Privacy Policy

Effective Date: 02/05/2021

Privacy Commitment

This Privacy Policy applies to all websites developed, maintained and operated by SPLASH CLINICAL LLC. SPLASH CLINICAL LLC is an innovative patient recruitment firm that uses digital & social media to recruit patients for clinical trials.  We perform as a data “processor” that processes personal data on behalf of clinical trial sponsors. You are responsible for carefully reading this Privacy Policy in its entirety. This Privacy Policy describes the information we collect about you and how we keep your personal information safe and confidential.

SPLASH CLINICAL LLC understands that privacy is important to you. The information that we collect about you from our websites will be maintained and used in accordance with this Privacy Policy and applicable laws, rules and regulations.  By accessing our websites, you agree to the terms and conditions set forth herein.  If you do not agree to any of the terms or conditions in this Privacy Policy, please do not access or use any part of our websites.

By providing us with your Personally Identifiable Information (as defined below), including Personal Health Information (as defined below), you consent to the collection and use of any information you provide in accordance with this Privacy Policy.

SPLASH CLINICAL LLC may share information among its subsidiaries and third parties working with or on behalf of SPLASH CLINICAL LLC, and such information shall be protected in accordance with the terms of this Privacy Policy.

SPLASH CLINICAL LLC is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Information We Collect

We will collect information through the use of Cookies (as defined below), Web Logs (as defined below), or IP Address (as defined below). We will only collect Personally Identifiable Information (as defined below) including Personal Health Information (as defined below) if you voluntarily provide such information to us.

Cookies

We collect non-identifiable web usage data about your use of our website through the use of Cookies. A Cookie is a small piece of information that our server sends to your web browser when you access our websites. Every computer that accesses our websites is assigned a different Cookie by SPLASH CLINICAL LLC. Cookies are capable of storing many types of non-identifiable data. Cookies may be used to help us analyze usage of our websites or to restrict underage use of the website. We do not link basic data from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store Personal Health Information about you.

Most browser software can be set to reject all Cookies. Note, however, that some portions of our websites may not work properly if you reject Cookies.

IP Addresses

We may also receive IP addresses in the normal course of the operation of our websites. An IP address is a number assigned to you by your Internet service provider so you can access the Internet.  Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

Web Logs

SPLASH CLINICAL LLC uses standard Web Logs that record basic data about your visit to our websites, such as the date and time of the visit, the pages viewed during the visit and the domain name of your Internet service provider.

We do not normally seek to identify individuals from Web Logs. However, we may use Web Logs to identify an individual whom we suspect tried to damage our websites or use them in an unauthorized way. We may share our Web Logs with law enforcement agencies if we believe there has been a violation of computer security or related laws or as otherwise required in order to comply with applicable law or legal process. In addition, we may share our Web Logs (which do not contain any Personally Identifiable Information) with our partners to assist them in better designing their websites for clinical research studies.

Google Analytics

Our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) which uses cookies to help analyze how users use the sites. The information generated by the cookies about your use of the websites (including your IP address) will be transmitted to and stored by Google [on SPLASH CLINICAL LLC’s behalf] under Google’s privacy policies:

Google: http://www.google.com/intl/en/analytics/privacyoverview.html

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our websites. By using our websites, you consent to the processing of your information by Google in the manner and for the purposes set out above.

Use and Disclosure of Personally Identifiable Information and Personal Health Information

Personally Identifiable Information that may be collected via a clinical research study survey is information that can be traced back to an individual. Personal Health information is a combination of your Personally Identifiable Information with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your name,
it becomes Personal Health Information. Examples of Personally Identifiable Information include your name, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information.

You may voluntarily provide Personally Identifiable Information and/or Personal Health Information, and if you choose to do so, you consent to our collection and use of such information as described in this Privacy Policy.  We will use the Personally Identifiable Information and Personal Health Information that you provide to determine if you may be eligible for research study participation. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SPLASH CLINICAL LLC. Inaccurate information will affect our ability to properly determine if you may qualify to participate in a research study.

While you may view some of our study websites without providing Personally Identifiable Information, this information will be required to be considered for participation in a research study.

We will not use or disclose Personally Identifiable Information or Personal Health Information of users of our clinical research study websites for any purpose other than those described in this Privacy Policy. If these uses change at any time, we will update the privacy policy on our websites. We use and disclose Personally Identifiable Information and Personal Health Information obtained from users in the following ways: 

    • COMMUNICATION WITH REGARD TO STUDY REFERRAL PRE-QUALIFICATION AND/OR OTHER STUDY-RELATED PURPOSES
      Personally Identifiable Information will be used by SPLASH CLINICAL LLC to follow-up with the clinical study site about your pre-qualification for and participation in the study and may be shared with the clinical study site for its assessment of your qualification for and participation in a study.
    • AGENTS AND SERVICE PROVIDERS SUPPORTING STUDY RECRUITMENT EFFORTS
      We sometimes employ web hosting companies to maintain our clinical study websites and data collected through those websites on our behalf in support of our study recruitment efforts. We may share your personal information, such as your name, disease or condition, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information, with these hosting companies so that they may perform such web hosting services for us.  With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.

We may also be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, in response to a search warrant, subpoena, court order, or  other valid legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or be inconsistent with our legal obligations.

Disclosures may also be appropriate in any of the following circumstances: (a) to protect our legal rights or the rights of users of our websites, (b) to protect the security or integrity of our websites, (c) to take precautions against liability, (d) to enforce this Privacy Policy, (e) if SPLASH CLINICAL LLC undergoes any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, (f) to detect, prevent, or otherwise address fraud, (g) pursuant to your explicit approval, or (h) during emergencies if physical safety is believed to be at risk.

In cases of onward transfer to third parties of data of EU, United Kingdom and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, SPLASH CLINICAL LLC is liable unless we  can prove we were not a party to the actions giving rise to the damages.

Aggregate Data

We will combine the information you provide with information from other visitors to our websites to create Aggregate Data which does not contain any uniquely identifying information. We will share this Aggregate Data with the sponsors of our websites, and/or their consultants. We will periodically analyze this Aggregate Data and use what we learn to make improvements to our websites. We may  also share this Aggregate Data with our partners to assist them in better designing their websites.

Children’s Privacy

We are committed to protecting the privacy of children. Neither SPLASH CLINICAL LLC, nor any of its websites or services, are designed or intended to attract children under the age of 13. We do not collect, solicit, or use Personally Identifiable Information from any person we actually know is under the age of 13.  If we learn that we collected Personally Identifiable Information from any child under the age of 13, we will endeavor to delete that information as soon as possible.  Please contact SPLASH CLINICAL LLC at info@splashclinical.com or phone number (414)-443-3280 if you have reason to suspect that we have collected Personally Identifiable Information of any child under the age of 13.

Data Security

We maintain generally accepted industry standard technical, physical, and organizational procedures to safeguard Personally Identifiable Information and Personal Health Information against unauthorized or unlawful processing and against accidental loss, alteration, disclosure and access.  Please note, however, that there are inherent risks in transmission of information over the Internet and electronic storage of information, and we cannot guarantee that unauthorized access or use of your Personally Identifiable Information or Personal Health Information will never occur.

Sharing Information with Third Parties

We may be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, or in response to a search warrant, subpoena, or court order. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or court order. Disclosures may also be appropriate to protect our legal rights, to protect the security or integrity of our websites, to take precautions against liability, or during emergencies if physical safety is believed to be at risk. These types of disclosures are unlikely to occur, but we want you to be aware that they are possible.

Links to Other Websites

Our websites may contain links to other websites. Please keep in mind when you access websites operated by other parties, whether through links on our website or otherwise, that we do not control what happens on those websites. You should always check the privacy policy of the website you are visiting in order to be sure you know how the operator of that website will collect information from you and what the operator of that website will do with the information.

Internet Transmission Risks

We acknowledge that no internet transmission is ever 100% secure or error free. It is your responsibility to ensure that the computer you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer, there is a risk that the information you provide could be disclosed to unauthorized third parties. Similarly, despite SPLASH CLINICAL LLC’s efforts to protect your Personally Identifiable Information and Personal Health Information, as noted above, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.

Rights to Access, Amend, and Delete Information

SPLASH CLINICAL LLC acknowledges the EU and Swiss individual’s right to access their personal data.  We provide you with reasonable access to the Personally Identifiable Information and Personal Health Information that we maintain about you. Subject to any legal requirements, you are given a reasonable opportunity to correct, amend, or delete information that is inaccurate. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe.

Change Notification

As privacy laws and regulations evolve, it may be necessary to revise or update  our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by  referring to the “Effective Date” of this policy.  Your use of our websites constitutes your acceptance of the terms of the revised Privacy Policy, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms.

Retention of Personally Identifiable Information and Personal Health Information

We will only maintain Personally Identifiable Information and Personal Health  Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it was collected or processed. We will delete Personally Identifiable Information and Personal Health Information when such time period has ended.

For EU Individuals: Your Rights under the General Data Protection Regulation

SPLASH CLINICAL LLC performs as a data “processor” that processes personal data on behalf of clinical trial sponsors. Pursuant to the General Data Protection Regulation (GDPR), if you are interested in participating in a study that appears on our clinical research study website, we request that you opt-in to consent to our collection and processing of your personal data for purposes of recruitment for the relevant research study.  These opt-in requests will be presented as check boxes under which you will have the opportunity to affirmatively indicate your consent to the processing of your personal data as described in this privacy policy and/or as described on our clinical research study website (as applicable).

Under the GDPR your rights are as follows.

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• the right not to be subject to automated decision-making including profiling.

These rights are described further, as required by the GDPR, on our clinical research study websites.

You also have the right to complain to a supervisory authority in the EU Member State in which you are located if you feel there is a problem with the way we are handling your data.  You can find a list of supervisory authorities here: http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm.

 

For Individuals in the European Economic Area:

VeraSafe has been appointed as SPLASH CLINICAL LLC’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to SPLASH CLINICAL LLC, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at:  VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.

For Individuals in the UK:

VeraSafe has been appointed as SPLASH CLINICAL LLC’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom VeraSafe, can be contacted in addition to or instead of SPLASH CLINICAL LLC, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003. Alternatively, VeraSafe can be contacted at:  VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.

EU-US and Swiss-US Privacy Shield Frameworks

SPLASH CLINICAL LLC complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework (Privacy Shield) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information. SPLASH CLINICAL LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

EU, United Kingdom (UK), and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also request that we correct, amend, or delete the personal information we hold about you.  If you wish to make any of these requests, please contact info@splashclinical.com.

We will provide an individual opt-in choice before we share your sensitive data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or  subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to info@splashclinical.com.

SPLASH CLINICAL LLC commits to subject to the Privacy Shield Principles all personal data it receives from the EU, UK and Switzerland in reliance on the Privacy Shield.  SPLASH CLINICAL LLC remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless SPLASH CLINICAL LLC proves that it is not responsible for the event giving rise to the damage.

EU, UK, and Swiss individuals with Privacy Shield inquiries or complaints should first contact SPLASH CLINICAL LLC at:

SPLASH CLINICAL LLC
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI  53222

USA
info@splashclinical.com
(414)-443-3280

Individuals in the European Economic Area or UK may also contact VeraSafe, SPLASH CLINICAL LLC’s representative, using the relevant contact information included in the section above (“For EU Individuals: Your Rights under the General Data Protection Regulation”).

SPLASH CLINICAL LLC will  refer any unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD,. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration

Please be advised that SPLASH CLINICAL LLC is subject to the investigatory and enforcement powers of the FTC, the Department of Transportation or any other U.S. authorized statutory body.

Privacy Contact Information

Questions or comments regarding this Privacy Policy, our practices, or our Privacy Shield participation should be submitted to:

SPLASH CLINICAL LLC
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI  53222
USA
info@splashclinical.com

Reservation of Rights

SPLASH CLINICAL LLC reserves the right to share an individual’s information as required by law or to duly authorized information requests of government authorities.

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