Updated January 16, 2018
This privacy policy describes how Acurian, Inc. (“Acurian”) collects and uses the personal information you provide on our web sites: www.acurian.com, www.acuriantrials.com, and www.test-screener.acurian.com. It also describes your choices regarding use, access and correction of your personal information. Acurian’s primary mission is to increase awareness about, and facilitate participation, in clinical trials related to development of investigational drugs and therapies. Individuals entrust us with information of a personal and confidential nature, so we have adopted this Privacy Policy (“Policy”) to inform you about our practices in collecting, using and protecting such information. The Policy explains in general terms how we seek to comply with data privacy laws and regulations, including but not limited to national laws.
Children Under 13
Our websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information to us through our websites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our websites. If we learn we have collected or received personal information from a child under 13 we will delete that information.
Information Covered by this Policy
This Policy applies to any personally identifiable information about you (“Personal Information”) that you may provide to Acurian when:
- using any of our websites or sending us information by email;
- speaking with one of our representatives on the phone; or
- providing information in writing.
Information Collected and How We Use It
At various locations on our site, and during our business practice, we ask you for information, which will allow us to provide you (whether you are a patient or physician) with information that is targeted specifically to you. If you would like to be considered for enrollment in a clinical trial, this information allows us to contact you regarding particular studies for which you may be eligible. We collect information in the following ways:
- Initial User Registration. We collect information you provide to us when you register at one of our sites (e.g., name, date of birth, email address, address, phone number, and demographic information).
- Further Information. At various locations on our site, we may ask you for additional information so that we can provide you with additional services (e.g., notification about your appointments or new clinical trials).
- Enrollment Forms. Many of our users are interested in enrolling in clinical trials. To learn whether you satisfy the criteria for a particular trial, we request medical information via a questionnaire. If you meet the prequalification criteria for the trial, and grant Acurian explicit permission to do so, your information will be forwarded to an investigator in your area for further evaluation; the investigator will be under strict constraints by laws governing the disclosure of Personal Information. You can also input your child’s date of birth and medical information to verify if your child satisfies the criteria for a particular trial.
- Data Aggregation. To enhance our ability to provide you with our services, we may combine your Personal Information with aggregated data about groups of people in similar circumstances. For example, we may infer that there is a 50% chance that you are divorced from the fact that your zip code has a 50% divorce rate.
- Tell-a-friend. We allow users to tell their friends about our site using our referral service. If you provide your friend’s name and email address, we will automatically send a one-time email inviting him or her to visit our site. We do not store this email address and will not use it for any other purpose. Your friend may contact us at information@acurian.com to request that we remove this information from our database.
- We and our partners (e.g., medical centers, healthcare companies, medical websites) may occasionally offer newsletters or other publications focused on specific medical conditions that you might want to receive. If you ask to receive a newsletter, we will use your contact information to deliver the material you request.
- Data Partners. Acurian partners with several companies that gather opted-in information from consumers, which include self-reported health information. If you have provided Personal Information to one of our Data Partners (including information on your health, purchasing habits, or lifestyle) indicated an interest in clinical research studies or health information, and opted in to receive information of interest from third parties, we may receive your Personal Information from the Data Partner.
- Public Records. In some circumstances, we may link the information you have provided to our Data Partners with publicly available data about you, such as public directory phone numbers.
- Lifestyle-based Analytics. In some circumstances, we may contact you by mail regarding potential clinical studies where information you voluntarily provided to our Data Partners or publicly available information suggests on the basis of analysis of various demographic and societal trends that you might benefit from such studies.
- Messaging Services. If you enroll in a clinical trial and expressly consent to receiving study information and messages, we will provide you with appointment reminders, study instructions, and other important study instructions. In addition, we may exchange relevant health information with the study doctor and staff in order to provide these services.
- Opt Out Requests. If you send us an email or use our website to opt out of receiving information or being contacted, we will retain and use some of your information to avoid further contact with you. We may also retain your information to the extent it has previously been incorporated in anonymized data and as necessary for us to meet legal requirements and defend claims against us.
- Resource Documents Registration. If you register to use our resource documents, we request your name, company email address, company name, and telephone number. We use this information to create an account for you to allow you access to our patient recruitment white papers, recorded webinars, brochures, case studies, and other resources.
We will retain your information for as long as your account is active or as needed to provide you services. You may remove your information from our contact list by sending an email entitled “Unsubscribe” to information@acurian.com. Please note that we may retain and use your information as necessary to comply with our legal obligations, when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or similar legal process served on our Web Site, resolve disputes, and enforce our agreements.
Information Sharing and Transfer
We will share your Personal Information with third parties only in the ways that are described in this privacy statement or unless you expressly opt in to such sharing.
Service Providers/Partners
We may provide your information with third-party service providers (e.g., call centers, email service providers), or data partners who are contractually bound to handle your information confidentially and prohibited from disclosing your information to others.
Legal Notice
We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
When and How Acurian May Contact You
When you register with Acurian, or complete a prequalification questionnaire associated with a particular trial, you indicate your consent for Acurian to store your Personal Information in our database and contact you about clinical trials for which you may be eligible by various means, including telephone, email, and US mail. You also have the option of receiving emails regarding new postings to our site, including news or new clinical trials. In addition, Acurian may contact you periodically when we have provided new functionality to our website, so that you may take advantage of the new services. If you receive a text message from us and would like to discontinue such messages, you may reply with the word “STOP.” Providing a telephone number constitutes your consent for Acurian to contact you at that number for the purposes outlined in this Policy.
Cookies / Tracking Technologies
We Acurian and our affiliates, or analytics or service providers use cookies or similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
A cookie is a data file that is placed by a website operator on the hard drive of a visitor’s computer to their site. First-party cookies (owned and controlled by Acurian) are enabled to the computers of those visiting our websites for the following purposes: to improve the user experience by allowing the site to remember a visitor as they browse through different pages; to allow us to perform site analytics; to assess whether visitors to the site later become referrals to clinical trials. One of the ways that we do this is through the use of Google Analytics using data layers listed here.
First-party cookies are enabled and controlled by our web team, which is established on U.S. territory. Our websites also place cookies for the purpose of serving Acurian-sponsored advertisements at third-party websites, and for the purpose of performing various cost analyses relating to the site.
You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve analytics and site functionality.
Acurian may allow third parties to place cookies on our site for advertising purposes. These third parties may use cookies or similar technologies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. This Privacy Policy does not cover the collection methods or use of the information collected by these vendors, which have their own privacy policies and may be members of the Network Advertising Initiative (“NAI”). To be removed from some or all NAI member advertising programs, please visit the NAI Opt-Out Page and follow the relevant instructions. Or if you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Social Media Widgets
Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
Correcting Your and Your Child’s Personal Information and “Opting Out”
Upon request Acurian will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at information@acurian.com.
You may correct your Personal Information or your child’s information, modify your contact preferences, or completely opt out of our services at any time. You can update your or your child’s information, correct inaccuracies, or delete some or all of your or your child’s data by emailing us at information@acurian.com, we will respond to your request to access within 30 days.
We sometimes refer to your consent to be contacted, to be included in a clinical trial, or to other use of your Personal Information as “opting in.” You may revoke your consent (i.e., “opt out”) at any time.
The first time you provide us with information, you will have the ability to instruct us regarding other communications (e.g., requesting newsletters, etc.). You may opt-out from receiving our newsletters by clicking on the “unsubscribe” link located at the bottom of each newsletter. To completely opt out of our services, please send an email entitled “Unsubscribe” to information@acurian.com
Information Security
We maintain information security safeguards to protect your Personal Information. We protect any Personal Information you provide using encryption, and utilize firewalls to protect our computer network from hackers. We take reasonable steps designed to prevent unauthorized access, use and alteration of Personal Information, but cannot guarantee the security of such information.
We require you to select a username and password. To minimize the chance that someone can guess your password, we require passwords with a minimum length of 8 characters, including numbers and upper and lower case letters. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
Data Protection Laws
In jurisdictions with data protection laws, we will ensure that individuals can exercise all relevant informational rights regarding their Personal Information we process, including the rights of access and correction, to prevent direct marketing, block processing, and erase data. Acurian has executed Standard Contractual Clauses for the purpose of transferring personal information from the European Economic Area.
Links to Third Party Sites
Our website includes links to other websites (including but not limited to Facebook, Twitter) whose privacy practices may differ from those of Acurian. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Sale or Transfer of Corporate Assets
Acurian expressly reserves the right to transfer its database of information to another legal entity as part of any sale or merger of Acurian, Inc. with that entity. Any entity acquiring Acurian’s data assets will do so with the express, written commitment to use the data only for authorized purposes, and only if the entity maintains a similar level of privacy and information security protection. You will be notified via email or notice on our website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Inquiries, Complaints, and Requests to Exercise Rights
All communications, queries, requests to exercise informational rights (e.g. access to data) or complaints should be addressed:
- by email to information@acurian.com
- by fax to (215) 323-9001, Attn: Privacy Officer
- by regular mail at Acurian, Inc., Attn: Privacy Officer, 2 Walnut Grove Drive, Suite 375, Horsham, PA, 19044.
EU-U.S. and Swiss-U.S. Privacy
Acurian (and its subsidiary, Panoply Health Limited) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Acurian has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: https://www.privacyshield.gov/
Acurian is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Acurian complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Acurian is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Acurian may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Acurian has put in place measures to ensure that adequate protection is provided to the data where legally mandated.
In compliance with the Privacy Shield Principles, Acurian commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Acurian:
by email at information@acurian.com; or
by fax to (215) 323-9001, Attn: Privacy Officer; or
by regular mail at Acurian, Inc., Attn: Privacy Officer, 2 Walnut Grove Drive, Suite 375, Horsham, PA, 19044.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Changes to the Policy
We regularly review our Policy to ensure that it provides an appropriate level of protection for your Personal Information. From time to time, we may make changes to our Policy to keep it current with industry standards and as required by law. We will post the date of the most recent revisions on this page. Please check back here from time to time to make sure that you are current and up-to-date on our Policy. Please keep in mind that your use of our Web site means that you accept our Privacy and Security Policy. For more information on this point, please read our Terms of Service of site use. If we make a material change to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the changes taking effect.