This Privacy Notice was last updated on January 1, 2020.
This Privacy Notice applies to Personal Information that United BioSource LLC (“UBC”, “we”, “us” or “our”) obtains from individuals (“you” or “your”) through our website (the “Site”) or otherwise, including, but not limited to, the delivery of our products, and services (collectively, the “Services”). Please read this Privacy Notice carefully before you access the Site, use the Services, or otherwise provide Personal Information to us, whether online or offline.
We are firmly committed to protecting the confidentiality of your Personal Information. When referred to in this Privacy Notice, the term “Personal Information” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws. Personal Information may include “protected health information” (“PHI”) as defined under the Health Insurance Portability and Accountability Act of 1996, as amended and implemented (“HIPAA”), “Personal Data” as defined under the European Union (“EU”) General Data Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018, and “Personal Information” as defined under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et. seq., as amended (“CCPA”).
Examples of Personal Information include but are not limited to: first and last name, postal address, email address or other online contact information (such as an online user ID), telephone number, date of birth, Social Security number (or its equivalent), driver’s license number or other government-issued identification number, financial account information, access code, password, security questions and answers, medical information, Internet Protocol (IP) address, or any other unique identifier.
The Site is not intended to collect or use PHI. Please do not submit any PHI through the Site.
United BioSource LLC operates the Site and is the data controller in respect of your Personal Information for purposes of European data protection law. In accordance with these laws, we have appointed UBC Late Stage (UK) Limited (26-28 Hammersmith Grove, London, W6 7HA (UK)) as our representative in Europe.
What does this Privacy Notice cover?
This Privacy Notice describes how we collect and use your Personal Information through your online and offline interactions with us, including any Personal Information we use to send you direct marketing (for example, to contact you about future clinical studies using Personal Information submitted via our Investigator Registration Page). It also describes your data protection rights and how to exercise them.
Categories of Personal Information We Collect
Currently, we may collect the following types of Personal Information about you:
How We Collect and Use Your Personal Information
How We Use Your Personal Information and the Legal Grounds for Such Use
We may use the Personal Information that we collect in furtherance of our legitimate interests in providing you with the Services, to fulfill the terms of a contract you have with us, with your consent, or to comply with our legal obligations. In some cases, failure to provide such Personal Information will mean that UBC cannot provide you with the Services.
Wherever we rely on consent, you will be able to withdraw that consent, although we may have other legal grounds for processing your Personal Information for other purposes, such as compliance with applicable laws. You have the right to opt out of our direct marketing at any time. You can do this by (i) following the instructions in the communication where this is an electronic message, or (ii) contacting us using the methods noted below at “Exercising Your Rights.”
Cookies and Other Tracking Technologies
Cookies are small pieces of information sent by a web server to a web browser, which allow the server to uniquely identify the browser on each page.
We use the following categories of cookies:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or submitted information cannot be provided.
Category 2: Performance Cookies
These cookies collect anonymous information on how people use our Site. For example, we use Google Analytics cookies to help us understand how individuals arrive at our Site, browse or use our Site, and highlight areas where we can improve such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Category 3: Functionality Cookies
These cookies remember choices you make such as the country from which you visit our Site, language and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other sites.
Category 4: Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an ad as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the sites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Criteo to provide you with more personalized ads when visiting other sites.
Category 5: Social Media Cookies
These cookies allow you to share what you’ve been doing on the Site on social media, such as Facebook and Twitter. These cookies are not within our control, and are therefore subject to a third party’s rules and policies. Social media companies may have their own privacy policies, which we strongly suggest you review if you use those websites or apps.
We may use different kinds of cookies including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve the Site, Site content, and the Services we offer. These cookies are deleted when you close your browser session. Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks.
We suggest consulting the Help section of your browser, or taking a look at https://www.aboutcookies.org/, which offers guidance for all modern browsers.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Disclosure of Your Personal Information
We will share your Personal Information with other UBC group companies (such as UBC Late Stage (UK) Limited – for more details: http://www.ubc.com/contact/locations), as necessary to provide the Services you have requested, and to fulfill any of the other purposes set out above.
We will also share your Personal Information with third party service providers, who will process it on behalf of UBC for the purposes above. Such third parties include, but are not limited to, UBC clients, research consultants, IT service providers (including customer relationship management vendors), payment providers, expense management vendors, credit and background check companies, banks, email providers, etc.
In certain circumstances, we may be legally compelled to share your Personal Information with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law (for example, in response to a court order, subpoena, search warrant, law or regulation) or if required for the legal protection of our legitimate interests in compliance with applicable laws.
If you are located in the EEA, note that we may transfer your Personal Information outside the EEA to countries that do not offer the same level of protection as required by the EEA (e.g., to a UBC affiliate or third party in the US). In order to safeguard your Personal Information, we will only make such transfers on the basis of: (i) an adequacy decision by the EU Commission, or (ii) subject to EU Commission approved standard contractual clauses or an appropriate Privacy Shield certification. A copy of the relevant mechanism can be provided for your review on request to: firstname.lastname@example.org
Except to the extent prohibited by law, and subject to this Privacy Notice, we will retain and use your Personal Information for as long as it is needed to provide you with the Services you have requested or access to our Site and Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where we process Personal Information for marketing purposes or with your consent, we process the data until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Information so that we can respect your request in the future.
Where we process Personal Information to meet legal requirements, we hold this for as long as the law requires (for example, we may hold records to help prevent fraud and other prohibited or illegal activities).
Storage and Protection of Your Personal Information
UBC employs data collection, storage and processing practices and security measures designed to protect Personal Information against unauthorized access, alteration, disclosure or destruction. Where appropriate, UBC uses firewalls and limits who can access databases that store Personal Information.
Please keep in mind that it is not possible to achieve a perfect state of data security. Although we undertake reasonable security measures to protect your Personal Information from unauthorized access, we cannot ensure absolute security of your Personal Information or guarantee that Personal Information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosure of any breach of your unencrypted electronically stored Personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Site, you agree to accept notice in that form.
We do not knowingly collect Personal Information from children under age thirteen (13) in the United States through our Site. If we learn that we have collected Personal Information directly from a child under the age of thirteen (13) through our Site, we will delete that information.
Links to Other Websites and Third Party Content
Your Rights Regarding Your Personal Information
Your Rights – European Union Residents
Pursuant to the European General Data Protection Regulation and where allowed by law, such as in the EEA and Switzerland, you have the right to ask us for a copy of your Personal Information; to correct, delete or restrict (stop any active) processing of your Personal Information; and to obtain the Personal Information you provide to us for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your Personal Information in some circumstances (including where we are using the data for direct marketing).
These rights may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have overriding legitimate interests in keeping.
Your Rights – California Residents
Access to Specific Information and Personal Information Portability Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past 12 months. This right of access includes information about:
You can request access to the personal information we have collected about you in the last 12 months here.
Deletion Request Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions
California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.
Exercising Access, Personal Information Portability, and Deletion Rights
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
We are not required to respond to a consumer’s requests for access or disclosure of Personal Information more than twice in a twelve (12) month period.
You can request us to delete your personal information we have collected from you here.
The CCPA permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described above to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.
No Sale of Personal Information
We are not currently selling your Personal Information.
UBC is a Service Provider under the CCPA
UBC acts as a Service Provider as defined by the CCPA when it collects Personal Information on behalf of UBC’s clients. In such instances, any request for such Personal Information should be made directly to the organization that uses UBC’s Services. If you submit a verified consumer request to UBC for such information, we will direct you to make that request directly to our client. If UBC has collected your Personal Information outside of its role as a Service Provider, UBC will respond to your verified consumer request accordingly.
Information Exempt from the CCPA
Note that certain information that is governed by the California Confidentiality of Medical Information Act (CMIA), HIPAA, or is subject to the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, pursuant to good clinical practice guidelines issued by the International Counsel for Harmonisation or pursuant to human subject protection requirements of the United States Food and Drug Administration, is not considered Personal Information with respect to the rights of California residents noted above. However, additional rights might be available under those laws and standards. Please contact UBC Compliance at email@example.com for more information.
No Sharing of Personal Information for Direct Marketing Purposes
We do not share Personal Information with other people or non-affiliated businesses for their direct marketing purposes.
Your Rights – Nevada Residents
Although UBC does not sell Personal Information, Nevada residents have the right to submit a verified request directing UBC not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted below at “Exercising Your Rights.”
Exercising Your Rights
To exercise any of the rights described above, you can get in touch with us – or our data protection officer by:
Changes to Our Privacy Notice
We use Personal Information within the scope of use described in this Privacy Notice. However, from time to time, we may, in our sole discretion, modify this Privacy Notice, indicated by a new version number and revision date. It is important that you check this Privacy Notice when you visit the Site. Your use of the Site, and your continued use of the Site after this Privacy Notice has been updated, indicates your agreement and acceptance of this Privacy Notice, including the modifications made as of the date of your use.
In the event that you have a question regarding this Privacy Notice, UBC’s data protection practices/procedures, Personal Information processing, or would like to access this Privacy Notice in an alternative format, you can contact our data protection officer at: firstname.lastname@example.org.