Privacy Policy
Last Updated: 27.06.2024
Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the various laws, including the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as “controller” of that personal information for the purposes of those laws.
Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Curify, Inc. and our affiliates; |
Site Personal information | AllClinicalTrials.com and associated applications Any information relating to an identified or identifiable individual |
Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
Personal Information We Collect About You
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
If you use our Site on behalf of someone else, you must ensure that you have that person’s express consent and authorization to provide us with their personal information.
Our Site is not intended for use by anyone under the age of 16. We do not knowingly collect Personal Information from anyone under the age of 16. If we learn that we have collected Personal Information from someone under the age of 16, by notice given to us or otherwise, we will remove that data from our systems.
Personally Identifiable Information (PII)
We obtain, use, and safeguard your PII information in compliance with applicable laws, We collect information from you to identify and match you with potential clinical trials in your area and to notify relevant clinical trial providers that you have matched in a clinical trial.
The PII we collect is used exclusively for the purpose of matching you with suitable clinical trials. Specifically, we use this information to assess your eligibility for specific clinical trials, communicate with you regarding potential participation in clinical trials, and share relevant information with clinical trial sponsors and investigators, strictly as necessary for the recruitment process.
By using the site and giving us PII through questionnaires, surveys and other forms, you consent to our use of such PII.
The third parties to whom we may disclose PII include, but are not limited to, clinical trial administrators and researchers, regulatory authorities (as required for compliance with applicable laws and regulations), and health care providers involved in the clinical trials.
How Your Personal Information is Collected
We collect most of this personal information directly from you through your use of our Site and applications. However, we may also collect information:
Why We Use Your Personal Information
Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
To prevent and detect fraud against you or Curify, Inc. | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Conducting checks to identify our customers and verify their identity; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator | To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration, and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
De-Identified and Aggregate Information.
We may use or disclose de-identified information (see above: “Why We Use Your Personal Information”). De-identified information is derived from the personally identifiable information you give to us. Before this information is used or disclosed, we remove certain identifiable information or alter that information so you can no longer be identified based on that information. In order to match you with clinical trials, we provide your profile to clinical trial providers such as pharmaceutical companies, contract research organizations (CROs), and research universities. Where we provide such information, it is in a de-identified format. Our third-party providers use this information to confirm your suitability to participate in clinical trials.
We may also share aggregate information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties for research and/or development purposes. This information is not personal information because it does not identify any particular individual or disclose any particular individual’s data. For example, aggregate information may include a statement that "8% of all AllClinicalTrials.com subscribers have diabetes," without providing any data or testing results specific to any individual user. We will always ask for your consent to share any individual-level information with any third party, other than our service providers as necessary for us to provide the Services to you.
Referrals.
When you provide PII to us, we may manually transfer that data to clinical trial sponsors through the sponsors website or application. We may receive referral fees from some sponsored clinical trials when we successfully match you with a clinical trial based on the information you provide to us. You acknowledge and agree that Curify may manually transfer the data to third party clinical trial sponsors and receive referral fees from such sponsors that you are matched with through your use of our Site.
Where Your Personal Information is Held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal information with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring your personal information out of the EEA”.
How Long Your Personal Information Will Be Kept
We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary. Different retention periods apply for different types of personal information.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.,:
These transfers are subject to special rules under European and UK data protection law.
If you would like further information please contact us (see ‘How to contact us' below).
Your Rights Under the GDPR
Access | The right to be provided with a copy of your personal information (the right of access). |
Rectification | The right to require us to correct any mistakes in your personal information. |
To be forgotten | The right to require us to delete your personal information—in certain situations. |
Restriction of processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data. |
Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
To object | The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests. |
Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
What right you want to exercise and the information to which your request relates.
Your Rights Under the CCPA.
Disclosure of Personal Information We Collect About You | You have the right to know:
Please note that we are not required to:
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Personal Information Sold or Used for a Business Purpose | In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://www.allclinicaltrials.com/?cky_preview=true |
Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is necessary to:
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Protection Against Discrimination | You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. |
Use of cookies and similar technologies.
Cookies are small text files placed on your computer or other device by websites that you visit. Cookies are widely used in order to make websites and other applications work, or work more efficiently, and help them remember certain information and recognize your internet browser. Cookies may last until you close your browser (“session” cookies) or over repeat visits (“persistent” cookies).
We use cookies and similar technologies to:
If you access any of our services subject to a subscription agreement or other contract between us and your organization, cookies and similar technologies will be used as necessary for the performance of that contract and for our legitimate business operations related to providing the service.
We use the following types of cookies:
Details about the cookies set by our Site(s) and by third parties, including service providers acting on our behalf, are listed directly on the site or in the cookie control tool made available on the site.
How to manage cookies and interest-based advertising.
You can manage the use of certain types of cookies, including targeting cookies used for personalized advertising, also known as interest-based advertising (IBA), by amending your cookies settings in the cookie control tool made available on the site. You also may be able to block or delete cookies by selecting the appropriate settings on your browser privacy preferences menu.
You can also opt out of IBA by turning off targeting cookies used for IBA via the consumer choice tools created under self-regulation programs in many countries, such as the US-based YourAdChoices, the Canada-based AdChoices or the EU-based Your Online Choices. We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Interest-Based Advertising.
Certain content and features in our services depend on cookies to function. For example, authentication cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. If you choose to block cookies, you cannot sign in or use certain content or features. If you choose to delete cookies, any settings and preferences dependent on those cookies will be lost.
Use of web beacons and other technologies.
Some of our Site(s), applications and electronic communications contain electronic tags known as web beacons, gifs or pixel tags, unique identifiers and similar technologies that help deliver cookies, measure online activity, provide more relevant advertising, or analyze the effectiveness of our promotional campaigns or other operations.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to Complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice
We may change this privacy notice from time to time–when we do we will inform you by updating the “Last Updated” date at the top of this Privacy Policy.
How to Contact Us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Our contact details | |
548 Market St #39969, San Francisco, California 94104 | |
info@curify.us | |
+1 (415) 941-0077 |
Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).