All Clinical Trials

Last Updated: 11.01.2024

Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the various laws, including the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom), the Personal Information Protection and Electronic Documents Act (PIPEDA) which applies across Canadian provinces and territories, and the California Consumer Privacy Act (CCPA) which applies to residents of the State of California, and we are responsible as “controller” of that personal information for the purposes of those laws.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Curify, Inc. and our affiliates;

Site

Personal information

AllClinicalTrials.com and associated applications

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

Personal Information We Collect About You

Your name and contact information, including your address, email address, telephone number, social security number, drivers license number, and other similar identifiers;
Information to enable us to check and verify your identity, e.g., your date of birth;
Your gender information, if you choose to give this to us;
Location data;
Biometric data;
Your genetic information, including test results which contain genetic information;
Details about your treatment, if any, and side effects;
Details of your medical history and medical condition(s);
Your family history of any related medical condition(s);
Details of clinical trials you have participated in previously;
Your billing information, transaction and payment card information;
Your personal or professional interests;
Your professional or employment-related information;
Your professional online presence, e.g., LinkedIn profile;
Your contact history, purchase history, and saved items;
Information from accounts you link to us, e.g., Facebook;
Information to enable us to undertake credit or other financial checks on you;
Information about how you use our Site, IT, communication and other systems;
Your responses to surveys, competitions, and promotions;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

If you use our Site on behalf of someone else, you must ensure that you have that person’s express consent and authorization to provide us with their personal information.

Our Site is not intended for use by anyone under the age of 16. We do not knowingly collect Personal Information from anyone under the age of 16. If we learn that we have collected Personal Information from someone under the age of 16, by notice given to us or otherwise, we will remove that data from our systems.

Personally Identifiable Information (PII)

We obtain, use, and safeguard your PII information in compliance with applicable laws, We collect information from you to identify and match you with potential clinical trials in your area and to notify relevant clinical trial providers that you have matched in a clinical trial.

The PII we collect is used exclusively for the purpose of matching you with suitable clinical trials. Specifically, we use this information to assess your eligibility for specific clinical trials, communicate with you regarding potential participation in clinical trials, and share relevant information with clinical trial sponsors and investigators, strictly as necessary for the recruitment process.

By using the site and giving us PII through questionnaires, surveys and other forms, you consent to our use of such PII.

The third parties to whom we may disclose PII include, but are not limited to, clinical trial administrators and researchers, regulatory authorities (as required for compliance with applicable laws and regulations), and health care providers involved in the clinical trials.

How Your Personal Information is Collected

We collect most of this personal information directly from you through your use of our Site and applications. However, we may also collect information:

From publicly accessible sources;
From our third party providers;
Directly from a third party that has such information;
From a third party with your consent;
From cookies on our Site.

Why We Use Your Personal Information

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;
To provide the services to you as described in our Terms;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Curify, Inc.	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration, and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Accuracy of Personal Information

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date. You may request corrections to your personal information by contacting us. Where appropriate, we will transmit updated information to third parties who have access to your personal information.

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

contacting us at privacy@curify.us
using the 'unsubscribe' link in emails or 'STOP' number in texts
updating your marketing preferences on our Site

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With

We routinely share personal information with:

Our affiliates, including companies within the Curify group;
Service providers we use to help deliver our services to you, such as clinical trial coordinators and sponsors;
Third parties we use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;
Other third parties we use to help us run our business, e.g., marketing agencies or Site hosts;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

De-Identified and Aggregate Information.

We may use or disclose de-identified information (see above: “Why We Use Your Personal Information”). De-identified information is derived from the personally identifiable information you give to us. Before this information is used or disclosed, we remove certain identifiable information or alter that information so you can no longer be identified based on that information. In order to match you with clinical trials, we provide your profile to clinical trial providers such as pharmaceutical companies, contract research organizations (CROs), and research universities. Where we provide such information, it is in a de-identified format. Our third-party providers use this information to confirm your suitability to participate in clinical trials.

We may also share aggregate information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties for research and/or development purposes. This information is not personal information because it does not identify any particular individual or disclose any particular individual's data. For example, aggregate information may include a statement that &qout;8% of all AllClinicalTrials.com subscribers have diabetes,&qout; without providing any data or testing results specific to any individual user. We will always ask for your consent to share any individual-level information with any third party, other than our service providers as necessary for us to provide the Services to you.

Referrals.

When you provide PII to us, we may manually transfer that data to clinical trial sponsors through the sponsors website or application. We may receive referral fees from some sponsored clinical trials when we successfully match you with a clinical trial based on the information you provide to us. You acknowledge and agree that Curify may manually transfer the data to third party clinical trial sponsors and receive referral fees from such sponsors that you are matched with through your use of our Site.

Where Your Personal Information is Held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal information with”).

Some of these third parties may be based outside the European Economic Area and Canadian territories. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring your personal information out of the EEA”.

How Long Your Personal Information Will Be Kept

We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly;
To keep records required by law.

We will not retain your personal information for longer than necessary. Different retention periods apply for different types of personal information.

Transferring Your Personal Information Out of the EEA and Canadian Territories

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) and Canadian territories, e.g.,:

With our offices outside the EEA and Canadian territories;
With your and our service providers located outside the EEA and Canadian territories;
If you are based outside the EEA or Canadian territories;
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European,UK, and Canadian data protection law. When we transfer your information internationally, we:

Ensure appropriate safeguards are in place
Use approved data transfer mechanisms
Require service providers to maintain equivalent protection levels
Notify you of potential risks associated with foreign processing

If you would like further information please contact us (see 'How to contact us' below).

Your Rights Under the GDPR

Access	The right to be provided with a copy of your personal information (the right of access).
Rectification	The right to require us to correct any mistakes in your personal information.
To be forgotten	The right to require us to delete your personal information—in certain situations.
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

Email, call, or write to us(see below: “How to Contact Us”) and include as much of the following information as possible so we can better assist you with your request:
- Provide enough information to identify you (e.g., your full name, address and customer or matter reference number);
- Provide proof of your identity and address (e.g. a copy of your driver's license or passport and a recent utility or credit card bill);

What right you want to exercise and the information to which your request relates.

Your Rights Under the CCPA

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://www.allclinicaltrials.com/?cky_preview=true
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Your Rights Under the PIPEDA.

Access	The right to be informed of and obtain access to your personal information that we hold, including how we use it and to whom we have disclosed it.
Accuracy	The right to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
Correction	The right to request corrections to your personal information where you can demonstrate that the information is inaccurate or incomplete.
Withdrawal of Consent	The right to withdraw your consent for the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice.
Challenge compliance	The right to challenge our compliance with PIPEDA's principles, including by filing a formal complaint regarding our practices.
Accountability	The right to have your personal information protected by appropriate safeguards and to have us be accountable for such protection.
Data Mobility	The right to receive your personal information in a structured, commonly used format and to have it transmitted to another organization, where technically feasible.

Recourse

The right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) regarding our handling of your personal information.

If you would like to exercise any of those rights, please:

Email, call, or write to us (see below: &qout;How to Contact Us") and provide:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number)
- Proof of your identity and address (e.g., a copy of your driver's license or passport and a recent utility or credit card bill)
- A clear description of the right you wish to exercise and the information to which your request relates

Use of cookies and similar technologies.

Cookies are small text files placed on your computer or other device by websites that you visit. Cookies are widely used in order to make websites and other applications work, or work more efficiently, and help them remember certain information and recognize your internet browser. Cookies may last until you close your browser (“session” cookies) or over repeat visits (“persistent” cookies).

We use cookies and similar technologies to:

Assist you in efficiently and safely navigating and experiencing our services;
Enable you to register, login, provide feedback and otherwise interact with our services;
Store and honor your preferences and settings;
Measure and analyze usage and performance data; and
Assist us with promotional and marketing efforts (including interest-based advertising).

If you access any of our services subject to a subscription agreement or other contract between us and your organization, cookies and similar technologies will be used as necessary for the performance of that contract and for our legitimate business operations related to providing the service.

We use the following types of cookies:

Strictly necessary cookies: These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.
Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
Functionality cookies: These cookies enable the Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies, you will experience less targeted advertising.
Social media cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
Anonymized analytical cookies: These cookies ensure that anonymous data about your surfing behavior is collected every time you visit the Site. This way we can see how visitors use the Site and improve on that basis. We use anonymized analytical cookies for:
- tracking the number of visitors to our web pages;
- tracking the amount of time each visitor spends on our web pages;
- keeping track of the order in which a visitor visits the different pages of our Site;
- assessing which parts of our site need updating;
- measuring and optimizing the performance of our marketing campaigns;
- redirecting traffic from different channels.

Details about the cookies set by our Site(s) and by third parties, including service providers acting on our behalf, are listed directly on the site or in the cookie control tool made available on the site.

How to manage cookies and interest-based advertising.

You can manage the use of certain types of cookies, including targeting cookies used for personalized advertising, also known as interest-based advertising (IBA), by amending your cookies settings in the cookie control tool made available on the site. You also may be able to block or delete cookies by selecting the appropriate settings on your browser privacy preferences menu.

You can also opt out of IBA by turning off targeting cookies used for IBA via the consumer choice tools created under self-regulation programs in many countries, such as the US-based YourAdChoices, the Canada-based AdChoices or the EU-based Your Online Choices. We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Interest-Based Advertising.

Certain content and features in our services depend on cookies to function. For example, authentication cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. If you choose to block cookies, you cannot sign in or use certain content or features. If you choose to delete cookies, any settings and preferences dependent on those cookies will be lost.

Use of web beacons and other technologies.

Some of our Site(s), applications and electronic communications contain electronic tags known as web beacons, gifs or pixel tags, unique identifiers and similar technologies that help deliver cookies, measure online activity, provide more relevant advertising, or analyze the effectiveness of our promotional campaigns or other operations.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

Data Breach Response

In the event of a privacy breach involving personal information, we will:

Contain the breach and conduct a preliminary assessment
Evaluate the risks associated with the breach
Notify affected individuals and the Privacy Commissioner if there is a real risk of significant harm
Implement measures to prevent future breaches

Accountability for Privacy Compliance

We have designated a Privacy Officer who is responsible for our compliance with this privacy policy and applicable privacy laws. Our Privacy Officer can be reached at nazar@curify.us. We maintain a comprehensive privacy management program, including regular staff training, privacy impact assessments for new initiatives, and internal privacy audits.

How to Complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. As for participants residing in Canadian territories and provinces, PIPEDA states that complaints can be filed with the OPC who will determine whether the complaint is covered by PIPEDA, and choose whether to investigate the matter or not. For California residents, complaints filed under the CCPA can be done through the California Privacy Protection Agency's (CPPA) online form or the California Attorney General's reporting tool.

Changes to This Privacy Notice

We may change this privacy notice from time to time–when we do we will inform you by updating the “Last Updated” date at the top of this Privacy Policy.

How to Contact Us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details
548 Market St #39969, San Francisco, California 94104
info@curify.us
+1 (415) 941-0077

Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).