22nd of March 2019
SMART-TRIAL (also referred to as “Company”, “we”, “our” or “us”) is committed to protect and safeguard our visitors’ and users’ personal data and privacy.
This Policy applies to information collected;
- Through the websites https://www.smart-trial.co/, any subdomains of smart-trial.co, and our services (also re-ferred to as “SMART-TRIAL”).
- In e-mail, text and other electronic messages between you and SMART-TRIAL; and
- When you interact with our advertising, third-party websites or services.
By accessing or using our websites and services, you agree to this Policy. If you disagree with this Policy, you should discontinue using our services.
We highly encourage you to visit our website regularly as we might amend the Policy from time to time. Such amendments will be effective upon posting on the website. Your continued use of our services is deemed an acceptance of those changes.
SMART-TRIAL controls the processing of personal data as described in this Policy. Our contact information is:
K. Christensens Vej 2L
9200 Aalborg SV
CVR no. 35 13 97 10
What Information we Collect and How we Collect it
We may collect general and sensitive information, such as:
- Name, address, e-mail, telephone number;
- Credit card and other payment information (such as bank account information);
- Occupation, home country, professional field;
- Information provided by you to us in e-mail, text and other electronic messages; and
- Information about your internet connection, the equipment you use to access our services.
- Geolocation and information obtained from public records searched (“yellow pages” or other publicly available registries etc.)
The information is either; supplied directly by you, automatically or by third parties.
INFORMATION PROVIDED BY YOU
SMART-TRIAL may collect and use all personal information that you choose to share or disclose directly to us.
We will collect your information when you are in touch with our customer service team, or reach out to us through other means (such as social media and advertising).
We will collect records and copies of your correspondence, if you contact us in any way (including mail, e-mail, text or electronic messages on our “Contact Us page”, your response to surveys that we might ask you to complete for research purposes, details of services you request and etc.).
If you have an actual or prospective business relationship with SMART-TRIAL (including actual or prospective customer, vendor, supplier or service provider), you may be required to provide us with additional information such as ID/registration number, bank and account details as well as other financial data considered necessary.
INFORMATION COLLECTED AUTOMATICALLY
We will collect your information automatically as you navigate through our websites and services. This may include your:
- Geolocation and ZIP code, IP-addresses, language settings, hardware, software and internet browser, date and time accessing our services; and
- Age, gender, preferences, click behaviour and other respective data collected through cookies and other tracking technologies.
PERSONAL DATA RECEIVED FROM THIRD PARTIES
We may collect information about you from third parties. These include business partners, public records and other independent third parties.
Anything we may receive from them, may be combined with information provided directly by you.
The technologies we use for automatic data collection may include:
- Device IDs. A device ID (device identification) is a unique device identification associated with a device. It may be possible to limit device ID tracking by adjusting the settings on your device. However, if you limit device ID tracking you may be unable to access our services or certain features offered in our services.
- Cookies. A cookie is a small file placed on your computer or mobile device.
- Web Beacons. Pages of the Website and electronic communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened a message and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). Some web beacons may be disabled by adjusting the settings in your browser or email settings or by installing browser add-ons. However, if you disable web beacons, you may be unable to access our services, the websites, or certain features offered in our services or websites.
- Server Logs. A server log is a log file (or several files) that are automatically created and maintained by a server that track activities performed. Users cannot disable server logs. These server logs are critical for maintaining security and minimise any performance issues of our services.
IP ADRESSES AND COOKIES
We may collect information about your computer including, where available, your IP-address, operating system and browser type for system administration. This is statistical data about our user’s browsing actions and patterns, and does not identify any individual.
SECURITY AND CONFIDENTIALITY
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We have implemented appropriate technical and organizational measures designed to secure your personal information from accidental loss, deletion, unauthorized access, use, alteration and disclosure.
We store your personal information at controlled facilities on computers with limited access.
Only authorized personnel are permitted to access personal data during their work.
We will retain your personal data for as long as we deem it necessary to;
- enable you to use our services,
- provide our services to you,
- comply with applicable law,
- comply with the research procedures,
- resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities
Please review the SMART-TRIAL service and security statement for more information on our service specific security procedures.
WHY DOES SMART-TRIAL COLLECT AND USE YOUR PERSONAL DATA?
SMART-TRIAL collects and uses information for the below mentioned purposes:
- Customer service; sharing and using relevant information (such as account information) when you need our help.
- Services and materials; to protect our materials and content. To operate and deliver the SMART-TRIAL service and other services that you have requested. And to improve, calibrate and customize our products and services;
- Account facilities; to administer your account (including information, products, services & billings).
- Marketing activities; to provide you with materials, products or services that we feel may interest you, where you have consented to be contacted for such purpose.
- Communication with you; there may be situations where we contact you (by e-mail or phone);
- responding to and handling any requests from you,
- to notify you about changes to the Website and services,
- to help us improve, calibrate, customize and optimize our products and services,
- Market research; sometimes we will ask for your assistance regarding;
- historical, statistical or research purposes,
- Legal purposes; we may need your information to carry out our legal and contractual obligations.
- Other purposes; other actions compatible with the abovementioned actions.
It is voluntary to provide information to SMART-TRIAL. However, some services are only possible if you provide us with certain personal data.
LEGAL BASIS FOR COLLECTING AND PROCESSING
The collection and processing is necessary for;
- the performance of a contract,
- the compliance with legal obligations and applicable law (such as lawful law enforcements requests),
Where the collection and processing is not due to the performance or compliance with a contract or legal obligation, we will obtain your prior consent.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you (except all service specific data, such as SMART-TRIAL user and study data) may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EAA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or process.
We will take all the steps reasonably necessary to ensure that the transfer of your data is compliant with data protection laws and this Policy.
DISCLOSURE OF THE INFORMATION
We may disclose your personal information to third parties;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, subject to their entering into appropriate confidentiality undertakings,
- If SMART-TRIAL or substantially all of its assets are acquired by a third-party, in which case personal data held by us about you may be disclosed to the third-party buyer,
You should not provide us with your information if you do not want your information collected, used or disclosed as described in this Policy.
MINIMIZING THE USE OF INFORMATION
We only collect and process personal data that is necessary. Data that is no longer necessary will be deleted or anonymized.
CORRECTING AND DELETING THE INFORMATION
We rely on you to ensure that your personal data is complete, accurate and current. Please inform us promptly if any changes occur.
On your request, we will change, correct and erase any personal data we hold about you. In most cases, you will be able to make such changes yourself. If we realise that the data is no longer correct, we will change it and notify you. Bear in mind, this only relates to the data that you deliver to us.
We will retain your information as long as we deem it necessary unless legal regulation requires otherwise. When the information is no longer necessary, we will delete or anonymize it in such a way that it cannot be linked back to its origin. We have established procedures for erasing and anonymizing personal data.
For any request regarding correction and erasing please e-mail us at: email@example.com.
Your consent is optional and can at any given time be withdrawn by contacting us at the above contact information. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason (other than consent) for doing so;
CHILDREN UNDER THE AGE OF 18
The services offered by SMART-TRIAL are not intended for children under the age of 18 years. We are however dependent on the users own identification and SMART-TRIAL will assume no liability if the user’s age was not stated properly or at all.
If we learn that we have collected or received personal information from a child under the age of 18 without parental or guardian consent, we will delete that information.
You are entitled to;
- know what data we collect and process about you, where they originate from and the purpose for processing,
- know how long we store the data and who receives the data,
- object to particular ways in which we are processing your personal data (you have the right to ask us not to process your personal data for marketing purposes),
- move data that you deliver to us to a third party (the right to data portability) or receive your personal information in a structured, commonly used and machine-readable format, where this is technically feasible. Please note that this right only applies to personal information which you have provided to us;
- access and inspect information held about you
You can exercise your right at any time by contacting us.
In some cases, we will have an obligation to delete your personal data, for example if you withdraw your consent, and we do not have any other legal ground for processing. Please note, that this only applies to the data that you deliver to us.
If you are a subject or participant in a SMART-TRIAL study/project then you will have to contact the study owner to exercise your rights on data correction, deletion and other information.
If you believe your data is no longer necessary for the purpose of processing you can demand them to be deleted. You can also contact us if you believe your personal data is being processed in violation with current legislation.
We will delete your personal information when it is no longer necessary for the purpose that it was collected for.
If you believe that, we have violated current GDPR legislation you are entitled to submit a complaint to “Datatilsynet”, Borgergade 28, 5. Sal, 1300 København K, tlf.: 33193200 or pr. e-mail: firstname.lastname@example.org.