United States Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible for your personal information as a “business” under the CCPA/CPRA.
1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Velocity Clinical Research, Inc.; any wholly owned subsidiary of Velocity Clinical Research, Inc. |
Our data protection officer | Alef Voelkner
fox-on Datenschutz GmbH
|
Personal information | Any information relating to an identified or identifiable individual. |
Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. |
Sensitive Personal Information | Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information. |
Biometric Information | An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
2. Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information | Specific Types of Personal Information Collected |
Identifiers (e.g., a 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) | - Real name
- Alias - Postal address - Internet Protocol Address - Email address
|
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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. | - Name
- Signature - Social security number - Physical characteristics - Drivers license - Telephone number - Education - Employment - Employment history - Gender - Language - Race - Ethnicity |
Characteristics of protected classifications under California or federal law. | - Sex
- Race - Age - Ethnicity - Sexual Orientation - Marital Status - National Origin |
Biometric information | - Fingerprint
- Face ID |
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) | - Raghu (are we keeping this information from the app/website)?
- Browser history - Search history |
Geolocation data | - Geolocation data |
Audio, electronic, visual, thermal, olfactory, or similar information | - Text messages
- Emails - phone messages |
Professional or employment-related information | - Employer
- Profession |
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | - Behavioral Tracking
- Pixels/cookies/beacons |
Racial or ethnic origin, religious or philosophical beliefs, or union membership | - Race
- Ethnicity |
Processing of biometric information for the purpose of uniquely identifying a consumer | - Fingerprint ID
- Facial Recognition |
Health information | - Health history
- Immunization history - X-rays and imaging - Medical Conditions - Current Medications - Primary Care Physician - Height and weight - Birth control methods |
Sex life or sexual orientation | - Sexual orientation |
If you do not provide personal information required to provide services to you, it may delay or prevent us from providing services to you.
3. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- You, directly in person, by telephone, text, or email and/or via our website and apps
- Third party with your consent (e.g., your bank)
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Publicly accessible sources (e.g., property records)
- Cookies on our website
- Our IT and security systems, including:
- Door entry systems and reception logs
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems –and–
4. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract, if applicable
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract, if applicable |
To prevent and detect fraud against you or Velocity Clinical Research, Inc. | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator | To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you |
Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations |
Updating and enhancing clients and participants’ records | For the performance of our contract with you or to take steps at your request before entering into a contract, if applicable
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our participants about existing orders and new products |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to:
· Existing and former clients and participants · Third parties who have previously expressed an interest in our services · Third parties with whom we have had no previous dealings |
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former clients and participants |
External audits and quality checks, e.g., Sponsor audits; financial audits | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations |
5. Who We Share Your Personal Information With. We routinely share personal information with:
- Our affiliates, including companies within the Velocity Clinical Research, Inc.’s group
- Service providers we use to help deliver our services to you, such as payment service providers, warehouses, and delivery companies
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
- Credit reporting agencies
- Our insurers and brokers
- Our bank
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Beyond the data collection and use as specifically set forth herein, Velocity does not sell data to third parties.
6. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers (e.g., a 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)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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
- Characteristics of protected classifications under California or federal law
- Biometric information
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
- Geolocation data
- Audio, electronic, visual, or similar information
- Professional or employment-related information
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
- Sensitive personal information
7. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly –or–
- To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information
8. California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of:
· The categories of personal information we have collected about you, including sensitive personal information · The categories of sources from which the personal information is collected · The categories of third parties to whom we disclose personal information, if any –and– · The specific pieces of personal information we have collected about you Please note that we are not required to: · Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained · Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– · Provide the personal information to you more than twice in a 12-month period |
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
· The categories of personal information about you that we shared and the categories of third parties to whom the personal information was sold or shared –and– · The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sharing of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information. To opt-out of the sharing of your personal information, visit our homepage and click on the Do Not Share My Personal Information link here: https://velocityclinicaltrials.com/opt-out-preferences/ |
Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
· Perform the services reasonably expected by an average consumer who requests those services · To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and– · As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, visit our homepage and click on the "Limit the Use of My Sensitive Personal Information" link here: https://velocityclinicaltrials.com/opt-out-preferences/ |
Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
· Delete your personal information from our records –and– · Delete your personal information from our records –and– · Direct third parties to whom the business has shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: · Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us, if applicable · Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes · Debug to identify and repair errors that impair existing intended functionality · Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law · Comply with the California Electronic Communications Privacy Act · Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent · Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us · Comply with an existing legal obligation –or– · Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information |
Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
· Deny services to you · Charge different prices or rates for services, including through the use of discounts or other benefits or imposing penalties · Provide a different level or quality of services to you –or– · Suggest that you will receive a different price or rate services or a different level or quality services Please note that we may charge a different price or rate or provide a different level or quality of services Nto you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
9. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: https://velocityclinicaltrials.com/opt-out-preferences/ You may also contact us via email at info@velocityclinical.com.
- Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
- If you choose to contact us directly by email you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number)
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
- A description of what right you want to exercise and the information to which your request relates
- We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
- Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
10. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11. Changes to This Privacy Notice. This privacy notice was published on September 28, 2023 and last updated on September 28, 2023.
We may change this privacy notice from time to time–when we do, we will inform you via our website.
12. How to Contact Us. Please contact us or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Our contact details | Alef Voelkner |
contact address | fox-on Datenschutz GmbH Pollerhofstraße 33a | 51789 Lindlar/Cologne www.fox-on.com |
contact email address | alef.voelkner@fox-on.com |
contact telephone number | +49 2266 90 15 922 |
13. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).