Reify Health, Inc.
Attn: Privacy Officer
745 Atlantic Avenue
Boston, MA 02111
Reify Health, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Reify Health, Inc is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List (https://www.privacyshield.gov/list).
Reify Health, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Reify Health, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Reify Health, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Reify Health, Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
What Types of Personal Information Does Reify Gather?
Services may include programs such as StudyTeam in which users with access to Restricted Areas of Reify’s Sites (each, a “Registered User”) communicate information about clinical research needs and capabilities and monitor and manage the performance of clinical research activities. Reify may collect any information provided or input by you or authorized by you to be provided by a third party in connection with any Site or Service, which information may include, but is not limited to, your name, email and physical address, and telephone number and the name, medical record number, email and physical address, and telephone number of a patient. We collect information from you when you use Sites or Services, when you fill out a form, upload information, create or use an account, or otherwise supply information to us. When you send email or other communications to us, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve our services.
Privacy and Cookies Policy
We may also automatically collect information regarding your interaction with, and use of, any Site or Service. We may use a variety of methods to collect this information, including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools (“Automatic Data Collection Tools”) to administer the Sites and Services, inform user support efforts, and analyze user trends to inform improvements to the Sites and Services user trends to support. These Automatic Data Collection Tools collect certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and click-stream behavior. You may have the ability, through your Internet browser settings, to receive notices regarding, or turn off, certain Automatic Data Collection Tools; however, please note that turning off Automatic Data Collection Tools may negatively impact the functionality or performance of the Sites and Services.
Information may be collected by us or by our vendors who provide internet hosting for the Sites or Services. We may combine information you give us with other information from Reify sources, transactions and communications. We may also combine that information with data from third parties, such as the name of your site or your site’s preferred business phone number from your website. This helps us to update, expand, and analyze our records and engage you about new products, services, and features that are most relevant to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or from third parties and combined with information we already have about you, may include:
In the event that the User decides to disable all cookies, the quality and speed of the service could diminish, and user may lose access to some of the services or features available on the Site.
Basis for Processing
Your Personal Information will be processed by Reify on the basis of a lawful “justification” for such processing, to the extent required by or permissible under applicable law.
In the majority of cases, the processing of your Personal information will be justified on one of the following bases:
How Does Reify Use Your Personal Information?
Facilitate Your Use of the Sites and Services. We may use your Personal Information to communicate with you regarding the Sites or Services, your account information or other customer service matters; to respond to your questions and instructions; and, with your prior consent, to enhance, customize, and personalize your experiences and communications with us.
Operate and Improve the Sites and Services. We may use your Personal Information to operate, provide, improve, and maintain the Sites and Services, including analyzing User behavior and trends to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users; to send you administrative messages and other information about Reify and the Sites and Services, including critical updates and notifications; to investigate or take action regarding violations or suspected violations of applicable law or our Terms of Service; and to maintain the integrity of the Sites and Services and our network and address security issues.
Marketing and Promotion Purposes. With your prior consent, we may use your Personal Information to communicate with you about the Sites and Services and other related products and services; and display relevant marketing to you. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in the marketing emails we send to you.
Special Circumstances. We may also access, use, copy or disclose Personal Information in the event of any Special Circumstances (as described below).
Aggregated Data. Information collected from any source may be combined to create aggregated data (“Aggregated Data”) to provide or improve the Sites and Services and facilitate a more targeted, tailored user experience. Reify may use Aggregated Data for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes.
With Whom Does Reify Share Your Personal Information?
With your prior consent, we may provide your Personal Information to our subsidiaries and affiliates (which today includes and is limited to Reify Health, Inc., and herein is called the “Reify Companies”). Unless not permitted by applicable law, all companies within the Reify Companies may share Personal Information collected through any Site or Service and may contact you directly.
We do not sell, trade, or otherwise transfer to third parties your Personal Information unless we provide you with advance notice and obtain your prior consent, except as described herein. The term "outside parties" does not include Reify Companies, our website hosting partners, and other parties who assist us with the administration of the Sites or Services, conducting our business, or servicing you, so long as those parties agree to maintain reasonable security measures to safeguard the confidentiality, security, and integrity of your Personal Information. Outside parties may have access to Personal Information as reasonably necessary to perform their functions.
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
These services may include:
We may disclose Personal Information when we believe disclosure is appropriate to comply with applicable law by public authorities, including to meet national security or law enforcement requirements; comply with a subpoena or other legal process;
Access and Choice
Upon request Reify will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
We may store and use your Personal Information for as long as you continue to access or use any Site or Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Reify Health may retain your Personal Information for the purposes of audits and review in the course of providing the Services and for the substantiation of other data in the system.
In the event your Personal Information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Furthermore, you have the right to lodge complaints relating to the processing of your Personal Information with your relevant data protection supervisory authority.
Information security is important to Reify. We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use your Personal Information. In particular, we have obtained the Privacy Shield certification which implies that Reify commits to comply with the Framework’s requirements that can be accessed here. However, like other companies, Reify cannot guarantee the 100% security or confidentiality of your Personal Information. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we cannot warrant or guarantee the absolute security of any Personal Information you transmit to, from or through any Site or Service. In the event that we become aware of a security breach involving your Personal Information stored by or for us, we may notify you by posting details of the breach to the applicable Site or Service or via email, to the extent available in connection with such Site or Service. We will provide you with a copy of our StudyTeam Security Overview upon request. You should be aware that Reify has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third party site appears on any Site or Service. In addition, Reify does not control or continuously monitor the activities of users of any Site or Service, and such users may have the ability to provide, access, use and/or disclose data and information, such as your Personal Information, in connection with the Sites and Services.
Please note that some of the content we deliver to or receive from you through the Sites and Services, specifically that of emails and text messages, is unencrypted. And so, transmissions may be unknowingly or unintentionally intercepted by third parties. We do not maintain or have access to your device, phone, e- mail server, or networks outside of our domain and control; therefore, we bear no liability or responsibility for the security or control of content or communications, once delivered to you.
If you have any questions about the security of your personal information, you can contact us at email@example.com.
Platform Data Collection and Practices
Reify collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Upon request Reify will provide you with information about whether we hold any of your personal information. Reify has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Reify’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Reify will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Privacy Policies
Notice to Residents of the State of California in the United States of America
The privacy of children is important to Reify. The Sites and Services are not directed at children, and we do not knowingly collect Personal Information from children under the age of 16 through the Sites and Services. Children under the age of 16 may not access, use or submit any Personal Information through any Site or Service.
By using any Site or Service, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to Reify will be treated as if provided by an adult. If a child has provided us with Personal Information, a parent or guardian of that child may send an e-mail to firstname.lastname@example.org with "Request for Child Information Removal" on the subject line and the name and age of the child in the body of the message. Upon verification, we will remove the child’s Personal Information from our applicable databases.
Reify Health, Inc.
Attn: Privacy Officer
745 Atlantic Avenue
Boston, MA 02111
Last Modified: 21 March 2018