Effective Date: February 5, 2020
This Online Privacy Notice (“Privacy Notice”) explains how Remarque Systems, Inc. (“Remarque Systems”) handles Personal Data that it collects and receives from users through the website (“Website”) and the Remarque Systems Platform (“Remarque Systems Platform”).
Online Privacy Notice
This summary section provides a brief overview of our Privacy Notice. Please read the full Privacy Notice below for more detailed information.
Remarque Systems collects the following types of information through the Remarque Systems Website:
- Information you provide. Personal Data you provide when entering information into the Website, Remarque Systems Platform, or contacting Remarque Systems.
- Information collected automatically. Personal Data is captured in the details of the actions you perform in the Remarque Systems Platform to generate the required audit trails. Your IP address and non-identifying information about your use of the Website and the Remarque Systems Platform may be collected automatically using tracking technologies, such as cookies. Your website browser software can be set to reject all cookies; however, cookies can allow you to take advantage of some of the site’s essential features, which may not work if you reject cookies.
- Information collected from other sources. Your Personal Data may be provided by a customer, user, or application programming interface (API) to create an account or provide you information.
Remarque Systems uses the information we collect for several purposes, mainly:
- To provide you with Remarque Systems services your organization has licensed.
- To communicate with you about Remarque Systems services.
- To improve your experience on the Website and the Remarque Systems Platform.
Remarque Systems does not sell or disclose your personal data to any individual or organization without your consent. Remarque Systems may disclose your personal data for the following purposes:
- To third-party service providers and affiliates to provide services required to support the Website and the Remarque Systems Platform and to support our business operations. We require these parties to handle Personal Data in accordance with appropriate contractual privacy and security provisions and this Privacy Notice.
- To governing regulatory authorities or as may otherwise be necessary for Remarque Systems to comply with a legal obligation or demand
Remarque Systems does not knowingly collect or use any Personal Data directly from children on the Website.
You may contact us at any time if you have questions about this Privacy Notice or the Personal Data we collect about you. Please submit your privacy inquiries here.
Remarque Systems maintains appropriate controls and technical and organizational security measures to protect and secure personal data, but when you share personal data online there is always some risk that an unauthorized third party could gain access to your information.
This Privacy Notice does not apply to third-party service providers’ applications, databases, services, or websites to which the Website or the Remarque Systems Platform may link.
Remarque Systems is a global company headquartered in the U.S. and your Personal Data will be processed in the U.S. before being shared with affiliates around the world. This means that Personal Data may not be processed in a country that offers the same level of data protection as the country where you reside, including the European Economic Area. Remarque Systems complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework.
Check this Privacy Notice regularly, as we may change or update portions of this Privacy Notice from time to time, subject to any applicable consent requirements. Any changes will be promptly posted to this page and accompanied by a new effective date at the top of this page.
REMARQUE SYSTEMS ONLINE PRIVACY NOTICE
Effective date: February 5, 2020
This Online Privacy Notice (“Privacy Notice”) explains how Remarque Systems Inc. (“Remarque Systems”) handles personal data that it collects and receives from users through this website (“Remarque Systems Website”) and the Remarque Systems Platform (“Remarque Systems Platform”).
Information We Collect
The types of Personal Data that we may collect and receive while you use the Website and the Remarque Systems Platform are described in this section and include data that you provide to us, data that we collect automatically when you use the Website and the Remarque Systems Platform, and data collected from other sources.
For purposes of this Privacy Notice, “Personal Data” means any data related to a natural person who can be identified or is identifiable by reference of an identifier such as a name or trial subject code. Examples of Personal Data include name, address, telephone number, and email address. Personal Data may also include Sensitive Personal Data such as health data or demographic data where the Remarque Systems Platform is used for the services Remarque Systems provides to its customers.
Information You Provide
Remarque Systems collects Personal Data that you provide to the Website or Remarque Systems Platform, for example, when you contact Remarque Systems. This could include:
- Registration data such as your username and password
- Contact data such as your address, phone number, or email address
Information Collected Automatically
When you use the Website and the Remarque Systems Platform, we also may collect certain usage and device data automatically as described below.
When you use the Remarque Systems Platform, your Personal Data will be combined with the details of your actions to generate audit trails.
We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit the Website and the Remarque Systems Platform. An IP address identifies the electronic device you use to access the Website and the Remarque Systems Platform which allows us to maintain communication with your computer as you move about the Website and Remarque Systems Platform and to manage your user experience.
Cookies and Other Tracking Technologies
To learn more about cookies and other tracking technologies, including how to disable them, please visit http://www.allaboutcookies.org/ or http://youronlinechoices.eu/. Please note that some cookies are essential to the functioning of our websites and deleting or disabling them will reduce the sites’ functionality.
Information Collected from Other Sources
Through our customers’ use of the Remarque Systems Platform, we may receive Personal Data relating to you in a pseudonymized or identifiable form. We receive:
- Name and contact data of customer personnel who will be added as account members
- Name and contact data of study participants who do not have Remarque Systems Platform accounts with whom the customer needs to provide information
- Pseudonymized Personal Data of trial subjects and other participants in clinical trials.
How We Use Your Information
We use your Personal Data to provide you the services you request, communicate with you, improve your experience on the Remarque Systems Website, and for other business purposes, as described in more detail below.
Providing Services You Request
If you choose to contact us, we use the Personal Data that you provide through Remarque Systems Website to respond to your questions on the basis of your consent.
Providing Services to Our Customers
If your data is provided to us in connection with Remarque Systems services, we process your Personal Data in accordance with our legitimate interest in fulfilling the contracts agreed with our customers, for the purposes of public health and scientific research, and on the basis of your consent where applicable.
Communicating with You
If you choose to submit your details through Remarque Systems Website, we may add you to our marketing list and contact you about our services. You may unsubscribe from such communications at any time using the link provided in emails from us.
Customized User Experiences
Business and Product Improvement
In order to discover new facts that could help Remarque Systems better understand customer needs and help improve, develop, and evaluate services, materials, and incentives to join us, Remarque Systems analyses the information that you have provided for its legitimate interests in business and marketing improvement.
Service Analytics and Improvement
We may use the information that you provide and the information we collect automatically about your use of the Remarque Systems Website to monitor user traffic patterns and preferences for our legitimate business interests of improvement, analytics, and optimization of the Remarque Systems Website.
Data Use and Retention
We will only keep Personal Data as long as necessary for the fulfillment of the purposes outlined above, except if otherwise required by applicable laws or legal orders.
When We Share Your Information with Third Parties
We only share your Personal Data with third parties as described below. We do not sell or rent Personal Data to third parties for their own marketing purposes.
Affiliates, Vendors, and Suppliers
We have relationships with various vendors and suppliers, including our affiliated group companies, who help us operate our business and for whom it may be necessary to have access to your Personal Data in the course of providing services to you. We will not authorize these parties to use your Personal Data for any purpose that is not related to Remarque Systems’ business operation or our services to you, and we require them to handle your Personal Data in accordance with appropriate contractual privacy and security provisions and this Privacy Notice.
Legal Rights and Obligations
In certain limited circumstances, Remarque Systems may need to disclose your Personal Data to comply with a legal obligation or demand, such as to comply with reporting obligations to our governing regulatory authorities or in connection with the sale or transfer of one of our product lines or divisions which includes the services provided through the Remarque Systems Platform. In such instances, we will take measures to protect your Personal Data to the extent possible. We also reserve the right to use Personal Data to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.
Privacy of Children
Remarque Systems does not knowingly collect or use any Personal Data directly from children on the Website. We do not knowingly allow children to communicate with us or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.
We do process Personal Data of pediatric trial subjects in the course of providing the Remarque Systems services on the Remarque Systems Platform. This processing is subject to suitable safeguards put in place by our customers and in accordance with applicable laws.
Your Privacy Choices
You may contact Remarque Systems to ask questions, discuss your concerns, or report privacy concerns. If you communicate with or request information from Remarque Systems, you may be prompted to provide your contact information as well as any Personal Data that is relevant to your request.
Remarque Systems has an appointed Data Protection Officer who is contracted through Remarque Systems’ parent group Premier Research. Please submit your privacy inquiries here.
Alternatively, you may send a letter to Premier Research, 250 South Oak Way, Green Park, Reading, RG2 6UG, United Kingdom (attention: Global Data Protection Officer).
Additional Information for California Residents
If you are a California resident, you have the right to receive specific information about how Remarque Systems collects, uses and discloses your Personal Data, and you may have specific rights with respect to your Personal Data. California-specific privacy requirements that are not addressed in other sections of this Privacy Notice are described in this section.
Consistent with the Information we collect section above, we collect certain categories and specific pieces of information about individuals that are considered Personal Data. As detailed above, we may collect this Personal Data from you and other third parties. We collect, use and disclose Personal Data for the business and commercial purposes described in the How we use Your Information and the When we share your Information sections above. Under the definition of “selling” in the California Consumer Privacy Act, Remarque Systems does not sell your Personal Data.
As a California resident, you have the right to request:
- Information about the Personal Data that Remarque Systems has collected, used and disclosed about you over the previous 12 months, including: the categories of Personal Data collected; the categories of sources from which your Personal Data was collected; the business or commercial purposes for which Remarque Systems collected your Personal Data; the categories of your Personal Data that was disclosed for a business or commercial purpose; and the categories of third parties with whom Remarque Systems shared your Personal Data;
- The specific Personal Data that Remarque Systems has collected about you over the previous 12 months; and
- To have your Personal Data deleted.
Should you exercise any of your privacy rights as a California resident, Remarque Systems will not discriminate against you by offering you different pricing or services, or by providing you with a different level or quality of services, based solely upon this request. Certain Remarque Systems Services, however, may require that Remarque Systems processes your Personal Data in order to provide the Service or to allow us to use and disclose your Personal Data to provide the Service. When you exercise your right to have your Personal Data deleted, you may lose access to certain aspects of Remarque Systems Services that require your Personal Data to perform the service.
Please see the Your Privacy Choices section if you have questions or would like to make a request to exercise any of your rights.
Additional Information for European Economic Area residents
Remarque Systems would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request Remarque Systems for copies of your Personal Data or a description of the Personal Data categories we process or a description of the processing.
- The right to rectification – You have the right to request that Remarque Systems correct any information you believe is inaccurate. You also have the right to request Remarque Systems to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that Remarque Systems erase your Personal Data, under certain conditions.
- The right to restrict processing – You have the right to request that Remarque Systems restrict the processing of your Personal Data, under certain conditions.
- The right to object to processing – You have the right to object to Remarque Systems’ processing of your Personal Data that are based on legitimate interests, under certain conditions.
- The right to data portability – You have the right to request that Remarque Systems transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If Remarque Systems will not be able to provide the requested information or make the change you request, you will be provided with reasons for such decision.
Under local law you are also entitled to lodge a complaint with your local data protection authority.
Please submit your requests and privacy inquiries as described in Your Privacy Choices.
Remarque Systems maintains reasonable technical, administrative, organizational, and physical security measures and controls to secure any Personal Data collected through the Remarque Systems Platform in accordance with the Remarque Systems Platform Security Overview available at https://remarquesystems.com/security-overview/. However, there is always some risk that an unauthorized third party could intercept an Internet transmission or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the Internet, especially any sensitive Personal Data. Remarque Systems cannot guarantee that unauthorized third parties will not gain access to your Personal Data; therefore, when submitting Personal Data to Remarque Systems Platform, you must weigh both the benefits and the risks.
Links to Third-Party Sites and Social Media Plug-ins
This Privacy Notice does not apply to third-party service providers’ applications, databases, services, or websites to which the Website or the Remarque Systems Platform may link. Personal Data may be provided to the Remarque Systems Platform via a direct application integration with third party systems. Remarque Systems makes no representation in this Privacy Notice as to the security of individual integrations.
Accessing Our Sites Globally
This site is owned and operated by Remarque Systems, and if you are visiting this site from a country outside the U.S., your communication with us will necessarily result in the transfer of information across international borders. Personal Data may be transferred to other Remarque Systems affiliates in territories that may not provide a level of protection to Personal Data equivalent to that provided by your home country.
As a covered entity of Premier Research International LLC, Remarque Systems complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from the European Union member countries and Switzerland to the United States. Remarque Systems, via Premier Research International LLC, has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
In compliance with the EU-US and Swiss-US Privacy Shield Frameworks, Remarque Systems adheres and cooperates fully with the EU Data Protection Authorities (EU DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) regarding human resource data (which is any Personal Data about an organization’s own employees, past or present, collected in the context of the employee relationship) and non-human resource data. Remarque Systems will comply with advice given by such authorities with regard to Personal Data transferred from the European Union and Switzerland. Remarque Systems commits to resolve complaints about your privacy and our collection or use of your Personal Data. Persons from the European Union and Switzerland who have inquiries or complaints regarding this Privacy Notice should first contact us here.
Remarque Systems has further committed to refer unresolved Privacy Shield concerns to the International Centre for Dispute Resolution®, the international division of the American Arbitration Association® (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshield.html for more information and to file a complaint. The services of the ICDR/AAA are provided at no costs to you.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Any onward transfers of Personal Data to vendors and suppliers outside the EEA will be done in compliance with the international data transfer restrictions that apply under EU and Swiss data protection laws, including, where appropriate, through the use of EU model contracts for data transfers to processors. In such cases of onward transfer to third parties of data of EU or Swiss individuals, received pursuant to the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield, Remarque Systems is potentially liable.
Changes to Our Privacy Notice
We will only use Personal Data in the manner described in the Privacy Notice in effect when the information was collected from you or as authorized by you. However, and subject to any applicable consent requirements, or if required by law, we reserve the right to change the terms of this Privacy Notice at any time. Any changes to this Privacy Notice will be reflected on this page with a new effective date. Remarque Systems encourages you to review this Privacy Notice regularly for any changes. Any Personal Data collected upon your continued use of Remarque Systems Website will be handled in accordance with the currently posted Privacy Notice.