Privacy Policy
- RESPONSIBILITY FOR THE PROCESSING OF YOUR DATA
This Privacy Policy describes how we collect, use and share your personal data in connection with our business including through the CLINICAL TRIALS FOR ALL website (https://www.clinicaltrialsforall.org/).
The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we collect and process your personal data. The following is a brief summary of the manner and purposes for which we process your personal data.
CLINICAL TRIALS FOR ALL (“CLINICAL TRIALS FOR ALL“, “we,” “us” or “our“) is the entity that is responsible for the processing of personal data referred to in this Policy. If you have any questions or concerns about CLINICAL TRIALS FOR ALL’s use of your personal data, please contact us at alyssa@scorrmarketing.com.
We collect and use your information as described below as part of our business as a marketing agency, in order to expand and keep up to date our network of contacts and clients, to provide our marketing services, understand our market, and improve our websites, online channels and other activities.
- HOW WE COLLECT AND USE YOUR PERSONAL DATA
- Information that you provide to us. If you provide us with your contact details (for example, when meeting our representatives, by giving us a business card at conferences or events, by telephone or email or other communication methods), or if you file a form or register on our website or provide details through the ‘contact us’ page of our website, we will add these contact details (including your name, email address, home address, telephone number, country of origin and other details you may provide us) to our contacts databases.
- Communications. We retain messages you send to us (through electronic or hard copy commutations) and other personal data you provide to us. We use this data for our business purposes in order to administer our business, market our services, communicate with clients and contacts and expand our client base and network of contacts.
- Our communications. Insofar as permitted under applicable law, we may use the information we collect or receive about you to communicate directly with you in relation to our business. Subject, where necessary, to obtaining your consent to receiving such communications, we may use the information to communicate with you in relation to other services that we offer. For example, we may use the information to send you emails containing newsletters, articles, promotions and special offers. We may also use the information to send you service-related notices (e.g., account verification, technical and security notices) and generally to administer our business.
- Using our website. We collect personal information about you when you view content on or otherwise interact with our website, such as, by responding to surveys or questionnaires or by purchasing services through the website. For example, when you visit our website or visit third-party websites or applications that include our content or ads, we may receive information about you by automatically collecting “Log Data.” This Log Data may include your IP address, browser type, operating system, the referring web page, pages you visited, your location data, your mobile carrier, device information (including device and application IDs), search terms you used, or cookie information (see below). We also receive Log Data when you click on, view or interact with links on our website or ads, including links to third-party applications. We use Log Data to make inferences, like what information you may be interested in, and to customize the content, including ads, we show you on our website and on third-party sites. We keep Log Data as needed for the purposes described in this Privacy Policy.
- Information received through our ads. We may collect information about you if you follow our content, links or ads that we may post on other websites. We may collect information in these situations just as we do when you use our website. Our ad partners and affiliates may share information with us such as a browser cookie ID, mobile device ID, or cryptographic hash of an email address, as well as demographic or interest data and content viewed or actions taken on a third-party website or app. Our ad partners may enable us to collect similar information directly from their websites or apps by integrating our advertising technology.
- Cookies. When you use our website, we use cookies (small text files containing a string of alphanumeric characters) that are installed on your computer and that enable us to uniquely identify your browser and enhance your navigation on our website. A cookie may also convey information to us about how you use the site (e.g., the pages you view, the links you click and other actions you take), and it may allow us or our third-party analytics tools we use to track your usage of the website. We use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the website. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookie. If you turn cookies off, some features will be disabled. This may make your site experience less efficient and the site may not function properly.
- Analytics. We collect, measure and analyze traffic and usage trends relating to users’ use of our website, and we use third-party analytics tools to help us do so. This allows us to understand, among other things, who is using our website, how they use it and how we can improve our website. Such third-party analytics tools use cookies and persistent device identifiers to collect and store information including, but not limited to time of visit, pages visited, time spent on each page, your interactions with links across our website, IP address, unique device ID, advertising tags and type of operating system used. You can block Google Analytics from tracking your online activities by using the Google Analytics Opt Out Browser add on.
- Device identifiers. When you access or use our website using a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the website. A device identifier may remain persistently on your device to enhance your navigation of the website. Some features of our site may not function properly if use or availability of device identifiers is impaired or disabled.
- Use of certain service-type information. We may use information collected on our website from cookies, log files, device identifiers, location data, clear GIFs and other tools to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the website; (ii) provide custom, personalized content or information to you or others; (iii) monitor the use of the website; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.
- Advertising: We may use the information described in this Privacy Policy to help make our advertising more relevant to you, to measure its effectiveness and to help recognize your devices to serve you ads on and off of our website. We prohibit advertising content or targeting ads based on categories we consider sensitive, such as race, religion, politics, sex life or health (also referred to as “interest-based advertising”). If you prefer, you can opt out of interest-based advertising through the Digital Advertising Alliance’s consumer choice tool at https://optout.aboutads.info. We will not use information from the browser on which you opt out for interest-based advertising, and that browser or account will not be eligible to receive interest-based ads from our website. Website users can set preferences for how Google advertises to you using the Google Ad Settings page.
- YOUR RESPONSIBILITIES
It is important that the personal data we hold about you is accurate and current. If you provided us with any details of personal data, please keep us informed if such details change by emailing us at alyssa@scorrmarketing.com.
- HOW WE SHARE YOUR INFORMATION
We do not disclose your private personal information except in the limited circumstances described here.
- Service Providers. We may share datasets containing your personal data with third-party service providers that perform services on our behalf in connection with our business, such as cloud service providers that we may use, or third-party analytical service providers. Where your information is shared with such third parties, we ensure that the third-party service provider will deal with your information only on our behalf and on our written instructions and solely for our benefit (and not for its own benefit).
- Business Change. If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer databases containing personal data of users to a successor party or parties in connection with such transaction or change in ownership or legal structure.
- Necessary Disclosure. To the extent permitted or required by applicable law, and as we may determine as necessary in the circumstances, we may disclose information about you to third parties to: (i) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (ii) protect our rights, reputation, safety or property, or that of our clients or others; (iii) protect against legal liability and establish or exercise our rights to defend against legal claims; or (iv) investigate, prevent or take action regarding known or suspected illegal activities, security breaches or technical issues. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
- Non-Personal, Aggregated or Device-Level Information: We may share or disclose non-personal, aggregated or device-level information such as the number of users who clicked on a particular link, the characteristics of a device or its user that indicate when it is available to receive an ad, or aggregated or device-level reports to advertisers about users who saw or clicked on their ads. This information does not include your name, email address or phone number. We may, however, share non-personal, aggregated or device-level information through partnerships with entities that may use data in their possession (including data you may have given them) to link your name, email address or other personal information to the information we provide them.
- HOW WE PROTECT YOUR INFORMATION
We take certain measures to protect personal data we collect against loss, theft and unauthorized access, use, disclosure, destruction or modification. These include physical, technological and administrative measures.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and who are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.
- HOW LONG WE KEEP YOUR INFORMATION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Insofar as the data is collected to enable us to recognize you as a client of our business and to administer our business, we will dispose of the data within a reasonable time after we determined that you ceased to be a client or potential client of our business.
- COUNTRY OF PROCESSING
We carry out our business from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. We store and otherwise process data (including personal data) through third-party cloud service providers and other IT service providers that may be located or that may operate in other countries.
- CHILDREN’S PRIVACY
Our business offerings are not directed to children and our website is intended for use by adult professionals only. We do not knowingly collect personal data from individuals under 13 years of age. If you are under the age of 13, please do not submit any personal information to us.
- THIRD-PARTY SITES AND SERVICES
Our website may reference or provide links to other websites, applications or resources. If you access any website, application or resources provided by a third party, our Privacy Policy will not apply. Your interactions with such websites, applications and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.
- FAIR INFORMATION PRACTICES
The Fair Information Practice Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices, we will take the following responsive action, should a data breach occur:
We will notify users via in-site notification within 7 business days.
We also agree to the Individual Redress Principle that requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
- CALIFORNIA PRIVACY RIGHTS
- Requesting Information. Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to alyssa@scorrmarketing.com with “Request for California Privacy information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal data sharing is covered by Section 1798.83’s requirements.
- CalOPPA. According to CalOPPA, we agree to the following:
- (i) Users can visit our site anonymously.
- (ii) You will be notified of any Privacy Policy changes on our Privacy Policy Page.
- (iii) You can change your personal information by emailing us.
- INFORMATION FOR EU RESIDENTS
For the purpose of data we collect from individuals in the European Union (“EU”), we rely on the following lawful basis for the processing of your personal data:
- Our legitimate interests in (among other things) carrying out, administering and marketing our business, conducting commercial research, improving and maintaining our website, personalizing and tailoring content made available to you through the website, dealing with our assets in the event of a business change, protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints;
- Where relevant, your express consent. If you give your consent, you can withdraw it by emailing us at alyssa@scorrmarketing.com or clicking on the “Connect” link on our home page.
- Where relevant, the fulfilment of our contractual obligations to you or in response to your request ahead of contracting with us; and
- Where relevant, for compliance with legal obligations to which we are subject.
- EU DATA SUBJECT RIGHTS
Users based in the EU have the following legal rights in respect of their information:
- The right to require CLINICAL TRIALS FOR ALL to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
- The right to require CLINICAL TRIALS FOR ALL to rectify inaccurate information without undue delay;
- Where CLINICAL TRIALS FOR ALL has relied on the “consent” basis for processing that information, the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;
- The right to request the erasure of their information. You can make a request for erasure where:
- (i) the information is no longer necessary in relation to the purpose for which it was collected;
- (ii) the processing of the information is based on the user’s consent (and the other circumstances described in the “Legal Basis for Processing Your information” and “How We Share Your information” sections above no longer apply), if the user withdraws his or her consent; or
- (iii) the personal data is processed by CLINICAL TRIALS FOR ALL solely on the basis of our legitimate interests referred to in the section “Information for EU Residents” (and the other legal basis set out in that section do not apply), if the data subject objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defense of legal claims).
- The right to require CLINICAL TRIALS FOR ALL to restrict its processing of a person’s personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, CLINICAL TRIALS FOR ALL will only process that information with the express consent of the data subject, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
- Where data is processed based on a person’s consent or to fulfill a contractual obligation, the data subject may have the right to receive his or her personal data from CLINICAL TRIALS FOR ALL in a structured, commonly used and machine-readable format;
- The right to object to the processing of personal data where:
- (i) CLINICAL TRIALS FOR ALL relies solely on the “legitimate interest” basis for processing that data, in which case we may be legally required to stop processing the data subject’s information unless we have compelling legitimate grounds for the processing which override the data subject’s privacy rights and interests; or
- (ii) the information is used for direct marketing purposes, in which case we will immediately stop processing the personal data for such purposes.
- Data subjects have the right to lodge a complaint with the data protection supervisory authority of the EU member state where the person resides.
The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
- APPLICATION
This Policy relates to your personal data, i.e., data about you, an individual, from which you can be identified. This Policy therefore does not apply to any data insofar as it is held, processed, disclosed or published in a form that cannot be linked to a living individual (such as anonymized data, or aggregated data that cannot directly or indirectly be used to extract your personal data). We reserve the right to generate anonymized and aggregated data extracted out of any databases containing your personal data and to make use of any such anonymized and aggregated data as we see fit (including publishing such data and sharing it with third parties).
- CHANGES TO THE PRIVACY POLICY
We may update this Policy from time to time, and the updated version of this Policy will be effective upon posting on https://www.clinicaltrialsforall.org/privacy-policy/. Please check this page to review the most up-to-date version of this Policy.
If we make a change to this Policy that, in our sole discretion, is material, we will notify you via email to the email address associated with your last communication.
- QUESTIONS/CONTACTING US
If you have any questions regarding this Privacy Policy or if you wish to make a request in accordance with your rights explained above, you may email us at alyssa@scorrmarketing.com or contact us by mail addressed to:
CLINICAL TRIALS FOR ALL
2201 Central Ave
Kearney, NE 68847