Policy for Protecting Your Online Privacy

Clindox is the EDP system of Clindox Ltd. Our website clindox.com is a business to business site, providing information about our services. The following provisions inform you about the type, scope, and purpose of the collection and use of your personal data. We have separated the information into three sections:

  1. Our website and marketing channels including social media CRM systems and communication channels
  2. The product/service we sell: our EDC system including our App
  3. Your rights and other provisions

Personal data being defined as any information relating to an identified or identifiable natural person. This may include your name and e-mail address.

Our Roles with respect to Data Processing:

  • Clindox is a data controller as an employer and with respect to prospects and clients' business information.
  • Clindox is a processor for its clients and their clients and trial subjects.

If you have any questions in relation to this Privacy Policy, or wish to exercise your rights relating to it, please contact us at dpo@clindox.com

A. WEBSITE, SOCIAL MARKETING AND COMMUNICATIONS CHANNELS

It is generally possible to use our website without providing personal data. You have no obligation to provide personal data. However, the provision of personal data is required, for example, in the case of requesting a demonstration or to contact us via any contact or call back form on this website. If you do not provide us with personal data for the purposes listed below, you may not be able to use the functions of this website or some of its services.

1. PROVIDER AND DATA PROTECTION DETAILS

Provider of this website, clindox.com, and controller in the sense of data protection law is Clindox Ltd, 16/17 College Green, Dublin, Ireland, D02 V0. E-mail: info@clindox.com

You can reach Clindox's data protection officer at: dpo@clindox.com

2. WEBHOSTING

Our website is self-managed. Hosting is with Names.co: Namesco Limited Acton House, Perdiswell Park, Worcester, Worcestershire, WR3 7GD. Data is held on their servers in the UK.

Their privacy policy is available here: https://www.names.co.uk/info/terms/privacy-policy

3. DATA YOU PROVIDE DIRECTLY TO OUR WEBSITE

Webforms: We collect data directly entered via one of the forms on our website. You may choose this method to contact us with regard to requesting a demonstration of our services or asking a question.

Chat: Our website chat function uses Zendesk International Ltd. 55 Charlemont Place, Saint Kevin's, Dublin, D02 F985 Ireland. Their privacy policy is available here: https://www.zendesk.co.uk/company/customers-partners/privacy-policy/

4. DATA PROCESSING COOKIES AND TRACKING

Tracking tools and other services used by us are listed in the following sections. The legal basis for the processing of your data follows from Article 6 paragraph 1 F of the GDPR. Our legitimate interest then consists in improving our site experience and monitoring performance.

The cookies we use are listed in the cookie banner. Our banner gives you the option to select all cookies, or to allow any of preferences, statistical or marketing cookies. The details of the tracking tools used are identified in the following sections.

5. TRACKING TOOLS / OTHER SERVICES

5.1. Google Analytics

Our website uses the tracking tool "Google Analytics". This tracking tool helps us to make the website more interesting for you and to improve the user experience. On our behalf, Google will use the information obtained via Google Analytics to evaluate your use of our website, to compile reports on website activity and to provide us with other services related to website and internet usage.

For more information about Google Analytics, see: https://support.google.com/analytics/answer/2790010?hl=de

5.2. Google Ads and Conversion Tracking

In order to advertise our products and services on external websites with the help of advertising media and to determine the success of our advertising measures, we may use the "Google Ads Conversion" service. You can find more information about data privacy at Google here: https://support.google.com/google-ads/answer/93148 https://ads.google.com/intl/de_de/home/faq/gdpr/

5.3. YouTube

Our website may use plugins from the YouTube site operated by Google. For more information on the handling of user data, please refer to YouTube's privacy policy at: https://www.google.de/intl/de/policies/privacy

5.4. LinkedIn Insight-Tag

On our website we may use the conversion tool "LinkedIn Insight-Tag" of LinkedIn Ireland. This tool creates a cookie in your web browser. For more information about the LinkedIn Insight-Tag, please see the following links.

5.5. Google reCAPTCHA

We use Google reCAPTCHA on our website. For more information about reCAPTCHA and Google's privacy policy, please see the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.

5.6. Google Tag Manager

We may use Google Tag Manager. Through this service from Google, website tags can be managed via an interface.

6. SOCIAL MEDIA PRESENCE

6.1. Links to social networks

Our website contains links to several social networks (Facebook, LinkedIn, and Twitter). These websites are operated exclusively by third parties. If you follow the links, the respective provider may process personal data about you.

7. TELEPHONE AND VIDEO CONFERENCES VIA TEAMS or Zoom or SKYPE

We use the online platforms Microsoft Teams or Skype and Zoom for interactive communication. The respective video-conference provider is responsible for the data processing. When using online meetings, various types of personal data are processed. For further details on data processing for the video-conferencing platforms we use, please refer to the respective privacy policies: Microsoft: https://privacy.microsoft.com/en-gb/privacystatement or Zoom: https://zoom.us/privacy

8. WEBSITE DATA SECURITY

To protect your personal data on this website, we use a secure online transmission procedure, the so-called "Secure Socket Layer" (SSL) transmission. You can recognize this by the fact that a closed padlock symbol is displayed on the address http(s).

9. THIRD PARTY SITES.

Pages within our website and software service may contain links to other websites. We are not responsible for the privacy practices or the content of these other websites.

B. USING OUR PRODUCTS AND SERVICES

10. DATA COLLECTED WHEN USING OUR EDC SERVICES

10.1 SUBJECT DATA

As required during the course of providing EDC services for our clients to conduct and store clinical trial data, we will only collect and store data in accordance with the protocols provided by the data controller(s) of the trial. This data typically involves pseudo-anonymised subject data.

10.2 CLIENT/USER DATA WITH RESPECT TO OUR EDC SERVICES

In order to use the Clindox EDC services, it will be necessary for client data to be held by us for the necessary functioning of a clinical trial.

C. YOUR RIGHTS AND OTHER PROVISIONS

11. YOUR RIGHTS

Data protection law provides you with a number of rights that Clindox is committed to supporting you with:

11.1 Right of Access

You have the right to obtain confirmation that your information is being used, stored or shared by Clindox.

11.2 Right to Object or Withdrawn Consent

You may withdraw your consent at any time.

11.3 Right to Rectification

You are entitled to request that we consider and correct your information if it is incorrect.

11.4 Restriction

You have a right to request that we do not further share the information whilst we process your request.

11.5 Portability

You have a right to request that we send you a copy of the personal data you have provided to us.

12. DATA TRANSFER

Data may also be transferred to recipients based in the USA within the scope of data processing.

13. DURATION FOR WHICH PERSONAL DATA IS STORED / CRITERIA FOR DETERMINING THE DURATION

Your personal data will be stored by Clindox for as long as it is necessary for the aforementioned purposes of processing.

14. NO AUTOMATED INDIVIDUAL DECISION

We do not use your personal data for automated individual decisions.

15. AMENDMENT OF THE PRIVACY POLICY

New legal requirements or technical developments may require changes to our privacy policy. We will adjust the privacy policy on our website as and when required.

Privacy Policy Date: March 2021.