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1 381783 v1/CO Mytrus, Inc. Page 1 of 6
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4 MYTRUS PRIVACY POLICY (last updated: 2014-10-01) MYTRUS PRIVACY POLCY (last updated:
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6 Thank you for visiting Mytrus.com, (collectively the “Site”), which is owned and provided by March 17, 2017)
7 Mytrus, Inc, (“Mytrus,” “we,” or “us”). We value and respect your privacy, and this privacy Mytrus, Inc. (“Mytrus,” “we,” “us,” or “
8 policy (the “ our”) is committed to protecting your privacy. We have
9 Privacy Policy”) is designed to assist you in understanding how we collect, use, and prepared this Privacy Policy to describe to you our practices regarding the personal information we collect
10 protect personal information you may provide from users of our websites and mobile applications (collectively, the “Site”) and
11 . online services (“Services”).
12 THE INFORMATION WE COLLECT THE INFORMATION WE COLLECT
13 Mytrus does not collect personally identifiable information via the website, unless you submit it Mytrus does not collect personal information via the Site unless you submit personal information
14 to us in connection with enrolling for our service “Enroll”. In such event, we will only use any to us in connection with using the Site or Services.
15 information you include in your email to respond to your request. We do not share The Services may collect and store certain personal information from you, including contact
16 any information, so we can communicate with you in regard to your use of the Services, and
17 information contained in such emails with any third parties or use it for any purpose except information
18 responding to you.
19 If you related to your health and medical condition (“Medical Data”) required for the
20 participate in a clinical study performed by any client of Mytrus, including our third p research in which you are participating that is being carried out by a third party (“Sponsor”). The
21 arty type of Medical Data collected will necessarily vary
22 clinical research organization clients (“CROs”), our automated program “Enroll” collects certain
23 information from you related to your health and medical condition (“Medical Data”) according to the research in which you are
24 participating. Prior to you being asked to provide your Medical Data via the Services, the
25 Sponsor will inform you of the kinds of data that you will be asked to provide during your
26 participation in the study and will require you to agree to one or more additional consents and
27 . Typically, we collect this from you via a tablet or computer at the time you enroll in a medical study and privacy authorizations. Typically, we collect this information from you via a computer or tablet at the time you enroll
28 sign an Informed Consent Form (“ICF”).
29 We protect your Medical Data in the following ways:
30 as a participant in the research and subsequently during your continued
31 We do not collect and store Medical Data from you unless you first agree and sign an participation in the research. We do not collect and store Medical Data from you unless you agree
32 ICF. The content and form of ICFs differ from country to country, but in all instances
33 describe in detail how your Medical Data will be collected and transferred.
34 • If you are locat to the terms of a privacy
35 ed in the European Union (“EU”), before any Medical Data is transmitted authorization provided by the
36 to the United States, our CRO in the EU will de-identify your Medical Data by removing Sponsor during the
37 all personally identifiable information and labeling it with a unique, randomly assigned
38 study number or ‘code’ before they are sent to Mytrus, or to facilities chosen by Mytrus process of enrolling in the Sponsor’s rese
39 that are arch
40 in the US. using the
41 • WE ADHERE TO AND HAVE CERTIFIED OUR COMPLIANCE WITH THE SAFE
42 HARBOR PRIVACY PRINCIPLES, INCLUDING NOTICE, CHOICE, ONWARD
43 TRANSFER, SECURITY, DATA INTEGRITY, ACCESS, AND ENFORCEMENT, OF
44 THE UNITED STATES/EUROPEAN UNION DATA PROTECTION SAFE HARBOR
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46 381783 v1/CO
47 FRAMEWORK AND THE UNITED STATES/SWITZERLAND DATA PROTECTION
48 SAFE HARBOR FRAMEWORK, BOTH OF WHICH ARE MADE AVAILABLE BY
49 THE U.S. DEPARTMENT OF COMMERCE AT
50 HTTP://WWW.EXPORT.GOV/SAFEHARBOR. OUR CERTIFICATION CAN ALSO
51 BE VIEWED AT HTTP://WWW.EXPORT.GOV/SAFEHARBOR. Services.
52 We may also collect certain usage and/or aggregate information as a result of your use of, We may also collect certain usage and/or aggregate information as a result of your use of,
53 and interaction with, the Site(s) (“Indirect Information”), including by using certain and interaction with, the Site or Services (“Indirect Information”), including using certain
54 standard web measurement and tracking technologies such as “cookies,” web server logs, or standard web measurement and tracking technologies such as “cookies,” web server logs, or
55 other statistics programs to track and record how you use the Site(s). Indirect Information helps us measure the success of the Site(s) and its features or pages and to improve your online experience. Your browser may have an option that allows you to accept cookies, reject cookies, or receive notification when a cookie is sent, but you should note that the use of such restrictive browser settings may limit your use of the Site(s). other statistics and analytics services to track and record how you use the Site. Indirect Information helps us to measure the success of the Site and its features or pages and to improve your online experience. Your browser may have an option that allows you to accept cookies, reject cookies, or receive notification when a cookie is sent, but you should note that the use of such restrictive browser settings
56 USE OF INFORMATION COLLECTED
57 We only use Medical Data for the specific purposes described in the ICF that you signed
58 when you enrolled in a study can limit your use of the Site.
59 Mytrus Privacy Policy, Updated March 17, 2017
60 Mytrus, Inc. Page 2 of 6
61 The Site may use Google Analytics, a web analytics service provided by Google, Inc.
62 (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer,
63 to help Mytrus analyze how users use the Site. The information generated by the cookie
64 about your use of the Site (including your IP address) will be transmitted to and stored by
65 Google on servers in the United States. Google will use this information for the purpose of
66 evaluating your use of the Site, compiling reports on website activity for website operators
67 and providing other services relating to website activity and Internet usage. Google may
68 also transfer this information to third parties where required to do so by law, or where such
69 third parties process the information on Google’s behalf. Google will not associate your IP
70 address with any other data held by Google. You may refuse the use of cookies by selecting
71 the appropriate settings on your browser, however please note that if you do this you may
72 not be able to use the full functionality of the Site. By using the Site, you consent to the
73 processing of data about you by Google in the manner and for the purposes set out above.
74 You can opt-out of Google Analytics at any time by installing the opt-out plugin, available
75 at the following web page:
76 http://tools.google.com/dlpage/gaoptout?hl=en-GB
77 The Site does not currently respond to “do not track” signals from web browsers.
78 The Site may use Adobe’s Typekit WebFont service. For information regarding privacy and
79 Typekit, please view the Typekit privacy policy at the following web page:
80 http://www.adobe.com/privacy/policies/typekit.html
81 USE OF INFORMATION COLLECTED
82 We only use Medical Data for the specific purposes described in the privacy authorization that is
83 provided by the Sponsor and to which you must agree before participating in the research being
84 . We do not share or use medical data for any other reason and we securely destroy all Medical Data after use. conducted by the Sponsor. We do not share or use Medical Data for any other reason and we securely destroy all Medical Data after use.
85 We use your Indirect Information for the following business purposes: We use your Indirect Information for the following business purposes:
86 • to determine the number of users accessing our Content; • to determine the number of users accessing our Content;
87 • to analyze, manage and improve the Site; • to analyze, manage, and improve the Services;
88 • to understand you and your preferences to enhance your experience and enjoyment using • to
89 our Site;
90 • to determine your particular areas of interests;
91 • to send you requested information;
92 • to send you related information, including links to Content that we believe to match your
93 interests; and
94 • for any other specific business purpose stated at the time you provide your information.
95 Dispute Resolution
96 If you believe that Mytrus has no send you requested information; and
97 • for any other specific business purpose stated at the time you provide your information.
98 SHARING OF YOUR INFORMATION
99 We will provide your personal information to the Sponsor and partners of the Sponsor who are
100 authorized to receive such information for the purpose of conducting and supporting the research
101 in which you are participating.
102 Mytrus Privacy Policy, Updated March 17, 2017
103 Mytrus, Inc. Page 3 of 6
104 We do not provide any of your information to other Mytrus employees or to any unaffiliated
105 third parties.
106 We may share some or all of your personal information in connection with or during negotiation
107 of any merger, financing, acquisition or dissolution transaction or proceeding involving sale,
108 transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an
109 insolvency, bankruptcy, or receivership, personal information may also be transferred as a
110 business asset. If another company acquires our company, business, or assets, that company will
111 possess the personal information collected by us and will assume the rights and obligations
112 regarding your personal information as described in this Privacy Policy.
113 Regardless of any choices you make regarding your personal information, Mytrus may disclose
114 personal information if it believes in good faith that such disclosure is necessary (a) in
115 connection with any legal investigation; (b) to comply with relevant laws or to respond to
116 subpoenas or warrants served on Mytrus; (c) to protect or defend the rights or property of Mytrus
117 or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential
118 violation of the law or this Privacy Policy.
119 INTERNATIONAL VISITORS
120 The Services are hosted in the United States and is intended solely for visitors located within the
121 United States and Canada. If you nonetheless choose to use the Services from the European
122 Union or other regions of the world whose laws governing data collection and use may differ
123 from U.S. law, then please note that by submitting any personal information, you are transferring
124 your personal information outside of those regions to the United States and that you consent to
125 such transfer.
126 EU-U.S. PRIVACY SHIELD
127 Mytrus complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department
128 of Commerce regarding the collection, use, and retention of personal information from European
129 t adhered to this Privacy Polic Union member countries. Mytrus has certified that it adheres to the Privacy Shield Principles of
130 y or the terms of any ICF in Notice, Choice, Accountability for
131 connection with the transfer of Medical Data to the United States Onward Transfer, Security, Data Integrity and Purpose
132 Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the
133 policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles
134 , please contact Mytrus by e- shall govern. To learn more about the Privacy Shield program, and to view our certification page, please
135 mail at info@mytrus.com. We will do our best to immediately address your concerns. If you
136 feel that your complaint has been addressed incompletely, we invite you to let us know for
137 further investigation. If you and Mytrus are unable to reach a resolution to the dispute, you and
138 Mytrus will settle the dispute exclusively under the pursuant to JAMS Comprehensive Rules or
139 International Rules of JAMS International (for more information, visit
140 www.jamsinternational.com/rules-procedures/safeharbor).
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143 OPTING-OUT.
144 If you are a medical practitioner or bioscience professional and you contact us via email, we
145 may use your email address to send you email communications about us and our products
146 that are related to your practice, specialty and interests. In the event that you choose not to
147 receive any future communications, you may opt-out by clicking on the link provided at the
148 bottom of each email communication.
149 SHARING OF YOUR INFORMATION
150 We do not provide any of your information to any unaffiliated third parties. We may however,
151 provide your information to other Mytrus employees who may contact you in regards to your
152 practice, especially and areas of interests.
153 CHANGES AND UPDATES TO THE PRIVACY POLICY
154 From time to time, we may revise this Privacy Policy. To help you stay current of any changes,
155 we note the date the Privacy Policy was last updated above. Your use of the Site(s) following
156 the posting of any revised Terms or Privacy Policy shall be deemed acceptance of the revised
157 policy. If you disagree with the provisions of this Privacy Policy, your sole remedy is to
158 terminate your use of the Site(s).
159 INTERNATIONAL VISITORS
160 This Site is hosted in the United States and is intended solely for visitors located within the
161 United States and Canada. If you nonetheless choose to use this Site from the European Union
162 or other regions of the world with laws governing data collection and use that may differ from
163 U.S. law, then please note that by submitting an email containing any personally identifiable
164 information, you are transferring your personally identifiable information outside of those
165 regions to the United States and by you consent to such transfer.
166 QUESTIONS
167 If you have any questions regarding privacy while using the Site(s), or have questions about
168 Mytrus’s practices, or wish to review or update your information, please contact Mytrus at:
169
170 Mytrus, Inc.,
171 105 E Street, Suite 2B, Davis, CA 95616
172 Main (530) 564-4600 | info@mytrus.com visit the following website:
173 http://www.privacyshield.gov
174
175 Mytrus is subject to the investigatory and enforcement powers of the U.S. Federal Trade
176 Commission (FTC) and the U.S. Food and Drug Administration (FDA).
177
178 As described in the Privacy Shield Principles, Mytrus is accountable for personal data that it
179 receives under the Privacy Shield Framework and subsequently transfers to third parties. If third
180 parties that process personal data on our behalf do so in a manner that does not comply with the
181 Mytrus Privacy Policy, Updated March 17, 2017
182 Mytrus, Inc. Page 4 of 6
183 Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for
184 the event giving rise to the damage.
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186
187 To review the Privacy Shield Principles, please visit the following web page:
188
189 https://www.privacyshield.gov/article?id=Requirements-of-Participation
190
191 In compliance with the EU-US Privacy Shield Principles, Mytrus commits to resolving
192 complaints about your privacy and our collection or use of your personal information. European
193 Union individuals with inquiries or complaints regarding this privacy policy should first
194 contact Mytrus at:
195 Mytrus, Inc.
196 105 E Street, Suite 2B
197 Davis, CA 95616
198 USA
199 Phone: (530) 564-4600
200 Email: privacy@mytrus.com
201
202 Mytrus has further committed to refer unresolved privacy complaints under the EU-US Privacy
203 Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution
204 provider located in the United States and operated by the Council of Better Business Bureaus. If
205 you do not receive timely acknowledgment of your complaint, or if your complaint is not
206 satisfactorily addressed, please contact BBB EU Privacy Shield at the following address:
207
208 Council of Better Business Bureaus, Inc.
209 BBB EU Privacy Shield
210 3033 Wilson Boulevard, Suite 600
211 Arlington, VA 22201
212 U.S.A.
213
214 For more information on BBB EU Privacy Shield, please visit the following web page:
215
216 https://www.bbb.org/EU-privacy-shield/for-eu-consumers/
217
218 Disputes may also be filed online from the following web page:
219
220 https://www.auto.bbb.org/eu-privacy-shield-complaint-form/
221
222 As further explained in the Privacy Shield Principles, binding arbitration will also be made
223 available to you in order to address residual complaints not resolved by any other means.
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227 Mytrus Privacy Policy, Updated March 17, 2017
228 Mytrus, Inc. Page 5 of 6
229 A NOTE ABOUT CHILDREN
230
231 We do not intentionally gather personal information from visitors who are under 13 years of age.
232 If a child under 13 years of age submits personal information to us and we learn that the personal
233 information is the information of a child under 13 years of age, we will attempt to delete the
234 information as soon as possible. If you believe that we might have any personal information from
235 a child under 13 years of age, please contact us at the following e-mail address:
236 privacy@mytrus.com
237 YOUR CHOICES
238 You have several choices regarding the use of information on our Services:
239 Email Communications. If you are a medical practitioner or bioscience professional and you
240 contact us via email, we may use your email address to send you email communications
241 about Mytrus and Mytrus products that are related to your practice, specialty and interests.
242 In the event that you choose not to receive any future communications, you may opt-out by
243 clicking on the link provided at the bottom of each email communication. Despite your
244 indicated e-mail preferences, we may send you service-related communications, including
245 notices of any updates to our Privacy Policy.
246 Changing or Deleting Your Personal Information. You may change any of the personal
247 information you submitted to us by sending an e-mail to us at the e-mail address set forth below.
248 You may request deletion of your personal information by us, and we will use reasonable efforts
249 to honor your request, but please note that we may be required to keep such information and not
250 delete it (or to keep this information for a certain time, in which case we will comply with your
251 deletion request only after we have fulfilled such requirements). When we delete any
252 information, it will be deleted from the active database, but may remain in our archives. We may
253 also retain your information for fraud-prevention or similar purposes.
254 SECURITY
255 Mytrus is committed to protecting the security of your personal information. We use a variety of
256 industry-standard security technologies and procedures to help protect your personal information
257 from unauthorized access, use, or disclosure. No method of transmission over the Internet, or
258 method of electronic storage, is 100% secure, however. Therefore, while Mytrus uses reasonable
259 efforts to protect your personal information, Mytrus cannot guarantee its absolute security.
260 THIRD-PARTY WEBSITES
261 Our Site may contain links to third-party websites. When you click on a link to any other website
262 or location, you will leave our Site and go to another site, and another entity may collect
263 information from you. We have no control over, do not review, and cannot be responsible for,
264 these outside websites or their content. Please be aware that the terms of this Privacy Policy do
265 not apply to these outside websites or content, or to any collection of your personal information
266 after you click on links to such outside websites. We encourage you to read the privacy policies
267 Mytrus Privacy Policy, Updated March 17, 2017
268 Mytrus, Inc. Page 6 of 6
269 of every website you visit. The links to third party websites or locations are for your convenience
270 and do not signify our endorsement of such third parties or their products, content, or websites.
271 CHANGES AND UPDATES TO THE PRIVACY POLICY
272 From time to time, we may revise this Privacy Policy. To help you stay informed of any changes,
273 we note the date that the Privacy Policy was last updated on the first page of this document and
274 in the header of each subsequent page. Your use of the Services following the posting of any
275 revised Privacy Policy shall be deemed acceptance of the revised policy. If you disagree with the
276 provisions of this Privacy Policy, your sole remedy is to terminate your use of the Services.
277 CONTACT
278 If you have any questions regarding privacy while using the Services, or have questions about
279 Mytrus’s practices, or wish to review or update your information, please contact Mytrus at:
280 Mytrus, Inc.
281 105 E Street, Suite 2B
282 Davis, CA 95616
283 USA
284 Phone: (530) 564-4600
285 Email: privacy@mytrus.com