Last modified: 1st October 2018

INTRODUCTION.

AutoCruitment LLC ("Company" or "We" or “AutoCruitment”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the websites https://trials.autocruitment.com, or https://autocruitment.com(collectively, the "Site(s)"), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect on this Site, or in email, text, and other electronic messages between you and this Site. This policy also describes your choices regarding use, access and correction of your personal information.

Our Sites allow you to provide us with information through a screening form (“Form”) which enables us to recruit, screen, and refer patients for clinical trials and specialty procedures (the “Programs”) to hospitals, private practices, cancer centers, pharmaceutical companies, CROs, and biotech or pharmaceutical companies, (collectively, “Researchers”). If by filling out a Form you are matched to a particular Program, Researchers may contact you. We are not responsible for any direct communications or any information that the Researchers may collect from you directly. 

This policy does not apply to information collected by us offline or through other means, including any other website operated by AutoCruitment, or any third parties that may link to or be accessible or recommended from or on the Site. Please review the privacy policies of these third parties to familiarize yourself with their practices. AutoCruitment operates globally, and this means we may transfer your personal data outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal data. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites. By accessing or using the Sites, you agree to this Privacy Policy.

EU-U.S. and Swiss-U.S. Privacy Shield

AutoCruitment participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. AutoCruitment is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]

AutoCruitment is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. AutoCruitment 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 receivedortransferred pursuant to the Privacy Shield Frameworks, AutoCruitment is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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 [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. 

CHANGES TO OUR PRIVACY POLICY.

This policy may change from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Sites’ home page. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

CHILDREN UNDER THE AGE OF 13.

Our Sites are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features, register on the Site, or provide any information about yourself to us, including your name, address, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information as soon as possible. We collect information data about children voluntarily provided from the parents.

COLLECTION OF INFORMATION. 

Information you Provide to Us

We collect several types of information from and about users of our Sites, including: 

·      Personal Information. When you register through the Sites and fill out a Form we may collect certain information about that you that can be used to identify you such as: name; home or work address; date of birth; email address; religious beliefs; sexual orientation or preferences; medical history; or home, work or mobile telephone number; and  

·      Other information you provide. We may also collect certain other information about you when you contact us through our Sites or through email or any other means, which may be used alone or combined with other information collected by us to personally identify you.

We collect this information directly from you when you provide it to us by filling out a Form, creating an account on the Sites, or when you contact us.

Information We Collect Automatically Through your Use of the Sites

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·      Details of your visits to our Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Sites;

·      Information about your computer and internet connection, including your IP address, operating system, and browser type; and 

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized service. The technologies we use for this automatic data collection may include:

·      Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. 

·      Google Adwords and Facebook Ads. Our Sites utilize remarketing services through Google Adwords and Facebook Ads to help us better serve our audience and advertise our services across the Internet. Based on information that we automatically collect and information that you provide to us, we may display targeted banner ads tailored to you based on your previous interactions with our Sites. Google and Facebook may also display targeted ads tailor made for you on outside sites based on your previous interactions with our sites. We may also send you an email encouraging you to complete a previously abandoned donation form, or to return to a previously visited website offering events or content, both audio and digital. You may opt out of Google Remarketing Ads and Facebook Ads on their websites;

·      Blog/Forum.Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@autocruitment.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

·      Links to Third Party Websites.Our website includes links to other websites whose privacy practices may differ from those of AutoCruitment. If you submit personal information to any of those websites, your information is governed by their privacy statement. We encourage you to carefully read the privacy policy of any website you visit.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Sites are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

HOW WE USE YOUR INFORMATION.

Any personal information you voluntarily provide to us in a Form on our Sites is used to enable the Researchers to contact you about Programs, but only with your consent. We may also use information that we collect about you or that you provide to us, including any personal information: 

·      To present our Site and its contents to you;

·      To provide interest-based advertising to you;

·      To respond to your questions or requests;

·      To contact you about Programs, and any news or offerings about the Programs or Sites; 

·      To notify you about changes to our Site or any support we offer or provide though it;

·      In any other way we may describe when you provide the information; and 

·      For any other purpose with your consent.

If you do not want us to use your information to contact you about our products, support, or services, please adjust your user preferences in your account profile.

DISCLOSURE OF YOUR INFORMATION.

We may disclose aggregated information about our users. We may disclose personal information that we collect or you provide as described in this privacy policy: 

·      To our subsidiaries and affiliates; 

·      To contractors, service providers, and other third parties we use to support our business; 

·      To Researchers if you have opted in to be contacted about Programs;

·      To fulfill the purpose for which you provide it;

·      To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Sites is among the assets transferred;

·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request. If AutoCruitment is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information; and/or

·      With your consent.

We may also disclose your personal information to enforce or apply our Terms of Use other agreements, including for billing and collection purposes, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AutoCruitment, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

·      Tracking Technologies and Advertising. We and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly; 

·      Promotional Offers from AutoCruitment. If you do not wish to have your contact information used by AutoCruitment to promote our Programs, you may update your email preferences by using the “unsubscribe” link found in emails we send to you or please contact us at info@autocruitment.com.

·      Targeted Advertising. Currently, our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, do not opt-in on the Form. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (http://www.aboutads.infoand http://www.networkadvertising.org) and if located in European Union, visit the Your Online Choices website (http://www.youronlinechoices.eu/). Please note that if you choose to opt out, you will continue to see ads on our Sites, but they will not be based on how you browse.

ACCESSING AND CORRECTING YOUR INFORMATION.

Upon request AutoCruitment will provide you with information about whether we hold any of your personal information. To access, modify, correct or remove any personal information that you have provided to us, you may email us at info@autocruitment.com, or select the “Contact Us” link on the Sites. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will respond to your request within a reasonable timeframe [30 days].

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

RETENTION PERIOD.

To access, modify, correct or remove any personal information that you have provided to us, you may email us at info@autocruitment.com, or select the “Contact Us” link on the Sites. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will respond to your request within a reasonable timeframe [30 days].

DATA SECURITY.

We have implemented reasonable security measures designed to protect your personal information from accidental loss, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites. If you have any questions about the security of your personal information, you can contact us at info@autocruitment.com.

CALIFORNIA PRIVACY RIGHTS.

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@autocruitment.com.

CONTACT INFORMATION.

To ask questions or comment about this privacy policy and our privacy practices, or to close your account on the Sites, contact us at info@autocruitment.com, select the “Contact Us” link on the Sites, or call us at (404) 334-3689.

AutoCruitment LLC
101 Avenue of the Americas, 8thfloor
New York, NY 10013  

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