Web-based and Mobile Application Platform Privacy Policy

Last Updated: May 25th, 2021

Introduction

Science 37, Inc. (“Science 37,” “we,” or “us”) is committed to protecting your information. To that end, we want you to be familiar with how we process your information on Science 37’s Web-based and/or Mobile Application Platform (“Platform”), which we provide to facilitate participation in clinical trials. This Science 37 Platform Privacy Policy (“Privacy Policy”) outlines how Science 37 collects, uses, and discloses information that you provide during your interactions with the Platform. This is separate from the data handling practices outlined by the sponsor in the Informed Consent Form. 

Sponsors make important decisions on what Personal Information is collected and how your Personal Information is used and disclosed as part of a clinical trial. For more information about how your Personal Information is handled in the clinical trial, your data protection rights, and whom to contact with any questions about the clinical trial, please refer to the confidentiality section of the relevant Informed Consent Form.
As used in this Privacy Policy, “Personal Information” means any information that can be used to identify or is reasonably linkable, directly or indirectly, to a specific natural person.
 

Information We Collect About You

We collect the following Personal Information when requested by the sponsor to create Platform user accounts:

  • Your name and email address
  • Your language preference and time zone

How We Collect Your Personal Information

We will collect information from you when you complete forms on the Platform. We may also collect information when you correspond with us (for example, by email) and when you report a problem with the Platform. 
We need to collect Personal Information to provide the requested Platform services to you. If you do not provide the information requested, we may not be able to provide the Platform services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Platform, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
 

How We Use and Disclose Personal Information

Use
We use the Personal Information that we collect for the legal, contractual, and business purposes associated with your participation in the clinical trial. This includes, for example, the collection of Personal Information for service-related purposes (such as optimizing your user experience and maintaining the security of the Platform), supporting compliance (your location can determine what laws or regulations apply to you), and providing language preference customizations.
We and our service providers use Personal Information for the following purposes:

  • Providing the Platform functionality and fulfilling your requests.
  • To provide the Platform’s functionality to you, such as arranging access to your registered account, and providing you with related customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise; for example when you send us questions, suggestions, compliments, or complaints.
  • To send administrative information to you, such as changes to our terms, conditions, policies, and changes to the Platform.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
 

  • Accomplishing our business purposes.
  • To administer and protect the security of the Platform, including troubleshooting, data analysis, and system testing.
  • For data analysis; for example, to assess trends about Platform use, to improve the efficiency of the Platform.
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
  • For fraud prevention and fraud security monitoring purposes; for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • For developing new products and services.
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
 

  • Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. For example, we may aggregate overall usage data to identify trends about how Platform users access a specific Platform feature to inform future improvements.

 
Disclosure
Personal Information may be disclosed to our third-party service providers, to facilitate the services they provide to us. These can include providers of services such as website hosting, data analysis, fraud prevention, information technology, and related infrastructure provision, customer service, email delivery, auditing, and other services.

Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, and without your specific consent, in particular when we have a legal obligation or legitimate interest to do so, including:

  • To comply with a court order, law, regulation, or legal process, including to respond to a government or regulatory request, which could include laws outside of your country of residence.
  • To cooperate with public and government authorities, including to respond to a request or to provide the information we believe is necessary or appropriate (these can include authorities outside of your country of residence).
  • To cooperate with law enforcement, including, for example, when we respond to law enforcement requests and orders or provide the information we believe is important.
  • For other legal reasons, including to enforce our terms and conditions or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
  • In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Platform collects Other Information such as:

  • Browser and device information
  • App usage data
  • Information collected through pixel tags and other technologies
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information.
 

Transfer and Storage of Personal Information

Science 37 is headquartered in Los Angeles, California, in the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Platform you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.

Additional Information Regarding the EEA, Switzerland, and UK
Some non-EEA countries are recognized by the European Commission, Switzerland, and the UK as providing an adequate level of data protection according to their standards (the full list of countries with adequate protection is available here). For transfers from the EEA, Switzerland, and the UK to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “How to Contact Us” section below.

If you have any privacy-related questions about the transfer or storage of your Personal Information please contact us at Privacy@Science37.com.
 

Data Security

Science 37 is committed to protecting the Personal Information you share with us. We seek to utilize a combination of reasonable security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
 

Data Retention

We retain your personal information for the length of time needed or permitted in light of the purpose(s) for which it was obtained, as outlined in this Privacy Policy, and/or in accordance with applicable law. The criteria used to determine our retention periods include: 

  • The length of time we have an ongoing relationship with you and provide the Platform to you (for example, for the length of the study in which you are participating);
  • Whether there is a legal obligation to which we are subject; or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).  

Your Rights

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt-out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us using the contact information at the end of this Privacy Policy. We will respond to your request consistent with applicable law. 

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. 

If you withdraw or are withdrawn from a clinical trial, we will not collect or receive any new information from the Platform. However, information already collected, processed, and stored up to the time that your withdrawal request is received and processed may not be deleted, and may continue to be used for the clinical trial’s purpose, including compliance with regulatory requirements, unless applicable law requires otherwise.
 

Changes to the Privacy Policy

We may make changes to the Platform and, as a consequence, we will need to revise this Privacy Policy to reflect those changes. We will post all such changes to this Privacy Policy on our website, so you should review this page periodically. Any changes will become effective when we post the revised Privacy Policy on our website.
 

How to Contact Us

Science 37, Inc.
Jen Davis, Deputy General Counsel and Privacy Officer
Privacy@Science37.com
600 Corporate Pointe #320
Culver City, CA 90230
 

Additional Information Regarding the EEA and UK

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