uses of our Services globally and you should not use the Platform and/or the Services if you do not agree to the Privacy Policy and Terms of Use. This Privacy Policy applies to European Economic Area (EEA) data subjects. By using or downloading the Platform, you acknowledge and agree that your Personal Information, including any information about you that you provide directly to us or that we collect through your use of the Platform and/or the Services, may be transferred to and stored in the United States.

Our Services are not intended for children under 18 years of age. We do not knowingly collect or sell Personal Information from children under the age of 18. If you are under the age of 18, do not use or provide any information on or to the Platform or through any of its features. If we learn we have collected or received Personal Information from a child under the age of 18 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided use with their Personal Information, you may Contact Us to request the Personal Information be deleted.

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.

We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.

The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Platform, in your operating system, or mobile device.

If you are a California resident, certain Personal Information that we collect about you is subject to the California Consumer Privacy Act (CCPA). Please note that the CCPA does not apply to, among other things information collected, used, or disclosed in research, including clinical trials, or consumer information that is de-identified or aggregated.

Collection of Personal Information.

Currently and in the last 12 months, we have collected and/or disclosed Personal Information about you when you visit our Platform and/or obtain the Services, including information about you that you provide to us, and information we automatically collect from you or your computer or devices as you use our Platform and/or the Services. Please refer to the section titled Personal Information for additional information and details.

Categories of Sources from which we have collected Personal Information.

We collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Platform, when you create a Versiti Clinical Trials account; and indirectly from you automatically through your computer or device as you use our Platform and/or the Services. We may also collect Personal Information about you from our advertising partners and service providers.

Use of Personal Information collected from California Residents.

We do not sell your Personal Information and have not done so in the prior 12 months from the effective date of this Policy. We may use or disclose the personal information we collect for our business purposes described elsewhere in this Privacy Policy (for example, please refer to “How do we use your Personal Information?” and “How do we share your Personal Information?”).

Sharing the Personal Information of California Residents.

Versiti Clinical Trials may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for Business Purposes.

We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us, and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. Please refer to “What types of Personal Information do we collect?” and “How do we collect your Personal Information?” for additional information and details.

Access Request Rights.

California residents have the right to request that Versiti Clinical Trials disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Contact Us. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: 
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights.

California residents have the right to request that Versiti Clinical Trials delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.

Exercising Access and Deletion Rights.

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either calling us at (414) 937-6418 or sending us an e-mail at privacyofficer@versiti.org.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. We will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts and other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or different level or quality of goods or services.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform and/or the Services 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 in 2022 will receive information regarding such activities in 2021). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

Versiti Clinical Trials is the data controller of the Personal Information you provide on the Platform and/or through the Services. Versiti Clinical Trials has appointed a Data Protection Officer and representative in the EEA in compliance with the General Data Protection Regulation. Versiti Clinical Trials and its Data Protection Officer and representative may be contacted in any manner set forth below in Contact Us.

Consent to Processing of Personal Information.

We rely on your consent as a lawful basis to process your Personal Information for the following purposes:

• Initial collection of Personal Information through the Platform and/or the Services; and
• Providing you with marketing communications. You may opt-out of such communications at any time by clicking the “unsubscribe” link found within the Versiti Clinical Trials email updates and changing your contact preferences.

We also process Personal Information based on our contractual obligations to provide you the Platform and/or the Services as described in How do we share your Personal Information?, including:

• To enable the Platform to function as expected; and
• To communicate with you in response to customer services inquiries, to deliver non-marketing, service-related emails, or to administer surveys.

Versiti Clinical Trials may also process Personal Information pursuant to a legal obligation or to protect your vital interests or those of another person.

We will process your Personal Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Information if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Versiti Clinical Trials and you; detect and correct bugs and to improve our Platform and/or the Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; develop our Products and Services;

What rights do I have?

Individuals located in the EEA have certain rights with respect to their Personal Information. These rights include:

• Access and Update. You can review and change your Personal Information by notifying us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. We may 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 Information 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 Information is determined to be unlawful, or if we no longer need your Personal Information for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Information you provide Versiti Clinical Trials is processed based on your consent or 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 Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Information to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Information 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 Information.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Information. We cannot delete your Personal Information 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 Information or after a final determination that your Personal Information 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 Information as set forth in this policy. In addition, we cannot completely delete your Personal Information as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
• 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 Us below. 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.

Automated Decision Making.

Our processing of Personal Information does not include automated decision making such as profiling.

Changes to our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Website’s homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s 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 Website and reviewing this Privacy Policy to check for any changes.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below.

How to Contact Us:

Versiti Clinical Trials
Telephone: (414) 937-6418
Email: privacyofficer@versiti.org

For EEA users:

Versiti Clinical Trials Data Protection Officer 

Versiti, Inc. General Counsel/Chief Privacy Officer
Telephone: (414) 937-6418
Email: privacyofficer@versiti.org

Versiti Clinical Trials EEA Representative 

Data Protection Representative Limited (trading as DataRep) 

Address: The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland 

Email: datarequest@datarep.com (include in the subject line)