Certain features of the Application have been developed for clinical trial sponsors, and for clinical trial patients who are using the Application under the direction of licensed health care professionals, in order to facilitate and coordinate patient medication adherence in connection with those clinical trials. We have agreed to provide our medication adherence monitoring services and other clinical trial services to sponsors of a clinical trials and to provide you a statement concerning your privacy rights on behalf of such sponsors, who retain at all times control over the use of your data in the course of such clinical trials (“Covered Clinical Trials”).
1. Data Processing on Behalf of Sponsors of Clinical Trials.
In context of providing our Services, we are collecting and processing personal data on behalf of individual clinical trial sponsors. In case such processing activities are subject to the EU General Data Protection Regulation (“GDPR”) we will be acting as data processors (as such term is defined in the GDPR) pursuant to a data processing agreement meeting the requirements of the GDPR from the following categories of data subjects (collectively, “Affected Data Subjects”):
a) Individuals enrolled in a Covered Clinical Trial,
b) persons working with a clinical trial site and need access to our system.
In all those instances, the clinical trial sponsors determine the means and purposes of such processing activities, including, which patients will use an Application, the principal Application functions, the personal data it will collect, how that data will be used and by whom such data is accessed, and how long the data will be retained. The sponsor acts as controller (as such term is used under the GDPR) of the personal data and of the Affected Data Subjects and is responsible for giving them information about how the Application processes their personal data; we provide you the Application only in accordance with instructions from the sponsor.
2. Processing of Personal Data Resulting in Improvement of our Application and Meeting our Compliance Obligations.
In context of your enrollment with a Covered Clinical Trial, our processing of your data will also result in improvement of our systems and therefore indirectly support other our commercial products, or our regulatory filings for future applications of our product. Collected non-identifiable and anonymized data may also be retained after the Covered Clinical Trial. If you are a resident of an EU Member State this type of processing activity will be subject to certain special conditions and rights that you have as a data subject more particularly described in this Additional Privacy Notice for Users in Jurisdictions Subject to GDPR Regulation.
3. Contacting Us
Attn: Gordon Kessler
General Counsel, Data Privacy Officer
214 Sullivan Street, 6C
New York, NY 10012
Changes to this Notice
If we alter our Privacy Notice, you can review any changes at this web location. Updated September 12, 2023