Effective Date: February 2018
MD Connect websites use a passive technology called “cookies” and other similar technologies. With cookies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as browser type, operating system and average time a visitor spends on our websites. MD Connect uses this information to help us understand our website activity and to monitor and improve our websites. Cookies also provide information about you and your preferences, and help us personalize your experience on our websites. You can set your web browser to notify you when cookies are being placed on your system or to not accept cookies. However, if you decide not to accept cookies from our websites, you may not be able to take advantage of all of the features available to you on our websites.
Our websites use another passive technology called “internet tags” or “web beacons”. This technology allows us to understand which webpages you visit and helps us optimize and tailor our websites to you and other future visitors.
MD Connect also collects information from and about your mobile device, such as a unique device identifier.
Any request on our Site or through our service providers for sensitive information will be limited to the Identified Stage of the Pre-screening Process, will require express consent (e.g., website check box, you voluntarily clicking a button (e.g. ‘Submit’) which clearly indicates doing so provides consent), and will be specific and necessary to Sponsor’s clinical trial pre-screening requirements. Sensitive personal information that may be collected includes:
When you visit our Site or contact us, we collect personal information that you provide voluntarily. Most of our websites contain a Pre-Screening Questionnaire (PSQ) where we collect personal information when you answer questions on the website or otherwise provide to us by telephone or email. During Pre-Screening, MD Connect only collects personal information that is limited and necessary to evaluate your eligibility and qualifications for participation in our Sponsor(s)’ current and future clinical trials. Many of our websites will use a two-stage PSQ, where in the first stage we will ask questions that will not yet uniquely identify you (the “Pre-identified Stage”). This information may include:
MD Connect uses and discloses the information collected at this stage for some limited purposes necessary to the operation of our business and the delivery of services to you. These purposes include to:
If, through your answers at the Pre-Identified Stage, it is determined you will not be eligible for the relevant clinical trial(s), your answers may be stored for the relevant data retention period, but will not be individually identifiable (and thus are not Personal or Sensitive Information). In some cases, you will be asked if you wish to submit personal contact information so that you may be considered for future clinical trials.
If, through your answers at the Pre-Identified Stage, it is determined you may be eligible for the relevant clinical trial(s), you will be forwarded to a second stage of Pre-Screening.
The Identified Stage of the Pre-Screening Process requires you to express consent before submitting Personal or Sensitive information, which then may be collected via the Site, phone or e-mail. Additional information collected at this stage may include:
We combine the personal information you voluntarily submit with other information we have collected from you (including that collected at the Pre-Identified Stage), whether on or off-line, to collectively create a record with Personal or Sensitive information for the purposes of determining your eligibility for Sponsor clinical trials. We may also combine it with information we receive about you from other sources.
MD Connect uses and discloses personal information for a variety of purposes that are limited and necessary to the operation of our business and the delivery of services to you. These purposes include to:
MD Connect discloses personal information collected through its Sites to affiliated third party service providers, such as IT support services, customer service providers, and other services providers that support us and facilitate the services we provide to you. These companies are authorized to use your personal information only as necessary to provide these services to us. For example, we use Google Analytics, a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of this website, to prepare reports on its activities and share them with us, our contractors, and other Google services.
MD Connect may disclose information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. Further, we may use and disclose information collected through the Site as we believe to be necessary or appropriate, including: (a) as permitted by applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain. We may also disclose your personal information to any other third party with your prior consent.
MD Connect reserves the right to use the personal information collected as described above, in a de-identified or anonymized format, i.e. no longer personally identifiable as defined by data privacy regulations, for data aggregation and data analytics purposes.
Use of this Site or our services is not generally directed to individuals under the age of 18, and we request that these individuals not provide Personal Information through the Site or our service providers unless identified as appropriate in the Pre-Screening criteria. However, there may be some Sponsors of clinical trials that are specifically seeking this age group. In such clinical trials, parental consent may be required as part of the Pre-Screening process.
If personal information related to individuals under the age of 18 is identified and deemed inappropriate, reasonable steps will be taken to delete the information.
MD Connect uses reasonable measures in an attempt to protect your information, such as using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please notify us immediately by contacting email@example.com or by faxing to 781-235-0929.
If you would like to review, correct, update, or delete the personal information that you have provided via the Site, please contact us at firstname.lastname@example.org or by faxing to 781-235-0929. We will reply to your request in a reasonable period of time not to exceed 60 days.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Your information may be processed in the country in which it was collected or transferred to other countries, including the United States (where our servers are generally located), for processing where laws regarding processing of information may be less stringent than the laws in your country. By using this Site and our services, you consent to the transfer of your personal information to countries outside of your country of residence, including the United States.
MD Connect collects information under the direction of its Clients and occasionally for potential future Client use, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
MD Connect acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to MD Connect’s Client (the data controller) or MD Connect directly. If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Clients. MD Connect will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.