Privacy Policy

Privacy Policy

We take the privacy of our website users and the security of their personal information very seriously. The purpose of this Privacy Policy is to set out the principles governing our use of the personal data which you submit to us, or we obtain about you, via our website.

 

Table of Contents

1. Who we are?
2. What data we collect?
3. Uses and Disclosure of information collected.
4. Your Rights regarding your Information and accessing and correcting your information.
5. Retention of Your Personal Data
6. How we Protect Your Personal Data
7. Children and Adolescents
8. How to contact Us?
9. Updates to our Privacy Policy

 

1. Who we are?

The Health Panel is owned and maintained by Patiro ApS (hereafter named Patiro). The references within this Privacy Policy related to “us”, “we” or “our” is related to Patiro ApS, Tagholm 21, 9400 Nørresundby, Denmark.

We assist pharmaceutical companies, medical device companies, sponsors and CROs with recruitment of individuals to participate in clinical trials, which may include production of patient-facing websites (“Recruitment Websites”) which collect and house data from individuals (“Patients”) who may become patients at a particular investigator site.

Since we process your Personal Data, Patiro acts, according to the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) as a data controller, which means that we are responsible for the safe handling of your Personal Data. This does not only apply for the EU, but we also handle your data safely and with great care within the USA, UK and Canada.

 

2. What Data we collect?

When You sign up to Health Panel, You go through a process where we directly collect information about You. When You visit our website or contact us or we contact You, we collect personal information that You provide voluntarily. Most of our Recruitment Websites contain a Pre-Screening Questionnaire (PSQ) where we collect personal information when You answer questions on the website, or we may collect personal information when we contact You by telephone or email. During Pre-Screening, we only collect personal information that is limited and necessary to evaluate Your eligibility and qualifications for participation in our Sponsor’s current Study.

 

• Personal data

On this Website, we may collect and process Your Personal Data. In the provision of our services, We process Personal Data on behalf of our Sponsor(s). Personal Data means any information relating to an identified or identifiable natural person (data subject).

Personal Data includes direct and indirect identifiers such as:

• Name
• E-mail address
• Phone number
• Address
• IP address
• Identification Number
• Location Data (e.g. zip or postal codes)
• On-line Identifier
• Sensitive Data that may include one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social identity of a natural person.

 

• Sensitive Data

In the provision of our services, we may process Sensitive Data on behalf of our Sponsor(s). Sensitive Data is a special category of Personal Data that requires additional privacy and security protections. The collection of Sensitive Data is done at the direction of our Sponsor(s) and is limited to specific and necessary Sensitive Data of potential clinical trial participants needed to determine eligibility for specific clinical trials or for potential Patients needed to determine appropriateness for a given medical practice.

Sensitive personal information that may be collected includes:

• Medical conditions
• Severity of condition
• Medical test results
• Age
• Height & Weight
• Lifestyle/habits (e.g. exercise, smoking)
• Prior medical procedures
• Medical symptoms
• Ethnicity
• Existing participation status or willingness to participate in a clinical trial
• Choice of physician or medical clinic
• Requested or actual appointment date and time

Our Pre-Screening webpages require express consent of potentially eligible participants (e.g., website check box, participant voluntarily clicking ‘Submit’ button) before collection of any Personal Data that will be linked to any Sensitive Data (thereby making it identifiable).

 

3. Uses and Disclosures of information collected.

We use and disclose Personal Data (including Sensitive Data) for a variety of purposes that are limited and necessary to the operation of our business and the delivery of services to You. These purposes include to.

• To contact you via phone to verify your Personal Data, and to ask you for your verbal consent to pass on your information to scientific institutions with ongoing research projects (private and public institutions). These research projects are always approved by respective Ethic Boards, responsible for the evaluation of clinical studies: the Research Ethic Committees (REC) within the EU, USA's Institutional Review Boards (IRB), Health Canada's Research Ethics Board (REB), and UK’s Medicines and Healthcare products Regulatory Agency (MHRA).
• The scientific institution(s) will contact you regarding health-related questions and participation in research projects - e.g., answering a questionnaire, participating in an interview or try a newly developed medicinal product.
• Provide information to You to help You determine whether our services may be of benefit to You.
• Reply to Your requests, inquiries and comments.
• Develop and improve our services.
• Respond to circumstances permitted or required by law, including defending and bringing legal actions.
• We may disclose information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Ensure the security and integrity of our websites and operations.
• Processing of Data may take place in countries other than Your home country. Such transfer will always be made according to current data legislation to ensure that Your information is appropriately protected while in transit and while in the destination country. We will take all reasonable measures to ensure that your Personal Data is protected when transferred to a country outside EU/EEA

We may disclose personal information collected through this website to affiliated third party service providers, such as IT support services, customer service providers, and other services providers that support us and facilitate the services we provide to You. These companies are authorized to use Your Personal Data only as necessary to provide these services to us.

 

4. Your Rights regarding your Information and accessing and correcting your information.

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

• Access and Update- You can review and change your Personal Data by contacting us directly at info@health-panel.com. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

• Restriction- You have the right to restrict our processing of your Personal Data under certain circumstances. You can request, we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.

• Withdrawal of Consent- Your Personal Data is stored until you withdraw your consent by contacting us to delete all your Personal Data, unless we are required by law to keep your data for longer. If you want us to delete this Personal Data, you can contact us by email, post or phone (see contact details below). In this case, your data will be deleted within 24 hours after reception and you will receive an e-mail, informing that your Personal Data has been deleted permanently from our systems.
• Complaints- You have the right to lodge a complaint with a supervisory authority. Patiro stores and processes the data compliant with the General Data Protection Regulation (GDPR) – Regulation 2016/679 within Europe, USA: Health Insurance Portability and Accountability Act (HIPAA), Canada: Personal Information Protection and Electronic   Documents Act (PIPEDA), and UK: The Data Protection Act 2018.

• Right to be Forgotten- You have the right to request that we delete all your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups.

• How you may Exercise your Rights- You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

 

5. Retention of Your Personal Data

We retain Your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

If you have not made any alterations within your health profile within the last 5 years, you will be notified 14 days prior to planned deletion, informing that we are going to delete your profile due to inactivity. If you wish to keep your profile, the e-mail must be answered, stating that you want to keep the health profile. In case of deletion, you will receive an email, informing that your Personal Data has been deleted. If you change your mind, you are always welcome to establish a new health profile.

We reserve the right to compile and use the Personal Data collected as described above, in a de-identified or anonymized format, i.e. no longer personally identifiable as defined by data privacy regulations, for data aggregation and data analytics purposes.

 

6. How we Protect Your Personal Data

Your Personal Data is not only protected by our quality, commitment and high standards. It is also protected by law. Patiro is compliant with-: EU: General Data Protection (GDPR) ; USA: Health Insurance Portability and Accountability Act (HIPAA); Canada: Personal Information Protection; Electronic Document Act (PIPEDA) and  UK: The Data Protection Act 2018.

We employ a series of physical, technical, and administrative security safeguards to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration of data.

 

7. Children and Adolescents

If the clinical study involves minors (age below 18 years), the parent(s), caretaker(s)or legal guardian are required to give consent allowing them to participate in the recruitment process. When answering the questionnaire, it is possible to fill in the contact information and health related state on behalf of the minor. Should the minor match for a current study, the contact to the minor is handled through the parent, caretaker or legal guardian.

 

8. How to contact Us?

If you have any questions, you can always contact us directly at info@health-panel.com  or +45 89 87 82 17 and we will answer all your questions regarding the handling of your personal data.

 

9. Updates to our Privacy Policy

Our Privacy Policy may change over time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a notice regarding this, by either adding a notice on the Health Panel webpage or by sending you an e-mail notification. We encourage you to stay informed and read our Privacy Policy when you use the Health Panel in order to be informed about our information practices and how we protect your privacy.

If you do not agree with the changes to the Privacy Policy please stop using the Health Panel and use the contact details above to withdraw your consent.

 

10. Uses of Cookies

More information regarding how we use cookies, please see our Cookies