myClin privacy policy

introduction

myClin ("myClin," "we," or "us") collects personal information from you and enables you to collect personal information about your patients online. Protection of personally identifiable information is a cornerstone around which our service can be offered and as such, it is essential that we ensure the highest level of security and privacy for the personal information we collect. We have established a comprehensive privacy program, including this policy and the designation of a global privacy officer, to ensure we respect and protect your data privacy rights when you visit our site and use our online Service. This Privacy Policy is applicable only to this Site, and not to any other websites that you may be able to access from this Site or any website of myClin's partners, each of which may have data collection, storage, and use practices that differ materially from this Privacy Policy. By using or accessing the Service, you agree to the terms of this Privacy Policy.

personal information we collect

The collection of your personal information online is designed to protect access to your account, to establish and maintain an audit trail on transactions and to assist us in providing you with the products and services you need. The minimum personal information we require for an account that allows you to set up your own password and create online patient records is your name and your email address. We will also collect company affiliation, role, telephone number, physical address and other similar information when it is voluntarily submitted to us, for example when you register as a member of an investigator site. We will use your information to respond to requests you make of us, and from time to time, we may refer to your information to contact you and to learn how we can improve our Site and our Service. If your account requires the payment of a fee, a valid credit card number, billing address, or other payment information may be required. myClin does not disclose your credit card information. When you pay by credit card, we submit the information needed to obtain payment to the appropriate clearinghouse.

After you register with myClin, you may create your own profile. If you do so, you acknowledge any information entered into your profile, including contact information, are displayed to other customers in the myClin community at large (see section on communities below). You may voluntarily transmit information to other myClin customers in the myClin community and in other communities by sending messages, participating in online forums, by posting blogs or using other Site collaboration features.

how we share your personal information

We share your information with third parties only in limited circumstances where we believe such sharing is reasonably necessary to offer the Service, legally required or, permitted by you. For example: We may provide information to service providers who help us to bring you the Service, such as hosting the service at a co-location facility, sending email updates about myClin, processing payments, or to provide search results or links. In connection with these business operations, our service providers may have access to your information for use for a limited time and shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy. We may be required to disclose customer information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we may share account or other information when we believe it is necessary to comply with the law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the myClin name, or to prevent imminent harm. This may include sharing information with other companies, lawyers, agents or government agencies. We may offer to provide service jointly with other companies on this Site, and we may share customer information with that company in connection with your use of that service. If the ownership of all or substantially all of the myClin business, or individual business units owned by myClin Clinical Research, LLC, were to change, your customer information may be transferred to the new owner so the Service can continue operations. In any such transfer of information, our customer information would remain subject to this Privacy Policy.

patient data

A primary activity myClin customers carry out on this Site is the creation of electronic patient records. To make these records useful to the investigator site on an ongoing basis, personally identifiable patient information, including "sensitive personal information" (information as defined by the EU Safe Harbor that "reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union memberships or that concerns an individual's health") may be entered in online forms. Physicians, their employees and their agents should be particularly aware of their obligations of patient confidentiality prior to entering the personal information of their patients on this Site, including without limitation their obligations under the Health Insurance Portability and Accountability Act ("HIPAA") and EU Safe Harbor Principles, both in communicating with myClin and in creating patient records on the Site. myClin does not have, and will not accept, any obligations of confidentiality with respect to any communications other than those expressly stated in this Privacy Policy and the myClin Terms of Service.

communities

myClin provides online communities as part of the Service. The myClin community at large ("myClin Community"), comprises all customers registered to use the Service. Investigator sites are private communities ("mySite Community") with one user acting as administrator. Access to information in a mySite Community, including the ability to create, update and view electronic patient records is strictly limited to those with permission as determined by the administrator. mySite Community access requires sign-in, is protected by password and all transactions carried out on patient records are documented by an electronic audit trail. Study communities ("Study Community") are private communities controlled by the sponsor of a clinical trial (drug company, clinical research organization, primary investigator, or other entity). Information that you may share in a message, post or blog in the online community areas of the Site is intentionally open only to other members of that community. There are no communities open to the general public. Each community has a specific purpose and protections and each requires sign-in and entry of a valid password to be accessed.

traffic data we collect

We automatically track and collect the following categories of information when you visit the public areas of our Site: 1) IP addresses, 2) domain servers, 3) types of computers accessing the Site, 4) types of web browsers used to access the Site, 5) referring source which may have sent you to the Site and 6) other information associated with the interaction of your browser and the site.

web beacons and cookies

The public areas of the myClin Site may use a tracking feature known as "web beacons" to collect anonymous, non-personal information about your use of our Site. This tracking feature allows myClin to monitor the date and time our Site is accessed, the pages you visited, the website you came from, the browser type and operating system you are using, and the domain name and address of your Internet Service Provider. We may include web beacons in promotional email messages in order to determine whether messages have been opened. We use session ID "cookies" to confirm that you are signed in and to ensure your session is terminated after a defined period of non-use. A cookie is a piece of data stored on the user's computer tied to information about the user. We do not use cookies to store your password and as such it must be entered each time you sign-in to use the Service.

IP addresses

This site uses Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet and is therefore "dynamic." Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP address does not change and is therefore "static". In this case, your IP address could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve our Site and Service.

changing or removing information

You may correct, amend or delete inaccurate personal information, except where the rights of persons or organizations other than yourself would be violated. For example, you may delete your public profile; however, you may not delete your account in its entirety if you have carried out transactions on behalf of a company or an organization. Information that has been removed may persist in backup copies but will not be available to other customers. Where you make use of the collaboration features of the Service to share information with other customers, you cannot remove such communications from the Site.

security

Areas of this Site that collect personal information use industry standard secure socket layer encryption (SSL); however, to take advantage of this, your browser must support encryption protection (found in Internet Explorer release 3.0 and above). Your account information is located on a secured server behind a firewall. myClin takes reasonable steps to protect information from loss, misuse and unauthorized access, disclosure, alteration and destruction and has put in place appropriate physical, electronic and managerial processes to safeguard and secure the information. Because email and instant messaging are not secure communications, we cannot guarantee the security of any private information sent to us by email or instant messaging services.

minors

You should be aware that this Site and Service are not intended for, nor designed to attract, individuals under the age of 18. If you are under the age of 18, please do not attempt to register for a myClin account. We do not knowingly accept personally identifiable information from anyone under the age of 18.

links

This Site may contain links to other websites. myClin has no control over and is not responsible for the privacy policies or content of such sites.

third party advertising

Advertisements that may be in the public areas of the Site are sometimes delivered directly to customers by third party advertisers. They automatically receive your IP address when this happens. These third party advertisers may also download cookies to your computer, or use other technologies such as JavaScript and "web beacons" to measure the effectiveness of their ads and to personalize advertising content. Doing this allows the advertising network to recognize your computer each time they send you an advertisement in order to measure its effectiveness or to personalize content. In this way, advertisers may compile information about where individuals using your computer or browser saw their advertisements and determine which ones are clicked. myClin does not have access to, or control of, the cookies that may be placed by third party advertisers. Third party advertisers do not have access to your contact information stored on myClin unless you choose to share it with them. myClin does not allow third party advertising in any private areas of the Site.

U.S. - EU Safe Harbor

For personal information of employees, consumers, healthcare professionals, medical research subjects and investigators, customers, investors, government officials and others that myClin receives from the European Economic Area, we are committed to handling such personal information in accordance with the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles"). If there is any conflict between the policies in this Privacy Policy and the Principles, the Principles shall govern.

Notice. When we collect your personal information, we will give you timely and appropriate notice describing what personal information we are collecting, how we will use it and the types of third parties with whom we may share it.

Choice. We will give you choices about the ways we use and share your personal information and we will respect the choices you make.

Relevance. We will collect only as much personal information as we need for specific, identified purposes, and we will not use it for other purposes without obtaining your consent.

Retention. We will keep your personal information only as long as we need it for the purposes for which we collected it, or as permitted by law.

Accuracy. We will take appropriate steps to make sure the personal information in our records is accurate.

Access. We will provide ways for you to access your personal information, as required by law, so you can correct inaccuracies.

Security. We will take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

Sharing. Except as described in this policy, we will not share your personal information with third parties without your consent.

International Transfer. If we transfer your personal information to another country, we will take appropriate measures to protect your privacy and the personal information we transfer.

Enforcement. We will regularly review how we are meeting these privacy promises, and we will provide an independent way to resolve complaints about our privacy practices.

myClin's Safe Harbor certification can be found at www.export.gov/safehrbr/list.aspx. For more information about the Principles, please visit the U.S. Department of Commerce website at www.export.gov/safeharbor/.

Questions, comments or complaints regarding myClin's Safe Harbor policy or data collection and processing practices can be directed to: Privacy Officer, myClin, Attn: Mr. James M. Denmark phone: +1 215 717 7361, email: james.denmark@myclin.com

If your inquiry is not satisfactorily addressed after contacting the myClin Privacy Officer, you may contact the International Centre for Dispute Resolution of the American Arbitration Association at www.adr.org. This organization will serve as liaison with myClin to resolve your concerns.

privacy policy changes

This Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will notify you via email of any significant changes to this policy and will post all revisions to this Site.