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Spectrum Prescreening
Privacy Policy

Spectrum Prescreening
Privacy Policy

Last updated: 10 November 2023

Spectrum Science Communications, Inc. (“Company”, “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for the website prescreening questionnaire (the “Web Screener”) and our telephone prescreening process (the “Phone Screener”) (collectively, the “Screeners”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions. This Privacy Policy does not apply to personal information that we collect through our Spectrum Science website located at https://spectrumscience.com or personal information that we may collect through other means. For more information about how we process other personal information we collect, including on our website, please see our Spectrum Science Privacy Policy.

We collect and process information through the Screeners as a “business” or “controller” (as those terms are defined under applicable data protection laws) on behalf of ourselves and/or our clients and business partners, who may be “businesses”, “third parties”, “service providers”, “independent controllers”, or “processors” (as those terms are defined under applicable data protection laws) . We control the use of the information we collect from you through the Screeners and determine the purposes for which we process such information.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws. The information that we collect directly from you is collected and processed for the purpose of running a clinical trial that is conducted in accordance with the Federal Policy for the Protection of Human Subjects, and pursuant to good clinical practice guidelines issued by the human subject protection requirements of the United States Food and Drug Administration.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact info@spectrumscience.com or use the following:

Spectrum Science
2001 Pennsylvania Avenue NW, Second Floor
Washington, DC 20006
Phone: (202) 955-6222

BY PARTICIPATING IN THE SCREENERS, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT PARTICIPATE IN THE SCREENERS OR PROVIDE US WITH ANY PERSONAL INFORMATION.

The following links will take you directly to the corresponding sections of this Privacy Policy:

PERSONAL INFORMATION WE COLLECT FROM YOU

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been de-identified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.

The following are the categories and types of personal information that we may collect from or about you through the Screeners:

  • Identifiers, such as your name, email address, postal address, and phone number;
  • Characteristics, such as your age (including date of birth or age range), and your height and weight;
  • Information that you voluntarily provide us about your health status, mental or physical health conditions and diagnoses, and personal histories relating to health conditions, medication and drug use, medical providers, and participation in clinical trials;
  • Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
  • Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement;
  • Any other personal information that you voluntarily provide us.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information that you provide to us directly through the Screeners or when you otherwise contact us.

When you participate in the Web Screener, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

  • Cookies and Similar Technology
    “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, type of browser you are using, your Internet Protocol (IP) address, what pages you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Web Screener.
  • Analytics
    We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Web Screener. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Web Screener. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Web Screener, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Web Screener and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

We do not permit Google or any other third-party analytics vendors to collect or identify your responses to the Screeners.

  • From Other Sources
    We may obtain information about you from other sources, such as data analytics providers, fraud prevention vendors, marketing or advertising vendors, vendors that provide other business services on our behalf, or publicly available sources.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

  • To communicate with you, which may include: following up with you regarding your participation in the Screeners; and responding to your direct inquiries, requests, issues, or feedback, and providing customer service;
  • To provide our services, which may include: operating and administering the Screeners;
  • For analytics, which may include: conducting research and analytics to improve our Screeners; and better understanding our screener participants’ needs;
  • For security and fraud prevention, which may include: helping maintain the safety, security, and integrity of our properties, databases and other technology assets, and business; internal research; technological development and demonstration; and improving, upgrading, or enhancing our services; detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity; and investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Screeners;
  • To comply with legal obligations, which may include: compliance with legal or regulatory obligations, establishing or exercising our rights, and defending against a legal claim; responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation; and acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;
  • To support core business functions, which may include: maintaining records related to business process management, loss, and fraud prevention, and to collect amounts owing to us; and providing and maintaining the functionality of our Screeners, including identifying and repairing errors or problems; and
  • For any additional purposes that you specifically consent to.

Additionally, we or our service providers may use your personal information to contact emergency medical services in the event that we believe you are experiencing a medical emergency. If you believe you are experiencing a life or safety risk, medical issue, or other emergency event, you should immediately contact your medical provider, or if appropriate, contact the police, fire department, 911, or other emergency response service.

We reserve the right to supplement your personal information with information we gather from other sources which may include online and offline sources. We may collect information that is not personal information (“non-personal information”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal information, and such aggregate data will be treated as non-personal information.

HOW WE DISCLOSE OR SHARE YOUR PERSONAL INFORMATION

In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:

  • Business Partners
    We may share your personal information with our business partners where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
  • Service Providers
    We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, payment processing, auditing, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
  • Corporate Affiliates
    We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
  • Legal Compliance and to Defend Our Rights
    We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • Business Transfers
    We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the participants of our Screeners.
  • Non-Personal Information
    We may share non-personal information with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Screeners, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at Helpdesk@SpectrumScience.com.

DATA RETENTION

We will retain your personal information: for as long as is needed to facilitate and complete the Screeners, and for a reasonable time thereafter in accordance with our standard procedures; for as long as your inquiry is active, if you have contacted us; or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

OPTING OUT OF COOKIES

If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Web Screener or some of its functionality may be affected.

Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

CROSS-BORDER DATA TRANSFERS

If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement.

CHILDREN’S PRIVACY

Our Screeners are intended for users ages 18 and over, and we do not knowingly collect personal information from children under the age of 18. For children under the age of 18, we require a parent or legal guardian to answer screening questions for the child and act as the child’s point of contact. In doing so, we collect the parent’s or guardian’s contact information in accordance with this Privacy Policy.

When we become aware that personal information (or other information that is protected under applicable law) has been collected from a child under the age of 18, and not from a parent or guardian, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information collected from a child under 18, please contact us by using the information section below titled Contacting Us.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively.

CONTACTING US

If you have any questions about our privacy or security practices, you can contact info@spectrumscience.com or via the following:

Spectrum Science
2001 Pennsylvania Avenue NW, Second Floor
Washington, DC 20006
Phone: (202) 955-6222