3 December, 2020
- Children Under 13
- Information Covered by this Policy
- Information Collected and How We Use It
- Information Sharing and Transfer
- When and How Panoply May Contact You
- Cookies / Tracking Technologies
- Social Media Features
- Correcting Your Personal Information and “Opting Out”
- Information Security
- Data Protection Laws
- Sale or Transfer of Corporate Assets
- Inquiries, Complaints, and Requests to Exercise Rights
- Changes to the Policy
Children Under 13
Our websites and applications are not intended for children under 13 years of age. No one under age 13 may provide any personal information to us through our websites or applications. We do not knowingly collect personal information directly from children under 13. If you are under 13, do not use or provide any information on our websites or applications. If we learn we have collected or received personal information directly from a child under 13, 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 Panoply when:
- using any of our websites or 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 websites and 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 particular 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 websites or applications (e.g., name, date of birth, email address, address, phone number, and demographic information).
- Further Information. At various locations on our websites or applications, 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 particular trial, we request medical information via a questionnaire. If you meet the prequalification criteria for the trial, and grant Panoply explicit permission to do so, your information will be forwarded to an investigator in your area for further evaluation; the investigator 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 particular trial.
- Study Data: If you meet the prequalification criteria for a clinical trial and decide to participate in the clinical trial or screening process for the clinical trial, we may receive basic information regarding your visits with the study doctor and staff (e.g., appointment dates).
- 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.
- Newsletters. We and our partners (e.g., medical centers, healthcare companies, medical websites) 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. Panoply 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, and where law allows, 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, and where law allows, we may contact you by mail regarding potential clinical studies where information you voluntarily provided to our Data Partners or publicly available information suggests on the basis of 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 will 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 in order to provide these services.
- Opt Out Requests. If you send us an email or use our website 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 anonymised 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 webinars, brochures, case studies, and other resources.
In many situations, including where mandated by data privacy law, and also where it is a matter of good practice, Panoply will seek your consent to collect, use and disclose your data consistent with the relevant privacy notice. However, in certain cases where law allows, particularly where gaining consent will involve a disproportionate effort, where intended processing of the data is in Panoply’s or our clients’ legitimate interests and the privacy risks are low, Panoply will proceed to process personal information absent of consent.
Your information may be collected and processed to assess your eligibility for a current or future clinical trial. Failure to provide any requested data or consent to data processing may prevent us from assessing your eligibility for a current or future clinical trial. Unless you indicate otherwise, the consent you provide shall be considered valid indefinitely.
In these circumstances, we will retain your information for as long as your account is active or as needed to provide you services. You have the right to withdraw your consent to the processing of your information at any time by sending an email to email@example.com. Your withdrawal of consent does not affect the lawfulness of the processing before the withdrawal.
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 served on our websites, resolve disputes, and enforce our agreements.
Information Sharing and Transfer
Personal information will be shared within Panoply and its affiliated companies and with third parties, including our agents and service providers, on a “need to know” basis to meet stated legitimate business purposes. Access to databases and folders containing personal information is restricted to appropriate staff. Panoply does not trade or sell personal information.
Under some circumstances, Panoply may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes. Panoply may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of Panoply or some or all of its assets.
Companies working as vendors of Panoply are required to sign “processor” and/or confidentiality agreements whereby they will commit to only process personal information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
We may provide your information with vendors or service providers (e.g., call centers, email service providers), who are contractually bound to handle your information confidentially and prohibited from disclosing your information to others.
When and How Panoply May Contact You
When you register with Panoply, or complete a prequalification questionnaire associated with a particular trial, you indicate your consent for Panoply 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 mail. You also have the option of receiving emails regarding new postings to our site, including news or new clinical trials. In addition, Panoply may contact you periodically when we have provided new functionality to our websites and 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.” Should you provide a mobile telephone number as a means of contact, your provision of that telephone number, and acceptance of the consent presented as a function of submitting it, constitutes your permission that Panoply may contact you at that number.
Cookies / Tracking Technologies
We Panoply and our affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyse trends, administer the website or application, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Panoply will gain necessary consent from those visitors for the placement of such technologies upon first visiting our European websites.
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 Panoply) are enabled to the computers of those visiting our websites for the following purposes: to improve the user experience by allowing the site or application 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. Our websites or applications also place cookies for the purpose of serving Panoply-sponsored advertisements at third-party websites, and for the purpose of performing various cost analyses relating to the site. One of the ways that we do this is through the use of Google Analytics using data layers listed here.
If you do not consent to the placement of cookies and other tracking technologies, 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 or 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.
Social Media Features
Our websites and applications include social media features, such as links to external websites, including Facebook and Twitter, which may collect your personal information if you choose to access these websites. The privacy practices of these websites are governed by their respective privacy policies.
Correcting Your and Your Child’s Personal Information and “Opting Out”
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 emailing us at firstname.lastname@example.org. We will respond to your request to access within 30 days.
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 send an email entitled “Unsubscribe” to email@example.com.
We maintain information security safeguards to protect your Personal Information. We protect your Personal Information using encryption, and utilise firewalls to protect our computer network from hackers. We take reasonable steps designed to prevent unauthorised access, use and alteration of Personal Information, but cannot guarantee the security of such information.
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. Your data may be securely transferred to affiliated companies, some of which are located outside of the European Union. Panoply has put in place measures to ensure that adequate protection is provided to such data transfers. For example, Panoply has executed Standard Data Protection Clauses (“SDPC”) for the purpose of transferring certain personal information from the European Economic Area. EU residents whose personal information is handled under these SDPC may request a copy of the agreement from Panoply through the contact details listed below.
Links to Third Party Sites
Our websites and applications includes links to other websites (including but not limited to Facebook and Twitter) whose privacy practices may differ from those of Panoply. If you submit personal information to any of those websites, 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
Acurian, Panoply’s parent company, expressly reserves the right to transfer its database of information to another legal entity as part of any sale or merger of Acurian, Inc. with that entity. Any entity acquiring Acurian’s data assets will do so with the express, written commitment to use the data only for authorised 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.
Inquiries, Complaints, and Requests to Exercise Rights
Under the Regulation, you have the right to request access to and correction of your Personal Information. You have the additional right to object to the processing of your information, request deletion of your data, and restrict aspects of the processing of your data or request transmission of your data in a common digital format to yourself or another controller.
You also have the right to complain about how your information is handled to a supervisory authority that is responsible for regulating compliance with the Regulation. A list of all EU supervisory authorities is available on the European Commission website: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
All communications, queries, requests to exercise informational rights (e.g. access to data) or complaints, can be addressed:
- to the attention of Vice President of Global Privacy, EU Data Protection Officer
- emailed to firstname.lastname@example.org
The Vice President of Global Privacy, EU Data Protection Officer is the designated Data Protection Officer for Panoply under the Regulation.
Changes to the Policy