Privacy Policy

Effective Date: January 1, 2023

General

We are Gray Consulting, Inc. dba Clincierge® (“we,” “us,” “Clincierge,” or “Gray Consulting”). Clincierge provides travel and lodging assistance, expense management, administrative, and other specialized solutions to clinical trial (“Trial”) participants (including, as appropriate, their caregivers) (collectively, “Trial Participants”) on behalf of our clients, which include Trial sponsors, Contract Research Organizations (CROs), and Trial sites (e.g., a hospital or clinic) (collectively, “Clients”). The services that we provide through Clincierge are collectively referred to herein as our “Services.” This Privacy Policy applies to the information collected online at www.clincierge.com (our “Website”) as well as to information collected by us offline in connection with our Services.

We have taken efforts to distinguish between the categories of individuals whose information we collect – namely, Trial Participants, Client business contacts, and Website visitors (who may also be Trial Participants or Client business contacts). In some cases, however, our activities apply generally. Thus, use of the terms “you” or “your” herein refers to all persons whose information we collect, whether a Trial Participant, Client business contact, or other individual.  

Finally, note that our practices involving your information are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this Privacy Policy in a particular country or region to the extent permitted under the laws of those places.

Information We Collect

Identity and contact information. When you contact us through our Website or otherwise reach out to us, we collect contact and other information including first and last name, company name, mailing address, email address, phone number, job title, information relating to a Trial Participant’s travel plans to and from the Trial, any other information that a Trial Participant chooses to provide to us, such as health-related information needed for special accommodations or other aspects of our Services. When you apply for a job with us, we request your contact information and information about your employment and education history. We may also request information such as your Social Security number in order to perform a background check.

Financial and payment information. We may collect certain financial and payment information including your bank account number and other data necessary for processing payments, including credit/debit card numbers and other related billing information.

Business information. We may collect information provided in the course of a contractual relationship between you or your organization and Clincierge, or otherwise voluntarily provided by you or your organization.

Website usage data. We may collect information about how you use our website, including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as mouse movements and clicks). To learn more about our use of cookies or similar technology, please see our Cookie Notice.

Technical data. We may collect information during your visits to our website such as the Internet Protocol (IP) address, device type, and location data.

How We Collect Your Information

The circumstances in which we collect personal data about you include:

  • when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including in conversation with our personnel;
  • when you browse our website, complete a contact form on our website or otherwise interact with our website (for example, subscribe to marketing emails);
  • when you or your organization offer or provide services to us.

How We Use Your Information

We use the information that we collect from you to provide our Website and Services; to respond to general inquiries; to solicit feedback regarding our Website and Services; to provide relevant content on our Website; to send invoices and receive payments; to maintain and improve our Website and Services; and to communicate with you regarding the Trials for which Trial Participants have registered.

In addition to collecting your information for the purposes described above, we also use your information:

  • to protect our interests or the interests of third parties;
  • to maintain and enhance the security of our Services;
  • to prevent abuse of our Services;
  • to comply with our legal obligations;
  • to perform or enforce our agreements;
  • for any other purpose with your consent.

Transfers to Third Parties

We may share personal information related to Trial Participants with our Clients in connection with the administration of Trials. For some Clients, only deidentified/pseudonymized data is shared. With a Trial Participant’s prior approval, we may share personal information with such Trial Participant’s bank for reimbursement of Trial expenses, to the extent such function has been designated to us as part of our Services to the applicable Client.

We may disclose personal information to service providers to the extent needed to enable them to support our Services. For example, we may share a Trial Participant’s personal information with our travel assistance and logistics partners, so that they may book transportation or accommodation on such Trial Participant’s behalf in connection with a Trial. Other third parties that may receive your personal information include: direct marketing vendors, billing support, customer service, data storage and hosting services, sales support, and technical support vendors.

Cookies

Please see our Cookie Notice for more information.

Aggregated Data

In an ongoing effort to better understand the visitors to our Website and the recipients of our Services, we may analyze information in aggregate or in “de-identified” form, to operate, maintain, manage, and improve our Website and Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners, including, without limitation, our Clients. We may also disclose aggregated user statistics in order to describe the Website or the Services to current and prospective business partners and to other third parties for other lawful purposes.

Related Entities; Business Transfers

We may share your personal information with any companies under common control with us.

In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity.

Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation, including, but not limited to, in response to court orders and subpoenas.

Retention of Personal Information

We will only retain your personal information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized, or as otherwise permitted by law. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

If you want to learn more about our specific retention periods for your personal information established in our retention policy you may contact us at compliance@clincierge.com.

How We Protect Your Personal Information

We will implement reasonable and appropriate security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing, the nature of such data, and applicable laws and regulations.

Children

We do not knowingly collect any personal information from children, as defined under applicable law, through our Website or Services. If you have reason to believe that your child has provided personal information to us, please contact us at compliance@clincierge.com so that we can delete that information from our databases.

Links to External Websites

Our Website may contain links to third-party websites, including, without limitation, those of Clients (“External Sites”). We have no control over the privacy practices of these External Sites and are not responsible for their privacy policies or practices. You should check the applicable third party’s privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.

Important Notice to Non-US Residents

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Your decision to provide such data to us, or to allow us to collect such data through our Website or through the provision of our Services, constitutes your consent to this data transfer to the extent permitted under applicable law.

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on our Website as soon as they go into effect. Where changes to this Privacy Policy are material, we will notify you in accordance with applicable law.

California Residents

The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”). These disclosures apply to individuals who reside in the State of California and supplement any other privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of Clincierge. Any terms defined in the CCPA have the same meaning in this notice.

Right to Know

California residents have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected,  used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information. 

The below chart reflects the categories of personal information we have collected from California residents, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties with whom we disclosed that information, and our anticipated retention period for each category of information.

Personal Information Category set forth in Cal. Civ. Code § 1798.140 Source(s) of Personal Information Collection Business or Commercial Purpose(s) for Collection/Use Third Parties Receiving Personal Information Category Retention Period

Personal Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

You; Clients; Third-party sources; Our Website; Publicly available information, Devices you use to access the Website or our Services; Recruiters and background check providers (for job applicants).
Provide our Services to you; Respond to questions; Provide you with information about our Services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; For research, analysis, and development; To evaluate or process a commercial transaction; As required by applicable law or government regulation; Conduct hiring and/or other human resources activities (for job applicants); To assess applications (for job applicants).
Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Technology services; Background check providers (for job applicants); Human Resources providers (for employees).
The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or seven years post-relationship, whichever is longer.

California Customer Records personal information (Cal. Civ. Code §  1798.80(e)), including name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

You; Clients; Third-party sources; Our Website; Publicly available information; Devices you use to access the Website or our Services; Recruiters and background check providers (for job applicants).
Provide our Services to you; Respond to questions; Provide you with information about our Services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; To evaluate or process a commercial transaction; As required by applicable law or government regulation; To collect and process applications (for job applicants).
Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Social networks; Technology services; Background check providers (for job applicants); Human Resources providers (for employees).
The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or seven years post-relationship, whichever is longer.

Characteristics of protected classifications under California or federal law. 

You; Clients; Recruiters and background check providers (for job applicants).
To provide you with our services and respond to your questions; To understand the products and services considered by our customers and to make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services; To collect and process applications for employment (for job applicants).
Background check providers (for job applicants); Affiliates; Human resources providers (for employees).
The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or six years post-relationship, whichever is longer.

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We do not collect.
N/A
N/A
N/A

Biometric information

We do not collect.
N/A
N/A
N/A

Internet or other electronic network activity information, including but not limited to, browsing history, search history, information on interactions with an internet website, application, or advertisement.

You; Devices you use to access the Website or our Services; Advertising networks; Internet service providers; Data analytics providers.
To provide you with our Services and respond to your questions; To make improvements to our offerings; To provide advertising/marketing services, analytic services, or similar services; To identify and repair errors that impair existing or intended functionality; To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity; To collect and process applications for employment (for job applicants).
Advertising networks. Affiliates; Data analytics providers; Marketing platforms; Recruitment platforms; Social networks; Technology services.
Barring any legally required additional retention period, up to two years.

Geolocation data

You using accounts owned or controlled by us (for employees).
Protect and secure our workforce and environment.
Technology services (for employees).
The time period the geolocated device is managed by us (for employees).

Sensory data, including audio, electronic, visual, thermal, olfactory, or similar information.

You (for employees).
To conduct human resource activities, including but not limited to training and development (for employees).
Human Resources providers (for employees).
Up to six years after discontinued use or any legally required retention period for this category of personal information, whichever is longer (for employees).

Professional or employment-related information

You (for employees); Background check providers (for job applicants); Publicly available information.
Conduct hiring and/or other human resources activities (for job applicants and employees).
Affiliates; Recruitment platforms; Technology services; Background check providers (for job applicants); Human Resources providers (for employees).
Barring any legally required additional retention period, up to seven years for non-hired applicants.

Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99)

You (for job applicants and employees); Recruiters (for job applicants).
To collect and process applications (for job applicants); Conduct hiring and/or other human resources activities (for job applicants and employees).
Background check providers (for job applicants); Human Resources providers (for employees).
Barring any legally required additional retention period, up to seven years for non-hired applicants.

Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitude, intelligence, abilities, and aptitude.

We do not collect.
N/A
N/A
N/A
Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140 Sources from which Information was Collected Purposes for Collection/Use Third Parties, Service Providers, and Contractors Receiving Personal Information Retention Period

Social security number, driver’s license number, state identification card, or passport number.

You; Clients; Recruiters and background check providers (for job applicants).
Provide our Services to you; To collect and process applications for employment (for job applicants); Satisfy legal obligations.
Background check providers (for job applicants); human resources providers (for employees).
Barring any legally required additional retention period, up to seven years for non-hired applicants.

Account access credentials (user names, account numbers, or card numbers combined with required access code, security code or password to access an account).

For accounts owned or controlled by us (for employees).
To protect and secure our workforce and environment (for employees).
We do not share.
The length of your employment (for employees).

Precise geolocation (location within a geographical area of a circle with a radius of 1850 feet or less).

From devices owned or controlled by us (for employees).
To protect and secure our workforce and environment (for employees).
We do not share.
The time period the geolocated device is managed by us (for employees).

Racial or ethnic origin

You (for job applicants and employees), only if you voluntarily provide to us.
For diversity and inclusion initiatives.
We do not share.
The length of your business relationship with us.

Religious or philosophical beliefs

You (for job applicants and employees), only if you voluntarily provide to us.
For diversity and inclusion initiatives.
We do not share.
The length of your business relationship with us.

Union membership

We do not collect.
N/A
N/A
N/A

Genetic Data

We do not collect.
N/A
N/A
N/A

Mail, email, or text messages where the content is not directed to us.

From devices or accounts owned or controlled by us (for employees).
To protect and secure our workforce and environment (for employees).
We do not share.
The length of your employment plus any legally required retention period for this category of personal information post-employment or up to three years post-employment, whichever is longer (for employees).

Unique identifying biometric information

We do not collect.
N/A
N/A
N/A

Personal information collected and analyzed concerning health.

We do not collect.
N/A
N/A
N/A

Personal information collected and analyzed concerning sex life, or sexual orientation.

We do not collect.
N/A
N/A
N/A

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also do not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

Right to Opt Out of Sharing for Cross-Context Behavioral Advertising

In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to advertising networks, data analytics providers, and social media networks for this purpose:

  • Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information, including browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.

We disclosed these categories of information to these third parties in order to provide advertising/marketing services, analytic services, or similar services.

If you would like to opt out of this sharing, you may exercise your right by modifying your cookie settings, or you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, click here. You may also contact us as set forth in the “Exercising Your Rights” section below.

Right to Opt-Out of Sale

While we do not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include actives such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have shared the following categories of information with advertising networks, data analytics providers, social media networks, and web mapping platforms, which could be considered a “sale” under California law:

  • Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information, including browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.

We disclosed these categories of information to these third parties in order to provide our Website and Services; perform analytics; and to maintain, improve, upgrade, or enhance our Services.

We have no actual knowledge of selling the personal information or the sensitive personal information or minors under 16 years of age.

If you are a California resident and would like to opt out of the “sale” of your personal or sensitive information.

If you would like to opt out of such disclosures, you may exercise your right by modifying your cookie settings, or you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, click here. You may also contact us as set forth in the “Exercising Your Rights” section below.

Right to Delete Personal Information

California residents have the right to request deletion of the personal information we have collected from them, subject to certain exceptions.

Right to Correct Inaccurate Personal Information

California residents have the right to request the correction of any inaccurate personal information that we maintain about them.

Right to Access

California residents have the right to request the categories and specific pieces of personal information we have collected about them.

Right of Non-Retaliation and Non-Discrimination

California residents have the right to not receive discriminatory treatment for exercising their CCPA privacy rights. We do not discriminate against California residents who exercise these privacy rights conferred to them under the CCPA.

Exercising Your Rights

California residents can exercise their rights by calling 1-888-458-8579 or by contacting us as set forth below in the “How to Contact Us” section. Requestors will need to provide us with personal information for us to match with the information we have on file in order to verify their identity and residency, including name, email address, state of residence, and request details. We will compare the information you provide with our internal records. The personal information that we use to verify identity and residency will not be used for any other purpose.

You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. We may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

Nevada Residents

Nevada consumers may opt-out of the “sale” of “covered information” as such terms are defined under Nevada law. We do not currently sell data triggering that statute’s opt-out requirements, but if you have questions about this you can email us at compliance@clincierge.com.

GDPR Privacy Notice

General

This General Data Protection Regulation (GDPR) privacy notice (this “GDPR Notice”) is included in and supplements our Privacy Policy and applies to the “personal data”, as defined in the GDPR, of natural persons located in the United Kingdom or European Economic Area processed by Clincierge (collectively, “European Individuals,” “you,” or “your”). Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them elsewhere in the Privacy Policy or, if not defined herein or elsewhere in the Privacy Policy, the GDPR. To the extent of any conflict between this GDPR Notice and any other provision of the Privacy Policy, this GDPR Notice shall control only with respect to European Individuals and their personal data.

Processor Disclosure

We typically serve as a data processor (a “processor”) when providing our administrative and logistics support in connection with Trials on behalf of our Clients, such as transportation and expense management services to Trial Participants, Trial Participant caregivers, or medical staff. When serving as a processor, we have certain obligations under the GDPR including only processing personal data at our Clients’ documented instructions, providing assistance with fulfilment of rights requests, and implementing appropriate security for personal data. Our Clients are responsible for obtaining any required consents or authorizations for a European Individual’s use of our Services; in many cases, Clincierge will provide a draft “consent form” to our Clients, as reviewed and approved by such Clients, and provide such consent form to Trial Participants who are European Individuals on such Clients’ behalf. We will forward any inquiries, complaints, or requests received from European Individuals with respect to our Services to the appropriate Clients and await instructions before taking any action.

Controller Disclosure and Details

We are a data controller of personal data for the purposes and under the legal bases described in the table below regarding the following categories of European Individuals:

  • Business contacts for European-based Clients, vendors and contractors (collectively, “Business Contacts”);
  • Trial Participants, when Clients ask us to determine the purpose and means of processing of their personal data;
  • Visitors to our website.

When acting as a data controller we decide why and how personal data relating to Business Contacts, Trial Participants, and website visitors is processed.  

Business Contacts. The personal data described below is provided to us either in the course of your performance of contractual duties for the organization for whom you work or on a voluntary basis in the course of your general business dealings with us (or your colleagues within your organization, such as those that provide your contact details as appropriate for the dealings in question or from third parties who may recommend you).  Depending on the applicable legal basis, if this data is not provided to us, then we may be unable to perform certain contractual obligations or communicate effectively.

Trial Participants. We process Trial Participants’ personal data in order to facilitate their housing, travel arrangements, and reimbursements as further described in the study-specific Data Protection Notice provided to each Trial Participant.

Website visitors. When visiting our website users are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see our Cookie Notice for more information.

Purposes of Collection and Use / Legal Bases for Processing

Purpose Legal Basis
Establishment and management of our relationship with Business Contacts and Trial Participants
We process your personal data based on our contractual relationship or our legitimate interest. When processing based on legitimate interest, we shall make a balance between our legitimate interest and your rights and interests. Depending on the applicable legal basis, if this data is not provided to us, then we may be unable to perform certain contractual obligations or enter in a contract with you.
Compliance with legal or regulatory obligations (e.g. maintaining records)
We process your personal data as it is necessary for compliance with a legal obligation to which we are subject.
Communicating with you when receiving an information request via the contact form on our Website or other channels
We process your data based on your consent.
Communicating with you in order to keep you up-to-date on the latest developments, and other information about our Services (including marketing emails and newsletters), events and initiatives
We process your personal data based on your consent or in certain cases on our legitimate interest (when we have a previous contractual or a business relationship with you and send you marketing communications about similar services). In cases where processing is based on our legitimate interest, we shall make a balance between our legitimate interest and your rights and interests.
Website UX design optimization
We collect information about the website usage based on your consent.
Serving ads
We process your personal data gained via cookies based on your consent.

The contact for our data protection officer and our representative in the European Union is:

CRANIUM International Holding NV
Excelsiorlaan 43, 1930 Zaventem,Belgium
Phone: +32 2 310 39 63
Email: be-info@cranium.eu
Website: https://www.cranium.eu/

Recipients

Clincierge personnel shall receive and process your personal data for the purposes described herein. Such personal data may be disclosed to the following recipients in connection with these purposes:

  • third parties that perform services for us (e.g. companies that assist us in marketing activities or IT operations);
  • internal and external auditors and our legal and other professional services providers;
  • cloud hosting providers;
  • public authorities or third parties pursuant to an order from public authorities;
  • analytics companies may access anonymous data (such as your IP address or device ID) to help us understand how our Services are used;
  • potential acquirers of the company: in case (a part of) our business is sold to a third party, your data may be shared with the acquirer.

Retention

The length of time for which we retain your personal data is determined by several factors including the purposes for which we use that information and our obligations under applicable laws.

We may need your personal data to establish, bring, or defend legal claims. In general, given this purpose, we typically retain your personal information for seven (7) years from the end of the year in which we receive it. The exceptions to this are where:

  • the law (including a court, regulator, or other authority) requires us to hold your personal information for a longer period or delete it sooner;
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
  • we bring or defend such legal claim or other proceedings during the period we retain your personal data, in which case we will retain your personal data until those proceedings have concluded and no further appeals are possible; or
  • the personal data is no longer reasonably necessary, in our discretion, for the purposes discussed herein (in which case we may delete such information).

Your GDPR Rights

As a European Individual you have a right to, where applicable and in accordance with the GDPR,: (i) request access to, rectification and/or erasure of your personal data; (ii) object to processing of your personal data; (iii) restrict processing of your personal data, (iv) data portability (v) withdraw your consent without affecting the lawfulness of the processing abased on consent before its withdrawal. You may exercise these rights by contacting: compliance@clincierge.com with the subject line “GDPR Notice.” We will reply to your request to exercise your right in accordance with the GDPR.

You also have the right to lodge a complaint about the processing of your personal data with an appropriate data protection authority, and, as applicable, to exercise third-party beneficiary rights under Clincierge’s Standard Contractual Clauses.

Contact details for the EU data protection authorities can be found at: https://edpb.europa.eu/about-edpb/board/members_en and for the UK data protection authority can be found at https://ico.org.uk/global/contact-us/.

Objecting to Legitimate Interest/Direct Marketing

You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims.

We will only provide you with marketing-related information when we have a previous contractual relationship or a business relationship with you and provided you do not opt-out to receive those communications. You may object at any time to the processing of your personal data for direct marketing purposes (including profiling related to such direct marketing) by clicking “Unsubscribe” within an automated marketing email or by submitting your request to privacy@clincierge.com with the subject line “GDPR Notice” (the latter for instances where, for example, you would not like to receive follow-ups from our sales team). We do not engage in direct marketing to Trial Participants.

If you have provided your consent to the collection, processing, and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

To opt out of receiving our marketing communications, please click “Unsubscribe” within an automated marketing email or by submitting your request to compliance@clincierge.com with the subject line “GDPR Notice”.

Transfer of Personal Data Outside the UK or EEA

Clincierge may transfer personal data to recipients outside of the EEA and the UK, in particular to the US. In addition, Clincierge may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

For international data transfers, we rely on appropriate Standard Contractual Clauses to ensure adequate protection for your personal data or a derogation under Article 49 of the GDPR (such as when you give us your explicit consent). For more information or a copy of these safeguards, please contact us at compliance@clincierge.com.

Updates to this GDPR Notice

If in the future, we make any material changes to this GDPR Notice relating to our controller obligations, we will provide you with the relevant information at a reasonable time prior to those changes taking effect and the “Effective Date” at the top of this page will be updated accordingly

How to Contact Us 

Clincierge is located at 190 N. Independence Mall West, Suite 201 Philadelphia, PA 19106. Please use this address or email compliance@clincierge.com regarding any questions, complaints, or requests regarding our privacy practices or this policy.

Voice of the Patient Research

View the results of our recent research to explore how effective patient support strategies can reduce barriers, increase retention, and improve outcomes in rare disease clinical trials in our latest eBook.

Voice of the patient