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3 MYTRUS PRIVACY POLCY MYTRUS PRIVACY POLICY
4 (last updated: March 17, 2017) (last updated: March 24, 2017)
5 Mytrus, Inc. (“Mytrus,” “we,” “us,” or “our”) is committed to protecting your privacy. We have Mytrus, Inc. (“Mytrus,” “we,” “us,” or “our”) is committed to protecting your privacy. We have
6 prepared this Privacy Policy to describe to you our practices regarding the personal information prepared this Privacy Policy to describe to you our practices regarding the personal information
7 we collect from users of our websites and mobile applications (collectively, the “Site”) and we collect from users of our websites and mobile applications (collectively, the “Site”) and
8 online services (“Services”). online services (“Services”).
9 THE INFORMATION WE COLLECT THE INFORMATION WE COLLECT
10 Mytrus does not collect personal information via the Site unless you submit personal information Mytrus does not collect personal information via the Site unless you submit personal information
11 to us in connection with using the Site or Services. to us in connection with using the Site or Services.
12 The Services may collect and store certain personal information from you, including contact The Services may collect and store certain personal information from you, including contact
13 information, so we can communicate with you in regard to your use of the Services, and information related to your health and medical condition (“Medical Data”) information, so we can communicate with you in regard to your use of the Services. At a minimum, we may collect and store your first name and last (family) name. If you create an
14 account on the Site, we may also collect and store your email address, which will serve as your
15 required for the research in which you are participating that is being carried out by a third party (“Sponsor”). The account’s “user name.” As may be required for the research in which you are participating that is being carried out by a third party (the “Sponsor”)
16 type of Medical Data collected will necessarily vary accor , we may ask for you to provide additional
17 personal information. Such personal information can include your date of birth, residential
18 address, and phone numbers (e.g., home, work, mobile). For Services that obtain your consent to
19 participate in research, this personal information may also include a digitized image of your
20 handwritten signature.
21 ding to the research in which you are participating. Prior to you being asked to provide your Medical Data via the Services, the Depending on the research study in which you are participating
22 Sponsor will inform you of the kinds of data that you will be asked to provide during your
23 participation in the study and will require you to agree to one or more additional consents and
24 privacy authorizations via the Site, we may collect and
25 store information related to your health and medical condition (“Medical Data”) as required for
26 the research in which you are participating that is being carried out by the Sponsor. The type of
27 Medical Data collected will necessarily vary according to the research in which you are
28 participating. The Medical Data may be collected directly from you via online forms that you
29 complete and submit to the Site or from researchers who may use the Site to submit your
30 . Typically, we collect this information from you via a computer or tablet at the time you enroll as a participant in the research and subsequently during your continued Medical Data on your behalf. Typically, we collect this information from you via a computer or tablet at the time you enroll as a participant in the research and subsequently during your continued participation in the research.
31 Prior to asking you to provide your Medical Data via the Services, the Sponsor will inform you
32 participation in the research. in detail regarding the types of data that you may be asked to provide during your participation in the research.
33 We do not collect and Moreover, the Sponsor will require you to agree to one or more additional consents
34 and privacy authorizations before asking you to submit any Medical Data. We do not collect and
35 Mytrus Privacy Policy, Updated March 21, 2017
36 store Medical Data from you unless you agree to the terms of a privacy authorization provided by the Sponsor during the process of enrolling in the Sponsor’s research using the Services. Mytrus, Inc. Page 2 of 6 store Medical Data from you unless you agree to the terms of a privacy authorization provided by the Sponsor during the process of enrolling in the Sponsor’s research using the Services. If
37 you do not agree to the additional privacy authorization, none of your Medical Data will be
38 collected and stored on the Site. However, some minimal personal information that you
39 submitted to the Site (such as your first name, last name, and email address) may continue to be
40 stored, unless you contact us to request that we delete your personal information (see the
41 following section “Changing or Deleting Your Personal Information”).
42 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,
43 and interaction with, the Site or Services (“Indirect Information”), including using certain and interaction with, the Site or Services (“Indirect Information”), including using certain
44 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
45 other statistics and analytics services to track and record how you use the Site. Indirect other statistics and analytics services to track and record how you use the Site. Indirect
46 Information helps us to measure the success of the Site and its features or pages and to Information helps us to measure the success of the Site and its features or pages and to
47 improve your online experience. Your browser may have an option that allows you to accept improve your online experience. Your browser may have an option that allows you to accept
48 cookies, reject cookies, or receive notification when a cookie is sent, but you should note cookies, reject cookies, or receive notification when a cookie is sent, but you should note
49 that the use of such restrictive browser settings can limit your use of the Site. Mytrus Privacy Policy, Updated March 17, 2017 that the use of such restrictive browser settings can limit your use of the Site.
50 Mytrus, Inc. Page 2 of 6 The Site may use Google Analytics, a web analytics service provided by Google, Inc. The Site may use Google Analytics, a web analytics service provided by Google, Inc.
51 (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer,
52 to help Mytrus analyze how users use the Site. The information generated by the cookie to help Mytrus analyze how users use the Site. The information generated by the cookie
53 about your use of the Site (including your IP address) will be transmitted to and stored by about your use of the Site (including your IP address) will be transmitted to and stored by
54 Google on servers in the United States. Google will use this information for the purpose of Google on servers in the United States. Google will use this information for the purpose of
55 evaluating your use of the Site, compiling reports on website activity for website operators evaluating your use of the Site, compiling reports on website activity for website operators
56 and providing other services relating to website activity and Internet usage. Google may and providing other services relating to website activity and Internet usage. Google may
57 also transfer this information to third parties where required to do so by law, or where such also transfer this information to third parties where required to do so by law, or where such
58 third parties process the information on Google’s behalf. Google will not associate your IP third parties process the information on Google’s behalf. Google will not associate your IP
59 address with any other data held by Google. You may refuse the use of cookies by selecting address with any other data held by Google. You may refuse the use of cookies by selecting
60 the appropriate settings on your browser, however please note that if you do this you may the appropriate settings on your browser, however please note that if you do this you may
61 not be able to use the full functionality of the Site. By using the Site, you consent to the not be able to use the full functionality of the Site. By using the Site, you consent to the
62 processing of data about you by Google in the manner and for the purposes set out above. processing of data about you by Google in the manner and for the purposes set out above.
63 You can opt-out of Google Analytics at any time by installing the opt-out plugin, available You can opt-out of Google Analytics at any time by installing the opt-out plugin, available
64 at the following web page: at the following web page:
65 http://tools.google.com/dlpage/gaoptout?hl=en-GB http://tools.google.com/dlpage/gaoptout?hl=en-GB
66 The Site does not currently respond to “do not track” signals from web browsers. The Site does not currently respond to “do not track” signals from web browsers.
67 The Site may use Adobe’s Typekit WebFont service. For information regarding privacy and The Site may use Adobe’s Typekit WebFont service. For information regarding privacy and
68 Typekit, please view the Typekit privacy policy at the following web page: Typekit, please view the Typekit privacy policy at the following web page:
69 http://www.adobe.com/privacy/policies/typekit.html http://www.adobe.com/privacy/policies/typekit.html
70 USE OF INFORMATION COLLECTED USE OF INFORMATION COLLECTED
71 We only use Medical Data for the specific purposes described in the privacy authorization that is We only use Medical Data for the specific purposes described in the privacy authorization that is
72 provided by the Sponsor and to which you must agree before participating in the research being provided by the Sponsor and to which you must agree before participating in the research being
73 conducted by the Sponsor. We do not share or use Medical Data for any other reason and we conducted by the Sponsor. We do not share or use Medical Data for any other reason and we
74 securely destroy all Medical Data after use. securely destroy all Medical Data after use. Mytrus Privacy Policy, Updated March 21, 2017
75 We use your Indirect Information for the following business purposes: Mytrus, Inc. Page 3 of 6 We use your Indirect Information for the following business purposes:
76 • to determine the number of users accessing our Content; • to determine the number of users accessing our Content;
77 • to analyze, manage, and improve the Services; • to analyze, manage, and improve the Services;
78 • to send you requested information; and • to send you requested information; and
79 • for any other specific business purpose stated at the time you provide your information. • for any other specific business purpose stated at the time you provide your information.
80 SHARING OF YOUR INFORMATION SHARING OF YOUR INFORMATION
81 We will provide your personal information to the Sponsor and partners of the Sponsor who are We will provide your personal information to the Sponsor and partners of the Sponsor who are
82 authorized to receive such information for the purpose of conducting and supporting the research authorized to receive such information for the purpose of conducting and supporting the research
83 in which you are participating. Mytrus Privacy Policy, Updated March 17, 2017 in which you are participating.
84 Mytrus, Inc. Page 3 of 6 We do not provide any of your information to other Mytrus employees or to any unaffiliated We do not provide any of your information to other Mytrus employees or to any unaffiliated
85 third parties. third parties. If this practice changes in the future, we will update this policy and provide
86 individuals with opt-out or opt-in choice prior to sharing their data.
87 We may share some or all of your personal information in connection with or during negotiation We may share some or all of your personal information in connection with or during negotiation
88 of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, of any merger, financing, acquisition or dissolution transaction or proceeding involving sale,
89 transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an
90 insolvency, bankruptcy, or receivership, personal information may also be transferred as a insolvency, bankruptcy, or receivership, personal information may also be transferred as a
91 business asset. If another company acquires our company, business, or assets, that company will business asset. If another company acquires our company, business, or assets, that company will
92 possess the personal information collected by us and will assume the rights and obligations possess the personal information collected by us and will assume the rights and obligations
93 regarding your personal information as described in this Privacy Policy. regarding your personal information as described in this Privacy Policy.
94 Regardless of any choices you make regarding your personal information, Mytrus may disclose Regardless of any choices you make regarding your personal information, Mytrus may disclose
95 personal information if it believes in good faith that such disclosure is necessary (a) in personal information if it believes in good faith that such disclosure is necessary (a) in
96 connection with any legal investigation; (b) to comply with relevant laws or to respond to connection with any legal investigation; (b) to comply with relevant laws or to respond to
97 subpoenas or warrants served on Mytrus; (c) to protect or defend the rights or property of Mytrus subpoenas or warrants served on Mytrus; (c) to protect or defend the rights or property of Mytrus
98 or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential
99 violation of the law or this Privacy Policy violation of the law or this Privacy Policy and in response to lawful requests by public authorities
100 . including to meet national security and law enforcement requirements.
101 INTERNATIONAL VISITORS INTERNATIONAL VISITORS
102 The Services are hosted in the United States and is intended solely for visitors located within the The Services are hosted in the United States and is intended solely for visitors located within the
103 United States and Canada. If you nonetheless choose to use the Services from the European United States and Canada. If you nonetheless choose to use the Services from the European
104 Union or other regions of the world whose laws governing data collection and use may differ Union or other regions of the world whose laws governing data collection and use may differ
105 from U.S. law, then please note that by submitting any personal information, you are transferring from U.S. law, then please note that by submitting any personal information, you are transferring
106 your personal information outside of those regions to the United States and that you consent to your personal information outside of those regions to the United States and that you consent to
107 such transfer. such transfer.
108 EU-U.S. PRIVACY SHIELD EU-U.S. PRIVACY SHIELD
109 Mytrus complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department Mytrus complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department Mytrus Privacy Policy, Updated March 21, 2017
110 of Commerce regarding the collection, use, and retention of personal information from European Mytrus, Inc. Page 4 of 6 of Commerce regarding the collection, use, and retention of personal information from European
111 Union member countries. Mytrus has certified that it adheres to the Privacy Shield Principles of Union member countries. Mytrus has certified that it adheres to the Privacy Shield Principles of
112 Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose
113 Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the
114 policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles
115 shall govern. To learn more about the Privacy Shield program, and to view our certification page, shall govern. To learn more about the Privacy Shield program, and to view our certification page,
116 please visit the following website: please visit the following website:
117 http://www.privacyshield.gov http://www.privacyshield.gov
118
119 Mytrus is subject to the investigatory and enforcement powers of the U.S. Federal Trade Mytrus is subject to the investigatory and enforcement powers of the U.S. Federal Trade
120 Commission (FTC) and the U.S. Food and Drug Administration (FDA). Commission (FTC) and the U.S. Food and Drug Administration (FDA).
121
122 As described in the Privacy Shield Principles, Mytrus is accountable for personal data that it As described in the Privacy Shield Principles, Mytrus is accountable for personal data that it
123 receives under the Privacy Shield Framework and subsequently transfers to third parties. If third receives under the Privacy Shield Framework and subsequently transfers to third parties. If third
124 parties that process personal data on our behalf do so in a manner that does not comply with the Mytrus Privacy Policy, Updated March 17, 2017 parties that process personal data on our behalf do so in a manner that does not comply with the
125 Mytrus, Inc. Page 4 of 6 Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for
126 the event giving rise to the damage. the event giving rise to the damage.
127 To review the Privacy Shield Principles, please visit the following web page: To review the Privacy Shield Principles, please visit the following web page:
128
129 https://www.privacyshield.gov/article?id=Requirements-of-Participation https://www.privacyshield.gov/article?id=Requirements-of-Participation
130
131 In compliance with the EU-US Privacy Shield Principles, Mytrus commits to resolving In compliance with the EU-US Privacy Shield Principles, Mytrus commits to resolving
132 complaints about your privacy and our collection or use of your personal information. European complaints about your privacy and our collection or use of your personal information. European
133 Union individuals with inquiries or complaints regarding this privacy policy should first Union individuals with inquiries or complaints regarding this privacy policy should first
134 contact Mytrus at: contact Mytrus at:
135 Mytrus, Inc. Mytrus, Inc.
136 105 E Street, Suite 2B 105 E Street, Suite 2B
137 Davis, CA 95616 Davis, CA 95616
138 USA USA
139 Phone: (530) 564-4600 Phone: (530) 564-4600
140 Email: privacy@mytrus.com Email: privacy@mytrus.com
141
142 Mytrus has further committed to refer unresolved privacy complaints under the EU-US Privacy Mytrus has further committed to refer unresolved privacy complaints under the EU-US Privacy
143 Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution
144 provider located in the United States and operated by the Council of Better Business Bureaus. If provider located in the United States and operated by the Council of Better Business Bureaus. If
145 you do not receive timely acknowledgment of your complaint, or if your complaint is not you do not receive timely acknowledgment of your complaint, or if your complaint is not
146 satisfactorily addressed, please contact BBB EU Privacy Shield at the following address: satisfactorily addressed, please contact BBB EU Privacy Shield
147
148 Council of Better Business Bureaus, Inc.
149 BBB EU Privacy Shield
150 3033 Wilson Boulevard, Suite 600
151 Arlington, VA 22201
152 U.S.A.
153
154 For more information on BBB EU Privacy Shield, please visit the following web page: using the following web page:
155
156 https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ https://www.bbb.org/EU-privacy-shield/for-eu-consumers/
157 Disputes may also be filed online from the following web page:
158
159 https://www.auto.bbb.org/eu-privacy-shield-complaint-form/
160
161 As further explained in the Finally, as a last resort and in limited circumstances, unresolved privacy complaints from EU
162 Privacy Shield Principles, binding arbitration will also be made individuals can be addressed before a Privacy Shield Panel, a binding arbitration
163 available to you in order to address residual complaints not resolved by any other means.
164
165 mechanism.
166 Mytrus Privacy Policy, Updated March 17, 2017 Mytrus Privacy Policy, Updated March 21, 2017
167 Mytrus, Inc. Page 5 of 6 A NOTE ABOUT CHILDREN Mytrus, Inc. Page 5 of 6 A NOTE ABOUT CHILDREN
168
169 We do not intentionally gather personal information from visitors who are under 13 years of age. We do not intentionally gather personal information from visitors who are under 13 years of age.
170 If a child under 13 years of age submits personal information to us and we learn that the personal If a child under 13 years of age submits personal information to us and we learn that the personal
171 information is the information of a child under 13 years of age, we will attempt to delete the information is the information of a child under 13 years of age, we will attempt to delete the
172 information as soon as possible. If you believe that we might have any personal information from information as soon as possible. If you believe that we might have any personal information from
173 a child under 13 years of age, please contact us at the following e-mail address: a child under 13 years of age, please contact us at the following e-mail address:
174 privacy@mytrus.com privacy@mytrus.com
175 YOUR CHOICES YOUR CHOICES
176 You have several choices regarding the use of information on our Services: You have several choices regarding the use of information on our Services:
177 Email Communications. If you are a medical practitioner or bioscience professional and you Email Communications. If you are a medical practitioner or bioscience professional and you
178 contact us via email, we may use your email address to send you email communications contact us via email, we may use your email address to send you email communications
179 about Mytrus and Mytrus products that are related to your practice, specialty and interests. about Mytrus and Mytrus products that are related to your practice, specialty and interests.
180 In the event that you choose not to receive any future communications, you may opt-out by In the event that you choose not to receive any future communications, you may opt-out by
181 clicking on the link provided at the bottom of each email communication. Despite your clicking on the link provided at the bottom of each email communication. Despite your
182 indicated e-mail preferences, we may send you service-related communications, including indicated e-mail preferences, we may send you service-related communications, including
183 notices of any updates to our Privacy Policy. notices of any updates to our Privacy Policy.
184 Changing or Deleting Your Personal Information. You may change Changing or Deleting Your Personal Information. Mytrus acknowledges the individual’s right to
185 access, modify, and delete his or her personal information. If the Site does not already provide
186 you with the ability to access, modify, or delete your personal information, you may request
187 any of the personal information you submitted to us by sending an e-mail to us at the e-mail address set forth below. You may request deletion of your personal information by us, and we will use reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). access to or changes to be made to any of the personal information you submitted to us by sending your request in e-mail to us at the e-mail address set forth below. You may request deletion of your personal information by us, and we will use reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). For example, applicable laws and regulations
188 may prevent your personal data from being deleted if that data was captured for the purpose of
189 When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud-prevention or similar purposes. your participation in a clinical research trial. When we delete any information, it will be deleted from the active database but it may remain in our archives. We may also retain your information for fraud-prevention or similar purposes.
190 SECURITY SECURITY
191 Mytrus is committed to protecting the security of your personal information. We use a variety of Mytrus is committed to protecting the security of your personal information. We use a variety of
192 industry-standard security technologies and procedures to help protect your personal information industry-standard security technologies and procedures to help protect your personal information
193 from unauthorized access, use, or disclosure. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Mytrus uses reasonable efforts to protect your personal information, Mytrus cannot guarantee its absolute security. from unauthorized access, use, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Mytrus uses reasonable efforts to protect your personal information, Mytrus cannot guarantee its absolute security.
194 Mytrus Privacy Policy, Updated March 21, 2017
195 THIRD-PARTY WEBSITES Mytrus, Inc. Page 6 of 6 THIRD-PARTY WEBSITES
196 Our Site may contain links to third-party websites. When you click on a link to any other website Our Site may contain links to third-party websites. When you click on a link to any other website
197 or location, you will leave our Site and go to another site, and another entity may collect or location, you will leave our Site and go to another site, and another entity may collect
198 information from you. We have no control over, do not review, and cannot be responsible for, information from you. We have no control over, do not review, and cannot be responsible for,
199 these outside websites or their content. Please be aware that the terms of this Privacy Policy do these outside websites or their content. Please be aware that the terms of this Privacy Policy do
200 not apply to these outside websites or content, or to any collection of your personal information not apply to these outside websites or content, or to any collection of your personal information
201 after you click on links to such outside websites. We encourage you to read the privacy policies Mytrus Privacy Policy, Updated March 17, 2017 after you click on links to such outside websites. We encourage you to read the privacy policies
202 Mytrus, Inc. Page 6 of 6 of every website you visit. The links to third party websites or locations are for your convenience of every website you visit. The links to third party websites or locations are for your convenience
203 and do not signify our endorsement of such third parties or their products, content, or websites. and do not signify our endorsement of such third parties or their products, content, or websites.
204 CHANGES AND UPDATES TO THE PRIVACY POLICY CHANGES AND UPDATES TO THE PRIVACY POLICY
205 From time to time, we may revise this Privacy Policy. To help you stay informed of any changes, From time to time, we may revise this Privacy Policy. To help you stay informed of any changes,
206 we note the date that the Privacy Policy was last updated on the first page of this document and we note the date that the Privacy Policy was last updated on the first page of this document and
207 in the header of each subsequent page. Your use of the Services following the posting of any in the header of each subsequent page. Your use of the Services following the posting of any
208 revised Privacy Policy shall be deemed acceptance of the revised policy. If you disagree with the revised Privacy Policy shall be deemed acceptance of the revised policy. If you disagree with the
209 provisions of this Privacy Policy, your sole remedy is to terminate your use of the Services. provisions of this Privacy Policy, your sole remedy is to terminate your use of the Services.
210 CONTACT CONTACT
211 If you have any questions regarding privacy while using the Services, or have questions about If you have any questions regarding privacy while using the Services, or have questions about
212 Mytrus’s practices, or wish to review or update your information, please contact Mytrus at: Mytrus’s practices, or wish to review or update your information, please contact Mytrus at:
213 Mytrus, Inc. Mytrus, Inc.
214 105 E Street, Suite 2B 105 E Street, Suite 2B
215 Davis, CA 95616 Davis, CA 95616
216 USA USA
217 Phone: (530) 564-4600 Phone: (530) 564-4600
218 Email: privacy@mytrus.com Email: privacy@mytrus.com