Privacy Policy
This Privacy Policy describes how Emvenio Research (collectively, “Emvenio,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. This policy applies when Emvenio Research is acting as a data controller. Where Emvenio Research is acting as a data processor, your information will be governed by the privacy policy of the data controller. You can jump to particular topics by going to the headings below:
Types Of Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information.
| Context | Types of Data | Primary Purpose and Legal Basis for Collection and Use of Data |
| Personal Information | We may collect personal information, such as your name, age, phone number, email address, and location. | We use this information to identify clinical trials that you may be eligible for or interested in. We have a legitimate interest in offering you the opportunity to participate in a clinical trial of interest. |
| Cookies and first-party tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. For more information about our use of cookies, please visit the cookie policy here. | We have a legitimate interest in ensuring our website operates efficiently. |
| Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and interact with our content. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Surveys | When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. | We have a legitimate interest in understanding your opinions, clinical trial preferences, or feedback in order to improve our services to you. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, social media networks, business partners, our affiliates, or publicly available sources.
Use And Processing of Information
In addition to the purposes and uses described above, we use information in the following ways: • To identify you when you visit our websites.
• To provide services and/or facilitate clinical trials.
• To conduct analytics.
• To respond to inquiries related to support, clinical trial opportunities, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, research, or Sponsor promotions.
• For internal administrative purposes, as well as to manage our relationships with sponsors, partners and affiliates.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
Sharing Of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
1. Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
2. Sponsors. We share information with sponsors of clinical trials to enable them to evaluate whether you meet a specific clinical trial’s prerequisites and to communicate with you about participation.
3. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
4. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
5. Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publically available.
6. Service Providers. We may share your information with service providers. Among other things service providers may help us to facilitate your participation in a clinical trial, administer
our website, conduct surveys, communicate with you, provide technical support, process payments, and assist in the fulfillment of orders.
Your Choices
You can make the following choices regarding your personal information where required by law:
1. Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
2. Changes To Your Personal Information. We rely on you to update and correct your personal information. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
3. Deletion Of Your Personal Information. You may request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
4. Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
5. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
6. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted clinical trial offers from our Sponsors and other third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
7. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
8. Promotional Text Messages. If you opt-in to receive autodialed text messages from us that contain promotional information you can opt-out of receiving future text messages by replying “STOP” to the phone number that sent you the text message.
9. Revocation Of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Please address written requests and questions about your rights to withdraw.consent@emvenio.com.
You may submit a copy of the personal information that we hold about you through our online portal, located here.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, address, and what clinical trials you told us you were interested in learning about when you signed up on our website. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:
1. A form or letter that has been completed or signed by the consumer indicating that you have authorization to act on the consumer’s behalf.
2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. If we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Other Important Information
The following additional information relates to our privacy practices:
• Transmission Of Information to Other Countries. We transmit information between and among our affiliates, partners, and clinical trial sponsors. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information, including through the execution of approved standard contractual clauses. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
• Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own or with whom we have a business relationship.
• Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
• Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
• Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “sold,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
• Data Retention. We retain your information for as long as necessary to provide you with information about clinical trials, information that you request, or until you request for your information to be deleted unless we are required by law to retain such information.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
withdraw.consent@emvenio.com
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
*******Separate page to be linked from the Information for California Residents Section********* California Information-Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than you.
| Categories of Personal Information That We Collect | Categories of Third Parties to Whom We Disclose Personal Information for Business Purpose |
| Identifiers – such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers. | • Service Providers • Product and service fulfillment companies • Internet service providers • Social Networks • Payment Processors and financial institutions • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Data analytics providers • Clinical trial sponsors, investigators, and recruiters |
| Protected characteristics – such as race, gender, physical or mental disability, and religion. | • Service Providers • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Clinical trial sponsors, investigators, and recruiters |
| Network activity data– internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. | • Service Providers • Product and service fulfillment companies • Internet service providers • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Data analytics providers |
| Electronic and sensory data – such as audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage). | • Service Providers • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Clinical trial sponsors, recruiters, and investigators |
| Education information – such as information contained in education records. | • Service Providers • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Clinical trial sponsors, recruiters, and investigators |
| Inferences – drawn from any of the information listed above to create a profile | • Service Providers • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law • Data analytics providers • Clinical trial sponsors, recruiters, and investigators |
Authorized Agent Designation Form
Instructions:
If you would like to designate an authorized agent to submit a request on your behalf related to your personal information, a signed and notarized1 copy of this form must be submitted to us. If Emvenio Research is unable to verify the identity of the individual about whom information is being requested (the “Requestor”), we may ask for additional information or documents for verification purposes. For more information, please see our Privacy Policy.
If sending by mail, please use the following address:
Emvenio Research, Inc
2530 Meridian Parkway, Suite 300
Durham, North Carolina, 27713
1. Requestor Information
If sending by email, please use the following address: authorized.agent@emvenio.com