Introduction and Scope

Klinisol LLC, having its registered address at 600 Broadway STE 200 #2189, Albany, NY 12207 (“Klinisol”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (the “Policy”) addresses data subjects whose Personal Data we may receive from our customers or business partners (“Clients”) in or through our Klinisol Web Application and Klinisol Mobile Application and Klinisol website www.klinisol.com (together hereinafter referred to as the “Klinisol Mobile and Web Applications”).

Information for California Residents

If you are a California resident, please refer to the “Additional Information for California Residents” below. 

Controllership

Klinisol acts as the data controller for personal information derived from activity on Klinisol Mobile and Web Applications. We use the personal information under this Policy. 

In some cases, Klinisol acts as an agent, also known as a data processor, for the Personal Data we process for our Clients when providing our Klinisol Mobile and Web Applications. This means that our Clients determine the type of Personal Data they provide for us to process on their behalf. We typically have no direct relationship with the individuals whose Personal Data we receive from our Clients.

Basis of Processing

Within the scope of this Policy, we process Personal Data based on the lawful basis, including:

• consent and/or instructions of our Clients;
• contractual obligations (when the Personal Data processing is necessary to perform our obligations under a contract);
• legitimate interests;
• compliance with applicable law (when we follow applicable personal data in order to be complied with).

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

How We Receive Personal Data

We may receive your Personal Data when:

• You provide it directly to us through the Klinisol Client’s account on the Klinisol Mobile and Web Applications;
• You subscribe to our news, newsletters, updates or media releases;
• Your complete and submit any forms to us;
• You contact us directly in person or via any medium including but not limited to by mail, telephone, social media and commercial electronic messages;
• You communicate with us for any matters and interact with or browse the Klinisol Mobile and Web Applications generally;
• Our Clients (including their employees, contractors, and other representatives of the company) provide it to us.

Categories of Personal Data

In the Klinisol Mobile and Web Applications, we may process the following types of Personal Data:

• Biographical information, such as first and last name;
• Contact information, such as phone number, email address and postal addresses;
• Information regarding your occupation, purchase history;
• Device information, such as IP address, and browser version; and
• Any other information posted by users in community forums.

We collect data from every visitor and customer of the Klinisol Mobile and Web Applications, in particular we automatically collect data about your visit to the Klinisol Mobile and Web Applications, your usage of the services and your browsing activities. This anonymized information may include IP address, browser type, browser language, cookies data, performance specifications of the user’s hardware and software, date and time of access to the website and the URL of the page requested, other information about how you interacted with our Klinisol Mobile and Web Applications. This type of data helps us to improve our services for both you and for all of our users.

Minors

Minors and children under age of 18 (or other legal age of your country of residence) should not use our Klinisol Mobile and Web Applications. We do not knowingly provide any services to minors. If you access our Klinisol Mobile and Web Applications or use our services, you represent that you have the legal capacity to enter into a binding agreement.

Purposes of Processing

In the Klinisol Mobile and Web Applications, we may process your Personal Data for the purposes of:

• enabling the use of the Klinisol Mobile and Web Applications;
• responding to your requests or questions;
• managing clinical trials;
• storing clinical trial information, team information, and clinical site information;
• providing customer support in response to customer inquiries;
• communicating available clinical trials to you; and
• generating applicable modules and reports.

Data Retention

We retain your personal data within the USA. We retain Personal Data for as long as instructed by the respective Client (who typically acts as a data controller). We delete the Personal Data submitted to us by our Clients or applicable patients within ten years of the end of our service agreement with the Client, unless applicable laws require otherwise.

Sharing Personal Data with Third Parties

We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Applications or as required by law. Our service providers may provide:

• application hosting services;
• cloud storage services;
• analytics services;
• document signature and management services;
• email software; and
• CRM software.

Some of these third parties may be located outside of the United States. However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do. We remain liable for the protection of your Personal Data within the scope of our Privacy Shield certification that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share your Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use your Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of the Personal Data with our Agents.

Other Disclosure of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). 

We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. If Klinisol sells or transfers all or some of the company’s business interests, assets, or both, or in case of a corporate restructuring, your Personal Data may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, Personal Data will always remain subject to this Policy.

Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our Applications.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Applications are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Applications. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Applications’ features. For more information, please visit https://www.aboutcookies.org/.

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Applications do not have the capability to respond to “Do Not Track” signals received from web browsers.

You can also use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction. While we strive to use commercially acceptable means to protect your Personal Data, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security of any data.

You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party. If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

Newsletters

We will send you newsletters and other news about our services if you subscribe to it. You can subscribe or unsubscribe from receiving news messages by using an unsubscribe link or sending us an email at privacy@klinisol.com.

Access & Review

If we process your or your child’s Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data.

You may access your Personal Data held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:

• delete some or all Personal Data that we held about you;
• change or correct your Personal Data that we held about you;
• object to, or limit or restrict, use of your Personal Data;
• right to access and/or take your Personal Data: you can ask us for a copy of your Personal Data in machine readable form;
• access information we hold about you.

If you request us to view, change and remove your Personal Data associated with your account, please contact us at privacy@klinisol.com. We will process your request within 15 business days. In accordance with the applicable laws, additional fees may be applied.

If your Personal Data was provided by the Klinisol Client, we will send your request directly to Klinisol Client. Klinisol has limited rights to access Personal Data our Clients submit to us. Therefore, if you contact us with such a request, please provide the name of the Klinisol Client who submitted your Personal Data to us. We will forward your request to that Client and provide any needed assistance as they respond to your request.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

For Personal Data processed in the scope of this Policy, Klinisol complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (the “Privacy Shield”), as adopted and set forth by the U.S. Department of Commerce regarding the processing of Personal Data transferred from the European Union, the European Economic Area, the United Kingdom, or Switzerland to the United States, or otherwise received in reliance on the Privacy Shield. We commit to adhere to the Privacy Shield Principles and have certified our adherence to the Department of Commerce.

Applicable Law and Dispute Resolution

This Agreement will be governed by and construed in accordance with the laws of the State of New York excluding that body of law known as conflicts of law. The Parties will endeavor to settle amicably by mutual discussions any disputes or claims related to this Policy. Where a privacy complaint or dispute cannot be resolved through our internal processes, we have agreed to to the exclusive jurisdiction of the state and federal courts sitting in the City of New York.

U.S. Regulatory Oversight

Klinisol is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Last Updated” date.

Additional Information for California Residents

In this section we describe how we handle Personal Data of California residents under the California Consumer Privacy Act (“CCPA”). This clause covers personal information that we collect, share and use for the last 12 months. 

We describe the Personal Data that we collect in section “Categories of Personal Data”. The section “Purposes of Processing” contains information on how we use Personal Data.

We share certain Personal Data in accordance with section “Sharing Personal Data with Third Parties”. However, we do not sell your Personal Data to third parties.

In accordance with the CCPA, California residents are entitled, in addition to other rights described in this Policy, to:

• Request deletion. You have the right to request deletion of your Personal Data that we collect from you;
• Request copy. You have the right to ask for a copy of all or part of Personal Data that we retain about you over the last 12 months;
• Designated agent. You are entitled to designate an agent who is able to make requests on your behalf. The agent should access your account to make a request.
• List of service providers. You have the right to request a list of third parties with whom we shared Personal Data (if any) for marketing purposes and what kind of information we shared during the previous calendar year.

If you want to exercise your rights, please contact us at privacy@klinisol.com. 

Klinisol does not tolerate discrimination. The quality of our services is equal for all our users and customers, irrespective of whether you decide to exercise your rights under the CCPA.

Contact Us

If you have any questions about this Policy or our processing of your Personal Data, please write to our Privacy Lead by email at privacy@klinisol.com or by postal mail at:

Klinisol LLC
Attn: Privacy Officer
600 Broadway STE 200 #2189
Albany, NY 12207

Please allow up to four weeks for us to reply.