PRIVACY NOTICE

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Last updated August 18, 2022

This privacy notice for Santa Monica Clinical Trials (“SM Clinical Trials”, “we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at research@smclinicaltrials.com

 

1. What information do we collect?

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Personal information provided by you

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names

  • Phone numbers

  • Email addresses

  • Mailing addresses

  • Contact preferences

Sensitive information

When necessary, with your consent as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • Health data

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user.

  • To respond to user inquiries/offer support to users.

  • To send you marketing and promotional communications.

  • To determine user eligibility for studies.

 

3. When and with whom do we share your personal information?

We will not share your personal information.

 

4. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy below.

 

5. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have a subscription with us.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

7. What are your privacy rights?

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “11. How can you contact us about this notice?” below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “11. How can you contact us about this notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

 

8. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

9. Do California residents have specific privacy rights?

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems.

 

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) Every individual who is in the State of California for other than a temporary or transitory purpose and

(2) Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents”

If this definition of “resident” applies to you, we must adhere to certain rights and obligation regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;

  • Participating in customer surveys; and

  • Facilitation in the delivery of our Service and to respond to your inquiries.

Will your information be shared with anyone else?

We may disclose your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. Santa Monica Clinical Trials has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Santa Monica Clinical Trials will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstance, you have the right to know:

  • Whether we collect and use your personal information;

  • The categories of personal information that we collect;

  • The purposes for which the collected personal information is used;

  • Whether we sell your personal information that we sold or disclosed for a business purpose;

  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

  • The business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • You may be object to the processing of your personal information.

  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

  • You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us with the information given in section "11. How can you contact us about this notice?" below. 

10. Do we make updates to this notice?

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. I f we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

11. How can you contact us about this notice?

If you have any questions or comments about this notice, you may email us at research@smclinicaltrials.com or by post to:

 

Santa Monica Clinical Trials

12301 Wilshire Blvd STE 200

Los Angeles, CA 90025

United States

 

12. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please click the link below: 

COOKIE POLICY

Last updated August 18, 2022

This Cookie Policy explains how Santa Monica Clinical Trials (“Company”, “we”, “us”, and “our”) uses cookies and similar technologies to recognize you when you visit our websites at https://www.santamonicaclinicaltrials.com/ , (“Websites”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

 

In some cases, we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Santa Monica Clinical Trials) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website. The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

 

Why do we use cookies?

We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable use to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.

 

The specific types of first- and third-party cookies served through our Websites and the purposes they perform are described below (please not the specific cookies served my vary depending on the specific Online Properties you visit).

 

How can I control cookies?

You have the right to decide whether you accept or reject cookies. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

You may set or amend your web browser controls to accept or refuse cookies. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

Essential website cookies:

These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.

 

Performance and functionality cookies:

These cookies are used to enhance the performance and functionality of our Websites but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.

 

Analytics and customization cookies:

These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.

 

Unclassified cookies:

These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

 

 

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

 

Do you use Flash cookies or Local Shared Objects?

Websites may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs”) to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the website storage settings panel. You can also control Flash Cookies by going to the global storage settings panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

 

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications including, potentially, Flash applications used in connection with our services or online content.

 

How often will you update your Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or the other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicated when it was last updated.

 

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please reach us at the contact information listed in the Privacy Notice above under the section “11. How can you contact us about this notice?”.

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