Effective as of 09-Nov-2020
This “Privacy Policy” describes the privacy practices of Clinical
Ink, Inc (“Clinical Ink”, “we”, “us”, or “our”). This Privacy Policy defines Clinical Ink’s
interpretation of the regulatory requirements related to Personally
Identifiable Information, Personal Health Information, Patient Privacy, the
Health Insurance Portability and Accountability Act (HIPAA), the EU General
Data Protection Regulation (EU GDPR), and the California Consumer Protection
Act (CCPA).
Respect for the privacy of personal information about our
customers and website visitors is very important to Clinical Ink. Clinical Ink
is committed to adhering to this Privacy Policy, as well as applicable laws, rules and regulations. This Privacy Policy applies to
Personal Information (as defined below) collected by Clinical Ink’s online
resources located under the domain name [https://www.clinicalink.com], and
subdomains of clinicalink.com, including all related pages. This Privacy Policy
does not apply to personal information collected from offline resources and
communications. This Privacy Policy also does not apply to third-party online
resources to which this website may link, frame or otherwise reference.
This Privacy Policy describes how we collect, use, disclose
and otherwise process personal information in connection with our websites,
mobile apps, and other services, and explains the rights and choices available
to individuals with respect to their information. For convenience, our websites
and mobile apps are collectively referred to as the “Products”, and, together
with our other services, collectively referred to as the “Services.” This
Privacy Policy governs any of the Services on which the Privacy Policy is
posted.
Individuals located in the European Union please read the
important information provided here.
Individuals located in California please read the important
information provided here.
Summary of our Privacy Practices
The
Types of Information Clinical Ink Collects About You: We collect information
that you provide to us, such as your contact details, as well as information
that is automatically collected by our Products, such as your Internet Protocol
(“IP”) address and information collected by our use of Cookies.
The
Purposes of Processing Your Information: We process information about you to provide our
Products and Services; to communicate with you; to comply with law and prevent fraud;
and for other reasons with your consent. We may also anonymize your data –
which means the data can no longer be used to identify you – to perform
analytics to learn how to better provide our Products and Services.
Your
Rights and Choices:
Depending on your jurisdiction, you may have legal rights associated
with our processing of your data, including rights to access, correct, delete,
transfer, or object to the processing of your data. Regardless of where you
live, we will honor your request to opt out of being contacted by us for
marketing reasons.
How
to Contact Us: Clinical
Ink is the controller of your information when it is processed in the context
of our Products and Services. Our Data Protection Officer may be contacted by
emailing privacy@clinicalink.com.
Please note that Clinical Ink’s customers are the
controllers of your data when it is processed in the Lumenis platform,
applications, and related services. For example, if you are a patient in a
clinical trial, or an investigator who logs into our applications, your data
controller is the Sponsor of that trial and/or the participating healthcare
provider.
Clinical Ink’s Platform, Applications, and Customer Data
As part of Clinical Ink’s platform, applications and
related services, our customer’s employees and authorized users may enter
information from or about their authorized users, employees, and clinical trial
subjects (collectively, “Customer Data”), into our Products.
This Privacy Policy does not apply to Customer Data, and we
are not responsible for our customers’ handling of Customer Data. Our customers
have their own policies regarding the collection, use and disclosure of your
personal information. Our use of Customer Data is subject to the written contract
for services between Clinical Ink and the customer that in no way involves the
sale of your data. Clinical Ink’s responsibility under that contract is the
obligation to keep Customer Data safe and secure.
Clinical Ink has no control or ownership of Customer Data.
Please direct any questions regarding Customer Data to the customer for which
you work, or which collected your information using Lumenis.
The Personal Information We Collect
We collect personal information about you in the following
ways:
Information you give us
Personal information that you may provide through the
Services or otherwise communicate with us includes:
·
Personal and Business Contact information, such
as your first name, last name, postal address, email address, telephone number,
job title, and employer name.
·
Profile information, such as your username and
password and preferences.
·
Feedback and correspondence, such as information
you provide when reporting a problem with the Products, receive customer
support or otherwise correspond with us.
·
Usage information, such as information about how
you use the Products and interact with us.
·
Clinical Ink collects identifying information
when you use the Products (including, without limitation, any clinicalink.com
web pages or landing pages), and when you submit data through a form such as
those found on gated resources and contact pages.
·
Marketing information, such as your preferences
for receiving marketing communications and details about how you engage with those
communications.
We may combine other publicly
available information, such as information related to the organization for
which you work, with the personal information that you provide to us through
our Products or Services.
Information automatically collected
We may collect an Internet
Protocol (“IP”) address from visitors to our Products. We use IP addresses to
help diagnose problems with our server(s), to administer the Products, and to
monitor activities on and interactions with our Products.
We may also automatically log
information about you and your computer or mobile device when you access our Products.
For example, we may log your computer or mobile device operating system name
and version, manufacturer and model, browser type, browser language, screen
resolution, the website you visited before browsing to our Products, pages you
viewed, how long you spent on a page, access times and information about your
use of and actions on our Products.
Changes to your personal information
It is important that the
personal information we hold about you is accurate and current. Please let us
know if your personal information changes during your relationship with us by
updating your Product profile or emailing us at privacy@clinicalink.com.
How We Use Your Personal Information
To provide our Services
If you have a Clinical Ink account or use our Products,
we use your personal information to:
·
Operate, maintain, administer, and improve the
Products.
·
Manage and communicate with you regarding your
Clinical Ink account, if you have one, including by sending you service
announcements, technical notices, updates, security alerts, and support and
administrative messages.
·
Process and manage registrations you make
through the Products, including to track and administer trainings or events you
have registered for and attended.
·
Better understand your needs and interests and
personalize your experience with the Products.
·
Provide support and maintenance for the Products
and our Services.
·
Respond to your service-related requests,
questions, and feedback.
To communicate with you
If you request information from
us, register on the Products, or participate in our events, we may send you Clinical
Ink-related marketing communications as permitted by law. You will have the
ability to opt-out of such communications.
To comply with law
We use your personal information
as we believe necessary or appropriate to comply with applicable laws, lawful
requests, and legal process, such as to respond to subpoenas or requests from
government authorities.
With your consent
We may use or share your
personal information with your consent, you instruct us to take a specific
action with respect to your personal information, or you opt into marketing
communications.
To create anonymous data for analytics
We may create anonymous data
from your personal information and other individuals whose personal information
we collect. We make “personal information” into “anonymous data” by excluding
information that makes the data personally identifiable to you, so that it is
no longer reasonably possible to use the data to identify you. We use this
anonymized data for lawful business purposes, such as improving our Products
and Services.
For compliance, fraud prevention and safety
We use your personal information as necessary or
appropriate to:
a)
Enforce the terms and conditions that govern our
Services.
b)
Protect our rights, privacy, safety
or property, and/or that of you or others.
c)
Protect, investigate
and deter against fraudulent, harmful, unauthorized, unethical or illegal
activity.
How We Share your Personal Information
Except as described in this
Privacy Policy, we do not share the personal information that you provide to us
with other organizations. In cases where Clinical Ink contracts with a
third-party that requires access to personal information that you provided to
us, Clinical Ink will obtain assurances that the third-party will safeguard
Personal Data and Clinical Study Data in a manner consistent with this Policy. Furthermore,
when transferring personal information to a third party acting as an agent,
Clinical Ink will:
·
Transfer such data only for limited and
specified purposes.
·
Ascertain that the agent is obligated to provide
at least the same level of privacy protection.
·
Take reasonable and appropriate steps to ensure
that the agent effectively processes the personal information transferred in a
manner consistent with Clinical Ink’s obligations.
·
Require the agent to notify Clinical Ink if it
decides that it can no longer meet its obligation to provide the same level of
protection.
·
Upon notice, including under (iv), take
reasonable and appropriate steps to stop and remediate unauthorized processing.
Such third-party agents are
restricted from using this data in any way other than providing services for or
on behalf of Clinical Ink. We disclose personal information to third parties
under the following circumstances:
·
Service Providers: We may employ third
party companies and individuals to administer and provide the Services on our
behalf (such as training, shipping, customer support, hosting, email delivery,
and database management services). These third parties may use your information
only as directed by Clinical Ink and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your
information for any other purpose.
·
Professional Advisors: We may disclose
your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional
services that they render to us.
·
Compliance with Laws and Law Enforcement;
Protection and Safety: Clinical Ink may disclose information about you to
government or law enforcement officials or private parties as required by law,
and disclose and use such information as we believe necessary or appropriate to:
a)
Comply with applicable laws and lawful requests
and legal process, such as to respond to subpoenas or requests from government
authorities.
b)
Enforce the terms and conditions that govern our
Services.
c)
Protect our rights, privacy, safety
or property, and/or that of you or others.
d)
Protect, investigate, and deter against
fraudulent, harmful, unauthorized, unethical, or illegal activity.
·
Business Transfers: Clinical Ink may
sell, transfer, or otherwise share some or all of its business or assets,
including your personal information, in connection with a business deal (or
potential business deal) such as a merger, consolidation, acquisition,
reorganization or sale of assets or in the event of bankruptcy, if such third
party agrees to treat all such information in accordance with this Privacy
Policy.
Your Choices
Access, Update, Correct or Delete Your Information
All Clinical Ink account holders
may review, update, correct or delete the personal information in their Product
profile by logging into their account. Clinical Ink account holders may also
contact us at privacy@clinicalink.com
if you have additional requests or questions.
Marketing communications
You may opt out of
marketing-related emails by by clicking on the
‘unsubscribe’ link at the bottom of each such email or by contacting us at privacy@clinicalink.com.
You may continue to receive service-related and other non-marketing emails.
Testimonials
If you gave us consent to post a
testimonial on our Products, but wish to update or delete it, please contact privacy@clinicalink.com.
Choosing not to share your personal information
Where permitted by law, your ability to access and
correct personal information will be limited where access and correction would:
[1]
inhibit Clinical Ink’s ability to comply with a
legal or ethical obligation.
[2]
inhibit Clinical Ink’s ability to investigate,
make or defend legal claims, result in disclosure of personal information about
a third party; or
[3]
result in a breach of a contract or disclosure
of trade secrets or other proprietary business information belonging to
Clinical Ink or a Third-Party.
Where we are required by law to
collect your personal information, or where we need your personal information
in order to provide the Services to you, if you do not provide this information
when requested (or you later ask to delete it), we may not be able to provide
you with the Services and may need to close your account. We will tell you what
information you must provide to receive the Services by designating it as
required in our Products and Services or through other appropriate means.
Cookies and Similar Technologies
What are cookies?
As is common practice with
almost all professional websites this site uses cookies, which are very small
files that are downloaded to your computer, to improve your experience. This
page describes what information they gather, how we use them and why we
sometimes need to store these cookies. We will also share how you can prevent
these cookies from being stored. However,
this may downgrade or ‘break’ certain elements of the Products functionality.
The Cookies We Set
This site also offers newsletter
or email subscription services and cookies may be used to remember if you are
already registered and whether to show certain notifications which might only
be valid to those subscribed.
When you submit data through a
form, such as those found on contact pages or comment forms, cookies may be set
to remember your user details for future correspondence.
Third-Party Cookies
In some special cases we also
use cookies provided by trusted third parties. The following section details
which third-party cookies you might encounter through this site.
Our Products use Google
Analytics which is one of the most widespread and trusted analytics solutions
on the web. We use Google Analytics to help us understand how you use our site
and ways that we can improve your experience. Cookies may track things such as
how long you spend on the site and the pages that you visit so we can continue
to produce engaging content.
For more information on Google
Analytics cookies, see the official Google Analytics page. For more information
about Google Analytics, or to opt-out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout
Disabling cookies
You can typically remove or
reject cookies via your browser settings. To do this, follow the instructions
provided by your browser (usually located within the “settings,” “help” “tools”
or “edit” facility). Many browsers are set to accept cookies until you change
your settings.
Further information about
cookies, including how to see what cookies have been set on your computer or
mobile device and how to manage and delete them, visit www.allaboutcookies.org.
On-Site Tracking
We may also use tracking tags
(which are also known as web beacons) on our Site to track the actions of users
while on our Site. Unlike cookies, which are stored on the hard drive of your
computer or mobile device by a website, tracking tags are embedded on webpages.
Tags compile statistics about usage of the Site, so that we can manage our
content more effectively. The information we collect using tracking tags is not
linked to our users’ personal data.
Security
The security of your personal
information is important to us. Clinical Ink employs reasonable safeguards to
protect Personal Data from loss, misuse, unauthorized access, disclosure,
alteration, and destruction. Clinical
Ink strictly controls access to Clinical Study Data through multiple security
mechanisms and adheres to a Defense-In-Depth approach about data security which
includes the following:
·
environmental monitoring,
·
anti-virus software,
·
network segmentation with multilayer security
access controls,
·
intrusion detection monitoring and alerting,
·
database logging and auditing,
·
multi-factor authenticated VPN,
·
data at rest encryption,
·
transport layer encryption,
·
anonymization of certain data elements.
However, no security safeguards are 100% secure and we
cannot guarantee the security of your information.
International Transfer
Clinical Ink is headquartered in Horsham, Pennsylvania, United
States and has service providers in other countries, and your personal
information may be transferred to the United States or other locations outside
of your state, province, country or other governmental jurisdiction where
privacy laws may not be as protective as those in your jurisdiction.
European Union users should read the important information
provided here about the transfer of personal information
outside of the European Economic Area.
Other Products and Services
The Products may contain links to other websites and
services. These links are not an endorsement, authorization, or representation
that we are affiliated with that third party. We do not exercise control over
third party websites or services and are not responsible for their actions.
Other websites and services follow different rules regarding the use or
disclosure of the personal information you submit to them. We encourage you to
read the privacy policies of the other websites you visit and services you use.
User Generated Content
We may make available on our Products, or link to, features
that allow you to share information online (e.g., on message boards, in chat
areas, in file uploads, through events, etc.). Please be aware that whenever
you voluntarily disclose personal information online, that information becomes
public and can be collected and used by others. We have no control over, and
take no responsibility for, the use, storage, or dissemination of such publicly
disclosed personal information. By posting personal information online in
public forums, you may receive unsolicited messages from other parties.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any
time. Any modifications to this Privacy Policy will be effective upon our
posting of the new terms and/or upon implementation of the new changes in the
Service (or as otherwise indicated at the time of posting). In all cases, your
continued use of the Products and Services after the posting of any modified
Privacy Policy indicates your acceptance of the terms of the modified Privacy
Policy.
Representations / Liability
Clinical Ink makes no representations about the content of
the information found on this website. The information presented on this
website is provided to you “AS IS,” WITHOUT ANY WARRANTY, IMPLIED OR EXPRESSED,
INCLUDING BY WAY OF EXAMPLE BUT WITHOUT LIMITATION, ANY WARRANTY OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR OTHERWISE.
Under no circumstances shall Clinical Ink assume liability
for the use or interpretation by you of information found on this website;
rather, this will be your responsibility.
Clinical Ink expressly disclaims liability for any direct,
indirect, incidental, consequential or special damages
arising out of your visit to this website and/or the information contained on
this website, even if Clinical Ink is proven negligent.
Reservation of Rights
Clinical Ink reserves the right to share Personal Data as
required by law to respond to duly authorized information requests of
government authorities. For such
requests involving Clinical Study Data, Clinical Ink shall provide notice to affected
customers, but shall not necessarily seek permission, before disclosing any
data to regulatory agencies.
Clinical Ink will fully cooperate with all customer
requests to investigate potential violations related to Clinical Study Data and
will do so expeditiously and at no cost to the individual. Individuals, including employees, who feel
that Clinical Ink has violated this Policy in any way, may contact the
designated Data Protection Officer directly to initiate a formal inquiry. Employees found willfully disregarding this
Policy shall be terminated.
Contact Us
If you have any questions or concerns at all about our
Privacy Policy, please feel free to email us at privacy@clinicalink.com,
or write to us at:
Clinical
Ink, Inc.
Attn: Data Protection Officer
110 Gibraltar Road, Suite 150
Horsham, PA 19044
Tel: 1-800-301-5033
Information for European Union Users
Personal information
References to “personal
information” in this Privacy Policy are equivalent to “personal data” governed
by European data protection legislation.
Controller and Data Protection Officer
Clinical Ink, Inc. is the
controller of your personal information for purposes of European data
protection legislation. Our Data Protection Officer can be reached at
privacy@clinicalink.com.
See the “Contact Us” section above for additional contact details.
Legal bases for processing
We only use your personal information as permitted by
law. We are required to inform you of the legal bases of our processing of your
personal information, which are described in the list below. If you have
questions about the legal basis of how we process your personal information,
contact us at privacy@clinicalink.com.
·
With your consent: Processing is based on
your consent. Where we rely on your consent you have the right to withdraw it
anytime in the manner indicated in the Service or by contacting us at privacy@clinicalink.com.
·
To provide the Services: Processing is
necessary to perform the contract governing our provision of the Services or to
take steps that you request prior to signing up for the Services.
·
To communicate with you: To create
anonymous data for analytics; and for compliance, fraud prevention and safety.
These processing activities constitute our legitimate interests. We make sure
we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your personal information for our
legitimate interests. We do not use your personal information for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law).
·
To comply with law: Processing is
necessary to comply with our legal obligations.
Use for new purposes
We may use your personal
information for reasons not described in this Privacy Policy where permitted by
law and the reason is compatible with the purpose for which we collected it. If
we need to use your personal information for an unrelated purpose, we will
notify you and explain the applicable legal basis.
Retention
We will only retain your
personal information for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements.
To determine the appropriate
retention period for personal information, we consider the amount, nature, and
sensitivity of the personal information, the potential risk of harm from
unauthorized use or disclosure of your personal information, the purposes for
which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal requirements.
By law we must keep basic
information about our customers (including Contact, Identity, Financial and
Transaction Information) for seven years after they cease being customers for
financial and tax purposes.
In some circumstances we may
anonymize your personal information (so that it can no longer be associated
with you) in which case we may use this information indefinitely without
further notice to you.
Your Rights
European data protection laws
give you certain rights regarding your personal information. You may ask us to
take the following actions in relation to your personal information that we
hold:
·
Opt-out: Stop sending you direct
marketing communications. You may continue to receive service-related and other
non-marketing emails;
·
Access: Provide you with information
about our processing of your personal information and give you access to your
personal information;
·
Correct: Update or correct inaccuracies
in your personal information;
·
Delete: Delete your personal information;
·
Transfer. Transfer a machine-readable
copy of your personal information to you or a third party of your choice;
·
Restrict: Restrict the processing of your
personal information;
·
Object: Object to our reliance on our
legitimate interests as the basis of our processing of your personal
information that impacts your rights.
You can submit these requests by
email to
privacy@clinicalink.com
or our postal address provided above. We may request specific information from
you to help us confirm your identity and process your request. Applicable law
may require or permit us to decline your request. If we decline your request,
we will tell you why, subject to legal restrictions. If you would like to
submit a complaint about our use of your personal information or response to
your requests regarding your personal information, you may contact us as
described above or submit a complaint to the data protection regulator in your
jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your
personal information out of the EEA to countries not deemed by the European
Commission to provide an adequate level of personal information protection, the
transfer will be based on the following safeguard recognized by the European
Commission as providing adequate protection for personal information, where
required by EU data protection legislation:
Contracts approved by the
European Commission which impose data protection obligations on the parties to
the transfer. For further details, see European Commission Model contracts for
the transfer of personal information to third countries.
Please contact us if you want
further information on the mechanism used by us when transferring your personal
information out of the EEA.
EU-US Privacy Shield &
Swiss-US Privacy Shield
On July 16, 2020, the Court of
Justice of the European Union issued a decision in a case called Data
Protection Commissioner v Facebook Ireland Ltd and Maximillian Schrems (“Schrems
II”). In Schrems
II, the court invalidated the EU-US Privacy Shield Framework as a
mechanism to satisfy the requirements of the General Data Protection Regulation
(GDPR) regarding transfers of personal data from the EU to the U.S.
Clinical Ink’s standard Data
Processing Addendum (DPA) incorporates the Standard Contractual Clauses (SCCs)
for any transfers of personal data from within the EU to the U.S. that occur in
connection with Clinical Ink’s performance of its Products and Services. By executing its DPA and the SCCs, Clinical
Ink becomes legally obligated to comply with the relevant requirements of GDPR
that apply to Clinical Ink’s performance of its services. To that end, Clinical
Ink maintains robust internal policies and procedures to ensure data security,
integrity, and data privacy.
Additional Information for California Users
California Privacy Notice
We are providing this
supplemental privacy notice to California users pursuant to the California
Consumer Privacy Act of 2018 (“CCPA”).
The provisions contained in this
section apply to all Users who are persons residing in the state of California,
United States of America, according to "The California Consumer Privacy
Act of 2018" (persons are referred to below, simply as “you”, “your”,
“yours”), and, for such consumers, these provisions supersede any other
possibly divergent or conflicting provisions contained in the privacy policy.
This part of the Privacy Policy
uses the term “personal information” as it is defined in The California
Consumer Privacy Act (CCPA).
Categories of personal information collected
This section summarizes the
categories of personal information that Clinical Ink collects and the purposes
thereof.
As part of its services provided
to clients, Clinical Ink may collect the following categories of personal
information about identifiers, commercial information, internet information.
We will not collect additional
categories of personal information without notifying you.
How personal information is collected
We collect the above-mentioned
categories of personal information, either directly or indirectly, from you
when you or your employer use the services provided by Clinical Ink.
As outlined in this policy,
Clinical Ink is a provider of software and services to life sciences companies
for use in the conduct of clinical trials throughout the world. Acting as a
third-party agent for our clients, for each clinical project Clinical Ink
receives Personal Data (name, email, work address, title, and phone number)
from study sponsors, research site staff, various consultants/subcontractors,
and employees.
Additionally, as specifically
authorized by our customers, Clinical Ink may also collect and store Clinical
Study Data, which is collected pursuant to a project-specific informed consent
with clinical research subjects, and may include detailed information regarding
health status, medical assessments, test results, and other data required for a
particular study. Detailed contractual arrangements, SOPs and business policies
govern all our work with customer data. Clinical Ink’s internal policies are
available for audit/review by our clients, provided that Clinical Ink remains
responsible for the adequacy of our business practices and technical
infrastructure.
Clinical Ink does not, and
will not, sell the personal information collected about you.
Personal information processing purpose limitation
Clinical Ink may process your
personal information in a fashion necessary and proportionate to the business
purpose for which it was collected, and strictly within the limits of
compatible operational purposes as outlined in the contractual arrangements our
clients.
We will not use your personal
information for different, unrelated, or incompatible purposes without
notifying you.
California privacy rights and how to exercise them
Right to know and to
portability
You have the right to request that we disclose to you:
·
the categories and sources of the personal
information that we collect about you, the purposes for which we use your
information and with whom such information is shared;
·
in case of disclosure for a business purpose, we
disclose the personal information categories obtained by each category of
recipient.
The disclosure described above
will be limited to the personal information collected or used over the past 12
months.
If we deliver our response
electronically, the information enclosed will be "portable", i.e.
delivered in an easily usable format to enable you to transmit the information
to another entity without hindrance – if this is technically feasible.
Right to the deletion of personal information
You have the right to request
that we delete any of your personal information, subject to exceptions set
forth by the law (such as, including but not limited to detect security
incidents and protect against fraudulent or illegal activities, to exercise
certain rights etc.).
If no legal exception applies,
because of exercising your right, Clinical Ink will delete your personal
information and direct any of our service providers to do so.
How to exercise your rights
To exercise the rights described
above, you need to submit your verifiable request to us by contacting us via
the details provided in this policy.
For us to respond to your request, it is necessary that
we know who you are. Therefore, you can only exercise the above rights by
making a verifiable request which must:
·
provide sufficient information that allows us to
reasonably verify you are the person about whom we collected personal
information or an authorized representative;
·
describe your request with sufficient detail
that allows us to properly understand, evaluate, and respond to it.
Clinical Ink will not respond to
any request if we are unable to verify your identity and therefore confirm the
personal information in our possession relates to you.
If you are unable to personally
submit a verifiable request, you can authorize a person registered with the
California Secretary of State to act on your behalf.
If you are an adult, you can
make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number
of 2 requests over a period of 12 months.
Individuals with inquiries or
complaints regarding this Privacy Policy should first contact Clinical Ink at privacy@clinicalink.com. You can
submit requests using the following contact information:
Clinical
Ink
Attn: Data Protection Officer
110 Gibraltar Road, Suite 150
Horsham, PA 19044
Tel: 1-800-301-5033
Request Response
We will confirm receipt of your
verifiable request within 14 days and provide information about how we will
process your request.
We will disclose and deliver the
required information to a consumer free of charge within 45 days of receiving
your verifiable consumer request. If more time is required to process your
request, we will explain to you the reasons why, and how much more time we
need. In this regard, please note that we may take up to 90 days to fulfill
your request.
Our disclosure(s) will cover the
preceding 12-month period.
Should we deny your request, we
will explain and provide you with a justification behind our denial.
We do not charge a fee to
process or respond to your verifiable request unless such request is manifestly
unfounded or excessive. In such cases, we may charge a reasonable fee considering
administrative costs or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind it.