This privacy policy describes how Progressive Medical Research (“PMR”) collects and uses the personal information you provide on our website. It also describes your choices regarding use, access and correction of your personal information. PMR’s primary mission is to increase awareness about, and facilitate participation, in clinical trials related to 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 such information. The Policy explains in general terms how we seek to comply with data privacy laws and regulations, including but not limited to national laws.
Children Under 18
Our websites and applications are not intended for use by children under 18 year of age. No one under age 18 may provide any personal information to us through our websites and applications. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our websites and applications. If we learn we have collected or received personal information from a child under 18 we will delete that information.
Information Covered by this Policy
This Policy applies to any personally identifiable information about you (“Personal Information”) that you may provide to PMR when:
· using any of our websites and applications or sending us information by email;
· speaking with one of our representatives on the phone; or
· providing information in writing.
Information Collected and How We Use It
At various locations on our site or other applications, and during our business practice, we ask you for information, which will allow us to provide you (whether you are a patient or physician) with information that is targeted specifically to you. If you would like to be considered for enrollment in a clinical trial, this information allows us to contact you regarding studies for which you may be eligible. We collect information in the following ways:
· Initial User Registration. We collect information you provide to us when you register at one of our sites (e.g., name, date of birth, email address, address, phone number, and demographic information).
· Further Information. At various locations on our site, we may ask you for additional information so that we can provide you with additional services (e.g., notification about your appointments or new clinical trials).
· Enrollment Forms. Many of our users are interested in enrolling in clinical trials. To learn whether you satisfy the criteria for a trial, we request medical information via a questionnaire. If you meet the prequalification criteria for the trial, and grant PMRre explicit permission to do so, your information will be forwarded to an investigator, site staff, or clinical trial recruitment professional in your area for further evaluation; the recipient will be under strict constraints by laws governing the disclosure of Personal Information. You can also input your child’s date of birth and medical information to verify if your child satisfies the criteria for a trial.
· Data Aggregation. To enhance our ability to provide you with our services, we may combine your Personal Information with aggregated data about groups of people in similar circumstances. 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.
· Tell-a-friend. We allow users to tell their friends about our site using our referral service. If you provide your friend’s name and email address, we may automatically send a one-time email inviting him or her to visit our site. Your friend may contact us to request that we remove this information from our database.
· We and our partners (e.g., medical centers, healthcare companies, medical websites and applications, etc.) may occasionally offer newsletters or other publications focused on specific medical conditions that you might want to receive. If you ask to receive a newsletter, we will use your contact information to deliver the material you request.
· Data Partners. PMR partners with several companies that gather opted-in information from consumers, which include self-reported health information. If you have provided Personal Information to one of our Data Partners (including information on your health, purchasing habits, or lifestyle) indicated an interest in clinical research studies or health information, and opted in to receive information of interest from third parties, we may receive your Personal Information from the Data Partner.
· Public Records. In some circumstances, we may link the information you have provided to our Data Partners with publicly available data about you, such as public directory phone numbers.
· 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 analysis of various demographic and societal trends that you might benefit from such studies.
· Messaging Services. If you enroll in a clinical trial and expressly consent to receiving study information and messages, we may provide you with appointment reminders, study instructions, and other important study instructions. In addition, we may exchange relevant health information with the study doctor and staff to provide these services.
· Opt-Out Requests. If you send us an email or use our websites or applications to opt out of receiving information or being contacted, we will retain and use some of your information to avoid further contact with you. We may also retain your information to the extent it has previously been incorporated in anonymized data and as necessary for us to meet legal requirements and defend claims against us.
· Resource Documents Registration. If you register to use our resource documents, we request your name, company email address, company name, and telephone number. We use this information to create an account for you to allow you access to our patient recruitment white papers, recorded webinPMR, brochures, case studies, and other resources.
We will retain your information for as long as your account is active or as needed to provide you services. You may remove your information from our contact list by contacting us. Please note that we may retain and use your information as necessary to comply with our legal obligations, when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or similar legal process, resolve disputes, and enforce our agreements.
Information Sharing and Transfer
We will share your Personal Information with third parties only in the ways that are described in this privacy statement or unless you expressly opt in to such sharing.
Service Providers/Partners
We may provide your information with our affiliates, third-party service providers (e.g., call centers, email service providers), or data partners who are contractually bound to handle your information confidentially and prohibited from disclosing your information to others.
Legal Notice
We may also 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.
When and How PMR and Affiliates of PMR May Contact You
When you register with PMR or complete a prequalification questionnaire associated with a particular trial, you indicate your consent for PMR and its affiliates to store your Personal Information in our database and contact you about clinical trials for which you may be eligible by various means, including telephone, email, and US mail. You also have the option of receiving emails regarding new postings to our site, including news or new clinical trials. In addition, we may contact you periodically when we have provided new functionality to our websites or applications, so that you may take advantage of the new services. If you receive a text message from us and would like to discontinue such messages, you may reply with the word “STOP.” Providing a telephone number constitutes your consent for PMR to contact you at that number for the purposes outlined in this Policy.
Cookies / Tracking Technologies
PMR and our affiliates use cookies or similar technologies to analyze trends, administer the websites or applications, tracking users’ movements around the website, and to gather demographic information about our user base. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
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 (owned and controlled by PMR) are enabled to the computers of those visiting our websites and applications for the following purposes: to improve the user experience by allowing the site to remember a visitor as they browse through different pages; to allow us to perform site analytics; to assess whether visitors to the site later become referrals to clinical trials. One of the ways that we do this is by using Google Analytics.
First-party cookies are enabled and controlled by our web team, which is established on U.S. territory. Our websites and applications also place cookies for serving PMR-, and PMR affiliates-sponsored advertisements at third-party websites and applications, and for the purpose of performing various cost analyses relating to the site.
You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.
As is true of most web sites and applications, we gather certain information 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 do this to improve services we offer you and to improve analytics and site functionality.
PMR may allow its affiliates and third parties to place cookies on our sites and applications for advertising purposes. These parties may use cookies or similar technologies to gather information about your activities on this site and other sites and applications to provide you advertising based upon your browsing activities and interests. This Privacy Policy does not cover the collection methods or use of the information collected by these parties, which have their own privacy policies and may be members of the Network Advertising Initiative (“NAI”). To be removed from some or all NAI member advertising programs, please visit the NAI Opt-Out Page and follow the relevant instructions. Or if you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Social Media Widgets
Our websites and applications 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 are either 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.
Correcting Your and Your Child’s Personal Information and “Opting Out”
Upon request PMR will 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.
You may correct your Personal Information or your child’s information, modify your contact preferences, or completely opt out of our services at any time. You can update your or your child’s information, correct inaccuracies, or delete some or all of your or your child’s data by contacting us.
We sometimes refer to your consent to be contacted, to be included in a clinical trial, or to other use of your Personal Information as “opting in.” You may revoke your consent (i.e., “opt out”) at any time.
The first time you provide us with information, you will have the ability to instruct us regarding other communications (e.g., requesting newsletters, etc.). You may opt-out from receiving our newsletters by clicking on the “unsubscribe” link located at the bottom of each newsletter. To completely opt out of our services, please contact us.
Information Security
We maintain information security safeguards to protect your Personal Information. We protect any Personal Information you provide using encryption and utilize firewalls to protect our computer network from hackers. We take reasonable steps designed to prevent unauthorized access, use and alteration of Personal Information, but cannot guarantee the security of such information.
We require you to select a username and password. To minimize the chance that someone can guess your password, we require passwords with a minimum length of 8 characters, including numbers and upper and lower-case letters. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
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. PMR has executed Standard Contractual Clauses for transferring personal information from the European Economic Area.
Links to Third Party Sites
Our website includes links to other websites and applications (including but not limited to Facebook, Twitter) whose privacy practices may differ from those of PMR. 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.
Sale or Transfer of Corporate Assets
PMR expressly reserves the right to transfer its database of information to another legal entity as part of any sale or merger of PMR, Inc. with that entity. Any entity acquiring PMR’s data assets will do so with the express, written commitment to use the data only for authorized purposes, and only if the entity maintains 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.
EU-U.S. and Swiss-U.S. Privacy
PMR participates in 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. PMR 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/.
PMR 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. PMR 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, PMR is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, PMR may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. PMR has put in place measures to ensure that adequate protection is provided to the data where legally mandated.
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.
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 our Privacy and Security Policy. For more information on this point, please read our Terms of Service of site 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.