Third Parties:

• Service providers acting as processors and who provide services to us.
• Our partners who provide complimentary support and services for the purpose of recruiting for the clinical study.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
• Regulators and other state authorities acting as processors or joint controllers in any jurisdiction in which we are operating and who require reporting of processing activities in certain circumstances.

Covered Entity: an institution, organization or other entity that is subject to the rules of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in the United States. Covered Entities include: (i) a health plan, (ii) a healthcare clearinghouse and, (iii) a healthcare provider which transmit any personal identifiable health information in electronic form in connection with a transaction covered by HIPAA.

PIHI: Personal Identifiable Health Information is any information, including demographic information, collected from an individual that:

• relates to (a) the past, present, or future physical or mental health or condition of an individual; (b) the provision of healthcare to an individual; or (c)  the past, present, or future payment for the provision of healthcare to the individual; and
• Identifies the individual or there is a reasonable basis to believe it can be used to identify the individual; and
• PIHI does not include education records or medical records covered by the Family Education Rights and Privacy Act or employment records held by Trialbee in its role as an employer.

Personal Information: any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

We use various methods to collect the categories of data described above through but not limited to:
 
Data Interactions. You may have given your personal data by filling in forms or by corresponding with us by phone, and email or otherwise. This includes personal data you provide when you apply or register online or request information.
 
Automated Technologies or Interactions. As you interact with our services, we may automatically collect technical data about your equipment, browsing actions or patterns. We collect this personal data by using cookies, log files, and other similar technologies. We may also receive technical data about you from other websites that you visit employing our cookies. This aggregate data gives a “macro-view” of visitor traffic patterns and provides insight to what aspects of our services users interact with. None of this information is linked to any personal information. We collect and log technical data as described in section 3 above Data We Collect About You.
 
Third-parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:

• Analytics providers such as Google, Piwik Pro
• Advertising Networks
• Search information Providers
• Portals

We will use your personal data in the following circumstances:

• To support services to our client for the purposes of recruiting into a clinical research study.
• To find people who do similar online activities as you or share similar interests and present them with content about a possible research opportunity. This may also be referred to as “look-a-like modelling”,
• To perform obligations to you, our clients, or as required by law,
• Where we need to comply with a legal or regulatory obligation.
• In the EEA, when necessary for our legitimate interests or those of a third party, and your interests and fundamental rights do not override those interests.
• To support our work with our partners, who provide complimentary support and services for the purpose of recruiting for the clinical study. 

Trialbee will not share your personal data unless:

• We have informed you otherwise and obtained your permission or
• There is a legal or regulatory obligation or
• The law forces us to share the data.

In relation to using your personal data as described above, we will only do so where (i) we have your consent or (ii) you are an existing recipient of these communications. You have the right to withdraw consent at any time by contacting us via email at privacy@trialbee.com.

Declaration of Consent. We will describe how we plan to use your data. This consent area usually appears before or after an online questionnaire, but always before you submit any personal data to us.

The matrix below describes the ways we plan to use your personal data, the legal basis, and identifies the legitimate interests where appropriate.
 
The primary purpose of processing your personal and health data is to administer patient recruitment to the clinical study, and the legal basis for all related activities is your consent. There is more information about this in section 6.1 of this policy.

Note, that we may process your personal data for more than one lawful ground depending on the specific purposes, this has been set out in the table below:

Trialbee may share your personal data with trusted clients and service providers where needed, as set out below, for the purposes set out in the table in section 5.1, Why and how we use your data.

• Clinical research centres, sites, or clinics who are conducting the clinical research study that you submitted your information for.
• Third party sub-contractors who provide services for us and/or help to provide services to you.
• Third party sub-contractors who may transfer, or merge.
• Your email address may be shared with the following companies to identify other individuals on their platforms who share similar characteristics with you and present them with ad campaigns about clinical research studies. If change of control arises in relation to our business, the new owners may use your personal data in the same way as set out in this privacy policy.
• Meta (Meta Platforms Ireland Limited) or Meta (Meta Platforms Inc)
• Google (Google Ireland Limited) or (Google LLC)
• TikTok (TikTok Technology Limited) or (TikTok Information Technologies UK Limited) or (TikTok Inc.)
• We may disclose personal information to law enforcement, government authorities, or otherwise in response to a legal subpoena or process as required by applicable law or in the circumstances involving the possibility of physical or financial harm, fraud, or crime.

 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Please note that third parties may be located in countries with a different level of personal data protection than the country in which you are located. It is therefore possible that this may include a lower level of data protection that the country you reside in.
 
We do not allow our third-party service providers to use your personal data for their own purposes, unless you have consented to this, and only permit them to process your personal data for the specified purposes and in accordance with our instructions. Please note that Trialbee is not responsible for any personal data that you provide directly to a third party, such as social media networks. For information on how these third parties process your personal data, please see the respective third party’s privacy policy.
 
We do not sell or lease your personal data to any third party. Our use and disclosure of PHI is limited to the minimum amount needed to accomplish the intended purpose of the specific clinical research study and is used in relation to pre-qualification activities for such clinical research studies. This includes using questionnaires that only ask questions related/associated to the specific clinical research study as specified in approved protocols. Your information will not be disclosed unless we have clear consent from you to do so.

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and subsequent regulations published by the Department of Health and Human Services (“DHHS”) impose restrictions on other organizations (Covered Entities) which may be covered under HIPAA with respect to your relationship with Trialbee. Trialbee may, in providing recruitment services for one of these organizations, be required to comply with certain aspects of HIPAA in their conduct of human subject research activities.

Although Trialbee is not a Covered Entity as defined in the HIPAA privacy regulations, our policies, and procedures, which govern the privacy rights of research participants included in this privacy policy, are compatible with those required by HIPAA for Covered Entities and will become standard for research activities involving PIHI.

All PIHI data collected by Trialbee in connection with clinical study recruitment is captured electronically and transmitted through a secure network connection to a secure database. Trialbee’s data security policies are consistent with Good Clinical Practices, HIPAA, and GDPR standards.

You can opt-out and request us to stop sending you information, and/or reminders, for which you have consented to receiving, at any time by contacting us at privacy@trialbee.com.

Opting out of receiving information, and/or reminders, will not impact the personal data provided to us.

We use cookies and other technologies to improve our services to record user-specific information on webpages which are accessed or visited.

We use cookies:
(1) to learn how our services are used and how they perform, including cross-site statistics,
(2) to provide you with additional functionalities and personalization,
(3) to provide you social media interactions, and
(4) for targeting and marketing purposes.
 
You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our services may become inaccessible or not function optimally. With most types of internet browsers, you can erase cookies from your computer’s hard drive, block all cookies, block specific kinds of cookies, or even receive a warning before a cookie is placed on your system. Refer to your browser instructions or help button to learn more about cookies.

You may have the choice to accept all cookies, accept functional or necessary cookies, or reject / deny all cookies. If you consent to cookies, those cookies will be stored on your computer, tablet, or smartphone. If you opt-out of cookies, this may impact the functionality of the website you are trying to view.

We do not sell, lease, or transfer your personal data to any non-affiliated entity for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent. We may use third party companies who partner with us to provide complimentary support and services to Trialbee’s digital marketing for the purpose of recruiting for the clinical study. These companies may use data about your interactions with our services and other websites to measure advertising effectiveness and to provide advertisements about goods and services that may be of interest to you. If you would like more information about this, please contacting us at privacy@trialbee.com.

We use cookies to make our services work optimally. Cookies are used to save your settings, analyse how you browse, and customize content to suit you. They are also used to promote our services, and some cookies come from partners we work with.

Trialbee AB, company registration number 556814-3019, address: Södra Tullgatan 3, 211 40 Malmö, Sweden, privacy@trialbee.com, gathers, processes, stores, and shares personal data on behalf of the Controller for clinical research recruitment.
The Controller (the research study Sponsor) intends to conduct a clinical study to determine the safety and effectiveness of an investigational product. With regards to the processing of your personal data during the application process the Controller is the data controller responsible for processing your personal data in accordance with applicable data protection legislation. However, the Controller has assigned Trialbee AB (“Trialbee”) the task of processing your application for the study.

If you are interested in participating in the study Trialbee will ask you, on behalf of the Controller, to provide certain information about yourself to process your application for the study. This allows us to evaluate your potential eligibility for the study and to contact you during the application process. The information we intend to collect are your name, telephone number(s), e-mail address, ZIP code / postal code and answers to questions we ask you for determining eligibility. These answers may include information about your health. Health information is only used for the purposes of determining your eligibility for the clinical research study. This information will not be shared with the sponsor or the client who has requested our services for the purpose of recruiting into the clinical research study. Please see section 5.2 for who we may share your data with, your data will only be shared if you provide consent.

Information about you is stored in Trialbee’s system until the clinical study recruitment is completed, Trialbee’s services related to the study are complete or until you request that the data is deleted by emailing privacy@trialbee.com, whichever occurs first.

You can at any time withdraw your consent to the Controller’s processing of your personal data for the purposes of evaluating your application by contacting Trialbee at privacy@trialbee.com. If you withdraw your consent, then Trialbee will stop processing your personal data. If your information has been shared with a trusted third party, we will notify them of your withdrawal. If you have chosen to participate in the clinical research study and have signed the Informed Consent Form (“ICF”), you will need to communicate your request to withdraw your personal data with the research centre.

For further information about the Trialbee’s processing of your personal data on the Controller’s behalf and your rights according to applicable data protection legislation, see section 6.1 Data Subject Information.

Information about Trialbee’s processing of your personal data on behalf of the Controller to register your information for this clinical research study is listed below.

SPONSOR (the Controller)
Sanofi-Aventis Recherche & Development
82 Avenue Raspail
94250 Gentilly
France
 
Relevant point of contact:
Trialbee AB (“Trialbee”) (the Processor)                                                            
Company registration no. 556814-3019
Södra Tullgatan 3
211 40, Malmö
Sweden


Categories of personal data. Name, telephone number(s), e-mail address, ZIP code / Postal code, gender, age, and answers to questions we ask you for determining eligibility. These answers may include information about your health.
 
Purpose of processing. To administer patient recruitment to the clinical study. This includes administering your registration for the study by evaluating your eligibility and contacting you during the pre-qualification process, and identifying and targeting ideal audiences for recruitment of clinical study participants through "look-alike modelling.
 
Legal basis for processing. Your consent.
 
Legal basis for processing personal data regarding your health. Your consent.
 
Categories of recipient. The personal data will be processed by Trialbee on behalf of the Controller. Your personal data may also be shared with those involved with processing your application on behalf of Trialbee, i.e., medical professionals acting on behalf of the Controller and/or engaged by Trialbee on behalf of the Controller and/or staff from a study clinic (also known as a research centre, or site) who may contact you to determine study eligibility. These will be the only parties with access to this information.

In addition, your email address is shared with Meta (Meta Platforms Ireland Limited) or Meta (Meta Platforms Inc), Google (Google Ireland Limited) or (Google LLC), TikTok (TikTok Technology Limited) or (TikTok Information Technologies UK Limited) or (TikTok Inc.) to identify other individuals on their platforms who share similar characteristics with you to create a target audience for ad campaigns for the clinical study. This is referred to as “look-a-like modelling” and helps us spread awareness of the study more effectively.
 
Retention period. Trialbee will retain your personal data, on behalf of the Controller, until the clinical study recruitment is completed, Trialbee’s services related to the study are complete or until you request that the data is deleted, whichever occurs first.
 
Your rights. In accordance with applicable data protection legislation, you have a right to request access to or rectification of your personal data. Further, and to the extent set out in applicable data protection legislation, you may request erasure of personal data or restriction of the processing of your personal data. Under certain circumstances, you also have a right to object to processing as well as the right to data portability in accordance with applicable data protection legislation. If you want to exercise any of the above-mentioned rights, please do not hesitate to contact Trialbee (see contact details above). Where the processing of your personal data is based on your consent, you can withdraw such consent at any time by contacting either the Controller or Trialbee. Should you be dissatisfied with our processing of your personal data, please let us know, and we will do our best to meet your complaints. Your integrity is important to us, and we always strive to protect and secure your personal data in the best viable way. Should we nevertheless, in your opinion, fail in this ambition, please note that you have the right to lodge a complaint at any time to the relevant supervisory authority in the country where you reside.

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when transferred to our affiliates or third parties in other countries.

We and our third-party hosting partners have put in place the appropriate security measures to prevent your personal data from being lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data with least privilege to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have procedures in place to deal with suspected data security breaches and will notify you and any applicable regulators of breaches in accordance with relevant legal requirements.

We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for persona data, we consider the amount, nature, and sensitivity of the personal data, the potential risk or harm from unauthorised 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, along with the applicable legal requirements.

We also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
 
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
 
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In the US, you may be entitled to certain rights with respect to your Personal Information under the law of your state of residence. Please refer to our state specific privacy policy for more details. We reserve the right to amend the state specific privacy policy and will notify you by updating its notice, so please check the policy from time to time.

You may be entitled to certain rights that differ from those above with respect to your Personal Information under law(s) for your country of residence.

If you wish to exercise any of the rights set out above, please contact us at privacy@trialbee.com.

You will not have to pay a fee to access your personal data or to exercise any of the other rights above.

Our services are directed and intended to be used by an adult audience (such as individuals interested in clinical research and healthcare professionals). We do not knowingly collect information from children but may collect information from a parent or guardian of a child under the age of 18 years old, who are interested in finding out about the suitability of a clinical research study for their child. Please do not use our services if you are under eighteen.

If you are a parent or guardian of a child under the age of 18 years old who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by emailing us at privacy@trialbee.com

You should note that if our business (or any part of it) is sold or transferred at any time, the information we hold may form part of the assets transferred although it will still only be used in accordance with this Privacy Policy.

For quality control and training purposes, we may monitor or record your communications with us.