Privacy & Legal
Privacy Shield
Privacy Shield Framework
CMI complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries, the United Kingdom and Switzerland to the United States in reliance on Privacy Shield. CMI has certified that it adheres to the EU-U.S. Privacy Shield Framework and the Swiss- U.S. Privacy Shield Framework and the Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability, as set forth by the US Department of Commerce. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.
This Policy applies to the processing of Personal information that CMI receives in the United States concerning individuals who reside in Switzerland and the EEA. This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes to prevent identification of individual persons).
If there is any conflict between the provisions in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.Scope
Definitions
For the purposes of the Policy, the following definitions shall apply:
- “Data Processor” means any third party processing personal information on behalf of, and under the instruction of CMI.
- “European Union” or “EU” means for the purposes of this Policy all countries within the European Economic Area (EEA).
- “Clinical Trial Participant” means an individual participating in a clinical trial in the EU and providing personal information to third parties CMI has contracted with to conduct the study. Clinical Trial Participant has the same meaning as “Data Subject” under Article 4 of the GDPR.
- “Pseudonymised Data” means Personal Data that can no longer be attributed to a specific individual in the EU without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an individual. CMI will protect Pseudonymised Data subject to the GDPR with the same care and high standards as Personal Data.
- “Anonymous Data” is information which does not relate to an identified or identifiable natural person or personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. The GDPR does not concern the processing of Anonymous Data.
- “Clinical Trial Data” is the data collected and processed by CMI for clinical trial purposes. It includes Pseudonymised Data received from third parties as well as new data generated by CMI and third parties based on data collected for the clinical trial. These new data may not relate to an identified or identifiable natural person.
- “Principle”: the Department of Commerce is issuing these Privacy Shield Principles, including the Supplemental Principles (collectively “the Principles”).
- “Personal data” and “Personal Information” means data about an identified or identifiable individual that are within the scope of the Directive, received by CMI in the United States from the European Union, and recorded in any form. It does not include personal information that has been anonymized or that is publicly available, that has not been combined with non-public personal information.
- “Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
- “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns health or sex life. In addition, CMI will treat as sensitive, any information received from a third party where that third party treats and identifies the information as sensitive.
Privacy principles
Notice
Where CMI collects Personal Information directly from individuals in the EU, the United Kingdom or Switzerland, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to whom CMI discloses that information, and the choices and means, if any, that CMI offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language, when individuals, are first asked to provide Personal Information to CMI, or as soon as practical thereafter, and in any event before CMI uses the information for a purpose other than that for which it was originally collected.
Where CMI receives Personal Information from its subsidiaries, affiliates or other entities in the EU, the United Kingdom or Switzerland, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to who such Personal Information relates.During the conduct of its operations, Concept Medical Inc. (CMI) may collect and process personal information relating to:
- Study participants: The collection of Personal Information such as contact information, qualifications, debarment status, and account information is to facilitate the proper conduct of research studies and to carry out other study-related services. Information collected may be transferred to third-party service providers performing study-related duties and may furthermore be transferred to regulatory authorities.
- Customers, vendors, and consultants: CMI keeps contact information, account numbers, and information relating to billing, together with other information necessary for the daily operation of CMI’s services. This includes conducting customer, product, and service surveys; direct marketing of products and services; handling customer complaints and enquiries; making disclosures under the requirements of applicable laws; and addressing any other directly related matters.
- Human resources data: Information such as curriculum vitae, contract information, residential address, date of birth, gender, government identification number, account information, qualifications, training records, debarment status, and performance reviews is processed to support CMI’s human resources functions. These include the administration of employee benefits, compensation, management of employee performance, business planning, disciplinary procedures (including the investigation and reporting of complaints), and compliance with legal obligations, policies, and procedures.
Clinical Trial
- Keeping your Personal Data confidential and secure.
- Using and disclosing your data for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation.
Categories of Third Parties Engaged by CMI for Clinical Trials
- Wholly owned subsidiaries/Affiliates of CMI
- Contract Research Organisations (CROs)
- Statistical Research Analysts
- Clinical advisors
- Technical providers for hosting and software services
- Safety boards
Choice
Accountability for onward transfer
(i) transfers such data only for limited and specified purposes; (ii) has ascertained that the Data Processor is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) takes reasonable and appropriate steps to ensure that the Data Processor effectively processes the Personal Information transferred in a manner consistent with the CMI’s obligations under the Principles; (iv) requires the Data Processor to notify CMI if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), CMI will take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) will provide a summary or a representative copy of the relevant privacy provisions of its contract with that Data Processor to the Department of Commerce upon request.
Security
Data integrity and purpose limitation
Access and correction
Verification
Recourse, enforcement and liability
Limitation on scope of principles
Changes to this policy
Contact information
Attention: Privacy department
Concept Medical B.V.
Hogebrinkerweg 33, 3871KM Hoevelaken, The Netherlands.
privacy@conceptmedical.com.
Privacy Policy
- Purpose: Your privacy is very important to us. This Notice sets out the way in which we process your information when you use our Website or other digital platforms in accordance with data protection laws.
- Applicability: This Notice applies to individuals visiting our Website. It applies only to the information we collect through our Website, in email, text, forms, and other electronic communication received through or in connection with our Website.
Information We May Process (“Personal Data”)
We may collect your personal data including but not limited to
- Various usage and user metrics when you visit and use our Website including but not limited to cookies, IP addresses, device and software identifiers, referring and exiting URLs, onsite behaviour and usage information, feature use metrics and statistics, usage history, and location data. While some of this data is captured directly from you, for example, by way of web forms and web log servers, others can be captured indirectly from third parties, for example, tracing organization details, preferences, and interests on the basis of IP address and browsing history respectively.
- Information that you provide to us for the purpose of registering to use the Website, subscribing to the Company’s service, posting material, requesting further services and/or applying for a position of employment with us, including but not limited to your job title, name, address, telephone number, e-mail address, social media profile, curriculum vitae / resume, skillset, preferences, and interests.
- Information that you provide to us by completing any other forms on the Website or if you contact us with comments or specific requests (including but not limited to your name, address, telephone number, and e-mail address). We may also ask you for information when you report a problem with the Website.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Means of Processing Data
We may process your Personal Data through the following means:
- Cookies
- Web job application forms/careers applications
- Web forms
- Newsletter sign-ups
- Registration for an event/activity
- Information request mechanism (for example, Contact Us).
COOKIES
Our Website uses these cookies to collect information and to improve our Service by making your interaction with us faster and more secure. They may be used for the purposes of managing your preferences, maintaining and optimizing security, marketing, communication, analytics, and research.
- Essential Cookies or Strictly Necessary Cookies: These cookies are essential to the functioning of our Website and for you to move around the Website. Without these cookies, certain features could not function. No information about your browsing habits is gathered by these cookies.
- Functional Cookies: These cookies remember how you prefer to use our Website and improve the way our Website works. These are persistent cookies that help us recognize you as an existing user, so it’s easier for you to return to our Website without signing in again. After signing in, the persistent cookies stay on your browser and will be read when you return to our sites. These remain on your computer/device for a pre-defined period of time.
- Performance Cookies: Some cookies help us with the performance and design of our Website. For example, these cookies show us statistics, which are the most frequently visited pages on the Website, help us record any difficulties you have with the Website, and whether our advertising is effective or not.
- Targeting or Tracking Cookies: On certain pages of our Website, we use cookies to help us understand your interests as you browse the Website, so we can tailor and deliver to you a more personalized service in the future. This assists us in delivering relevant, interest-based ads to you.
Grounds for Lawful Processing of Personal Data
Use of Personal Data
- Communication: We may use your information to administer and provide services you request or have expressed an interest in, to communicate with you in case of any inquiry or support, for sending newsletters, updates and promotional materials, for seeking your opinion and feedback, to notify you about changes to our service, and/or tailor any communications that we may send you.
- Career Offering: We provide career options on our Website for the users. They can apply to them using our online forms/links by registering with us. Once you are registered with us, we may use your personal data for various job openings that we have in our company and for sending you communication in case of job vacancies.
- Advertising: We may use your information to carry out advertising and market research based on behavioural metrics, geo-location data, demographic data, and marketing preferences we capture. We may permit certain third-party companies to help us tailor advertising based on use.
- Activity Tracking: We may use your information to track your activity on our digital platforms and personalize and improve your experience. This can be used to create an individual profile for you so that we can understand and respect your preferences or for profiling purposes to enable us to personalize and/or tailor any marketing communications that you may consent to receive from us.
- Optimization: We may use your information to operate, improve, and maintain our site, and to prevent fraud and abuse.
- Information Sharing: We may use and share your information with third parties with whom we have a contractual relationship.
Transferring Your Personal Data
Children’s Privacy
Security: How Secure is Your Information With Us?
Changes to the Notice
Third Party Websites
Your rights and your personal data
- The right to access information: At any point, you can contact us to request the information we hold on you, as well as why we have that information, who has access to the information, and where we obtained the information from. Once we have received your request, we will respond within one month.
- There are no fees or charges for the first request, but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information: If the data we hold on you is out of date, incomplete, or incorrect, you can inform us and your data will be updated.
- The right to have your information erased: If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (e.g., because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing: You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability: You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent: You can withdraw your consent to the processing of data at any time for any processing to which consent was sought. You can withdraw your consent easily by telephone, email, or by post (see Contact Page).
- The right to object to the processing: You have the right to object to the processing of personal data where applicable.
- The right to lodge a complaint: You can lodge a complaint with the Data Protection Officer at privacy@conceptmedical.com.
- How long do we keep your personal data?
Legal Notice
The Website contains information about products that may or may not be available in any particular country or region of the world, may be available under different trademarks in different countries and, where applicable, may be approved or cleared by a government regulatory body for sale or use with different indications and restrictions in different countries. However, the Website and its contents are designed to comply with India laws and regulations. Although accessible by others, it and its content are intended for access and use by Indian residents only.
The Website may contain from time to time information related to various health, medical and fitness conditions and their treatment. Such information is not meant to be a substitute for the advice provided by a professional health care provider. You should not use the information contained herein for diagnosing a health or fitness problem or disease. You should always consult a professional health care provider.
The Website contains information concerning CMI that may be useful to the Company’s customers and employees as well as the general public. In particular, CMI makes no representations or warranties as to the availability, accuracy or completeness of any information contained herein and expressly disclaims any obligation to update said information, except to the extent required by Food and Drug Administration regulations. CMI further assumes no liability or responsibility for any errors or omissions in the content of the Website.
The Website may contain financial and other information which is forward-looking and involves risks and uncertainties, including, without limitation, risks associated with the inherent uncertainty of pharmaceutical research, product development and commercialization, the impact of competitive products, patent, product liability and third-party reimbursement risks associated with the pharmaceutical industry, and the other risks and uncertainties detailed from time to time in CMI’s Annual Report.
Through your access and use of the Website, you accept, without limitation or qualification, the terms and conditions (“Terms and Conditions”) set forth below.
Terms and Conditions
You should assume that all contents of the Website are copyrighted unless otherwise noted and may not be used except as provided herein and without the express written permission of CMI. Images of people or places displayed on the Website are either the property of, or used with permission by, CMI.
The use of these images by you is prohibited unless specifically permitted by these Terms and Conditions or by specific permission provided elsewhere on the Website. Unauthorized use of the images may violate copyright, trademark, privacy and/or publicity laws as well as communications regulations and statutes.
Your use of the Website is at your own risk. Neither CMI nor any other party involved in creating, producing or delivering the Website is liable for any direct, incidental, consequential, indirect or punitive damages arising out of your access to, or use of, or browsing in the Website. This includes damages to, or arising out of viruses that may infect, your computer equipment or other property. Without limiting the foregoing, everything on the Website is provided to you “AS IS” Without warranty of any kind, either expressed or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose or non-infringement. Please note that some jurisdictions may not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you. Check your local laws for any restrictions or limitations regarding the exclusion of implied warranties.
Any communication or material that you transmit to, or post, on the Website by electronic mail or otherwise, including any data, questions, comments, suggestions or the like, is, and will be treated as, non-confidential and non-proprietary information. CMI, or any of its affiliates, may use such communication or material for any purpose whatsoever, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and further posting. Further, CMI and its affiliates are free to use any ideas, concepts, know-how or techniques contained in any communication or material you send to the Website for any purpose whatsoever, including, but not limited to, developing, manufacturing and marketing products.
The trademarks, logos and service marks (collectively, the “Trademarks”) displayed on the Website are registered and unregistered trademarks of CMI and others. Nothing contained in this Website should be construed as granting, by implication, estoppel or otherwise, any license or right in and to the Trademarks without the express written permission of CMI or such third party. Your misuse of the Trademarks on the Website and in its contents, except as provided in these Terms and Conditions, is strictly prohibited. You are advised that CMI will aggressively enforce its intellectual property rights in the Website and its contents to the fullest extent of the law, including by seeking criminal sanctions.
CMI has not reviewed all of the Websites that may be linked to the Website and is not responsible for the content of any off-Website pages or any other Websites linked to the Website. Your linking to any other off-Website pages or other Websites is at your own risk. Once you link to another Website, please be sure to review the legal notices and privacy policy of the new Website. They may be different from this Website.
Although CMI may, from time to time, monitor or review the discussions, chats, postings, transmissions, bulletin boards and the like on the Website, CMI is under no obligation to do so, except to the extent required by Food and Drug Administration regulations, and CMI assumes no responsibility or liability arising from the content of the Website nor for any error, defamation, libel, slander, omission, falsehood, obscenity, pornography, profanity, danger or inaccuracy contained in any information within the Website.
You are prohibited from posting or transmitting any unlawful, threatening, libellous, defamatory, obscene, inflammatory, pornographic or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability or would otherwise violate the law. CMI will fully cooperate with any law enforcement authorities or court order requesting or directing CMI to disclose the identity of anyone posting any such information or materials.
You are prohibited from altering, damaging or defacing the Website or adding any unauthorized material to the Website. You are advised that CMI will aggressively protect the Website and will prosecute violators to the fullest extent of the law, including by seeking criminal sanctions.
CMI reserves the right to alter or delete material from the Website at any time, and CMI may, at any time, revise these Terms and Conditions and the other Policies set forth in this Website by updating this posting. You are bound by any such revisions and should, therefore, periodically visit this page to review the then current Terms and Conditions and Policies.
Privacy policy
If you do provide us with personally identifiable information, such as your name, postal address, e-mail address, telephone number and other personal information, we may contact you, via e-mail or regular mail to provide you with information we believe may be of interest to you. At the time, you will be offered the opportunity to opt out of this service. We do not sell or transfer to others outside our company the information you send to us, except that your data may be transferred to an outside fulfilment company for processing and mailing purposes only. We consider your e-mail address and any personal information you give to be private and these data will be kept confidential within CMI and by any outside Fulfilment Company. Within CMI, data may be transferred to or accessed by authorized CMI personnel in other countries. At all times, personal data are treated confidentially.
Data that are not personal, such as questions, comments, ideas and suggestions, shall be deemed to be non-confidential, and CMI shall be free to disclose and use the same, without any obligation whatsoever to you, for any purpose and through any means.
In addition, we may store some information on your computer to improve the quality of your visit to our Website. In some cases, this information will help us to tailor the content to your interests, or help us to avoid asking for the same information on repeat visits to the Website. With most Internet browsers, you can erase the information, referred to as “cookies” from your computer’s hard drive, block all cookies or even receive a warning before a cookie is placed on your system. Refer to your browser instructions or help button to learn more about cookies.
We are very concerned about protecting the privacy of children. We do not intend to collect any personally identifiable information from children under 18 years old. If a child has provided us with personally identifiable information, the parent or guardian of that child should contact us.
If at any time you do not wish us to contact you or if you have questions concerning our privacy practices, please feel free to reach out to us.
Disclaimer
Disclaimer of Liability
Indemnity Disclaimer
Copyrights
Non Transferable
Applicable Law
Intellectual Property Rights
FAQs
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