SPLASH CLINICAL LLC is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).
Information We Collect
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.
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.
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.
Collection, 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 may be used to identify you.
While you may view some of our study websites without providing Personally Identifiable Information, submitting Personally Identifiable Information to us will be required to be considered for participation in a research study.
- 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 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.
SPLASH CLINICAL LLC’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, SPLASH CLINICAL LLC remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process 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.
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.
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 firstname.lastname@example.org 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.
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.
Links to Other Websites
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 or device you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer or other device, 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 under certain laws and regulations, individuals have rights to access, amend and/or delete their personal data. To the extent such laws or regulations apply to SPLASH CLINICAL LLC, you may request that we provide you with access to, amendment of, or deletion of your personal data. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe and as required by applicable laws and regulations.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your 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 email@example.com
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.
EU-US and Swiss-US Privacy Shield Frameworks
In compliance with the Privacy Shield Principles, Splash Clinical, LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, 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
Splash Clinical, LLC has further committed to refer 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/privacy-shield-complaints/ 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 for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
For Individuals in the European Economic Area and United Kingdom
In some situations, SPLASH CLINICAL LLC acts as a data “processor” that processes personal data on behalf of clinical trial sponsors. Pursuant to the European Union’s General Data Protection Regulation and United Kingdom’s General Data Protection Regulation (collectively, the “GDPR”), if you are interested in participating in a study that appears on our clinical research study website, we may (on behalf of clinical trial sponsors) request that you opt-in/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 on our clinical research study website(s).
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 your personal data is handled. 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.
We may transfer Personally Identifiable Information and/or Personal Health Information about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws and regulations. Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country. Accordingly, with respect to an international transfer, your Personally Identifiable Information or Personal Health Information may be subject to different protections depending on the laws and regulations of the country to which such information is transferred. In all cases, we will seek to apply reasonable safeguards to protect Personally Identifiable Information and Personal Health Information which we transfer internationally.
Privacy Contact Information
SPLASH CLINICAL LLC
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI 53222
You may also contact our data protection officer, VeraSafe, LLC, using the following contact information:
100 M Street S.E., Suite 600
Washington, D.C. 20003 USA
+1 (617) 398-7067