PRIVACY POLICY
Courante Oncology is committed to protecting the privacy of its users. This Privacy Policy (“Privacy Policy”) is designed to help you understand what information we gather, how we use it, what we do to protect it, and to assist you in making informed decisions when using our website.
I. CONSENT
By accessing our website, you accept our Privacy Policy and Terms of Use, and you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. In addition, by using our website, you are accepting the policies and practices described in this Privacy Policy. Each time you visit our website, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use and disclosure of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this Privacy Policy.
II. INFORMATION WE COLLECT
In the context of the work that Courante performs, personal data refers to any information that relates to an identified or identifiable individual such as a name, email, mailing address, phone number, or any information related to an individual’s health for the purpose of healthcare research. We collect personal data provided directly by you during direct communication with us either through email or by phone. We collect your name, email address, phone number and the reason for your communication. For the purpose of our research, we do not collect your personal data directly. Your personal data is collected through the partners (“Clinical Site”) that manage the clinical trials that we support. They collect your personal data as a participant of the clinical trial or as a Clinical Site employee or contractor involved in the clinical trial.
With respect to our website, we may collect both “Non-Personal Information” and “Personal Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, referring/exit pages and URLs, and number of clicks. “Personal Information” includes information that can be used to personally identify you, such as your name, address, contact numbers and email address, but it may also include other information you may choose to provide us with (for example, to provide a requested service, where consulting services are being pursued or where a health professional is interested in participating in a clinical trial).You may voluntarily provide us with Personal Information to receive additional information about Courante, if you are interested in pursuing a consulting opportunity with Courante, or if you are interested in providing clinical trial investigator services to Courante or to receive customized information (usually through the “Contact Us” form). Personal Information does not include information that is anonymized such that an individual cannot be identified.
In addition, we may also track information provided to us by your browser when you view or use the website, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the website, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the website, to maintain the quality of the website, to provide general statistics regarding use of the website and for other business purposes. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. Courante may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of the Service may not work properly.
III. HOW WE USE AND SHARE INFORMATION
Personal Information and Disclosure:
In general, we do not sell, trade, rent or otherwise share your Personal Information with third parties without your consent or in a manner inconsistent with applicable law or this Privacy Policy. We may use your Personal Information to respond to inquiries and/or supply requested information on Courante’s services. We may share your Personal Information with vendors and other third-party providers who are performing services for Courante. In general, the vendors and third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide for Courante.
In addition, we may need to disclose your Personal Information to law enforcement, regulatory bodies or courts, in response to legal requests by public authorities including to meet national security or law enforcement requirements or when we are required to do so under applicable laws and regulations.
Companies working as agents of Courante are required to sign confidentiality agreements whereby they will commit to only process Personal Information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
If disclosure of your Personal Information under the conditions above involves transfer of your Personal Information to countries that were not recognized as providing an adequate level of protection of Personal Information pursuant to the rules applicable in your country, Courante will set up appropriate guarantees to secure your Personal Information in the context of such transfer, including but not limited to Standard Contractual Clauses.
Data Retention:
Your Personal Information is retained by Courante for no longer than is needed for performance of the respective purpose of its processing as described under this Privacy Policy. For example, we retain personal data from clinical trials in accordance with the local laws of the country/region where the trial has taken place for legal and legislative reasons. Records of payments made and received will, likewise, have a statutory period in the country/region where we must store it for any inspection from the authorities or regulators. It may however be retained for a longer duration, as archive, for the purpose of proof management in prevention of any claim.
IV. HOW WE PROTECT INFORMATION
We implement reasonable precautions and follow industry best practices in order to protect your Personal Information and ensure that such Personal Information is not accessed, disclosed, altered or destroyed. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using our website, you acknowledge that you understand and agree to assume these risks.
V. YOUR RIGHTS YOU CAN EXERCISE REGARDING THE USE OF YOUR PERSONAL INFORMATION
Subject to any exceptions provided by law, you have the right to request access to, update of or deletion of your personal data. You also have the right to request restriction of or object to the processing of your personal data. And you have the right to request to have your data transferred to another organization in a commonly used format. On each particular case we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal or contractual requirements. During a clinical trial your rights to access, update or delete your pseudonymized personal data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and accuracy of the research for reasons of public interest in public health and for archiving purposes.
Pursuant to the Data Privacy Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
VI. DATA PRIVACY FRAMEWORK COMPLAINT RESOLUTION MECHANISM
In compliance with the EU-US Data Privacy Framework Principles and the UK Extension to the EU-US DPF, Courante is committed to resolving DPF Principles-related complaints about your privacy and our collection and use of your personal information transferred to the United States pursuant to the DPF Principles. European Union and United Kingdom individuals with DPF inquiries or complaints regarding our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF should first contact Courante at [email protected].
In compliance with the EU-US Data Privacy Framework Principles and the UK Extension to the EU-US DPF, Courante commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF.
If you reside in the EU and want to lodge a complaint with a Supervisory Authority (Data Protection Authority) you may do so in the Member State where you reside, where you work or where you may have experienced an issue with the processing of your personal data. You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.
VII. ONWARD TRANSFERS TO THIRD PARTIES
Courante’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Courante remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages with to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Courante proves that it is not responsible for the event giving rise to the damage.
VIII. WEEBLY
Our website is hosted by Weebly, Inc. (“Weebly”). Your information, including Personal Information, may be stored through Weebly’s servers. By using the website, you consent to Weebly’s collection, disclosure, storage, and use of your Personal Information in accordance with Weebly’s privacy policy available at https://www.weebly.com/privacy.
IX. LINKS TO OTHER WEBSITES
We may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
X. AGE OF CONSENT
By using the website, you represent that you are at least 16 years of age.
XI. CHANGES TO OUR PRIVACY POLICY
Courante reserves the right to change this Privacy Policy and our Terms of Use at any time. If we decide to change this Privacy Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. It is your sole responsibility to check this website from time to time to view any such changes to the terms of this Privacy Policy. If you do not agree to any changes, if and when such changes may be made to this Privacy Policy, you must cease access to this website. If you have provided your email address to us, you give us permission to email you for the purpose of notification as described in this Privacy Policy.
XII. MERGER OR ACQUISITION
In the event we (or Weebly) undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our (or Weebly’s) assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes here so that you may opt out of the new information practices. We suggest that you check this Privacy Policy periodically if you are concerned about how your information is used.
XIII. EMAIL COMMUNICATIONS & OPTING OUT
Based upon the Personal Information that you provide us, we may communicate with you in response to your inquiries to provide the services you request. We will communicate with you by email or telephone, in accordance with your wishes. We may also use your Personal Information to send you updates and other promotional communications. If you no longer wish to receive those email updates, you may opt-out of receiving them by following the instructions included in each update or communication.
XIV. WORLDWIDE TRANSFER OF PERSONAL DATA
Your personal data may be transferred to, stored, and processed in a country other than the one in which it was provided (i.e., a ‘Recipient’ country). When Courante does so, it transfers the personal data in compliance with applicable data protection laws. Courante will follow the applicable laws to use such lawful mechanisms for the transfer as are approved by the applicable data protection authority of your jurisdiction prior to transferring any of your personal data (e.g., the Standard Contractual Clauses for transfers from the European Economic Area (EEA) and the United Kingdom’s International Data Transfer Agreement as applicable).
Courante complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the U.K. Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Courante has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprovacyframework.gov/.
The Federal Trade Commission has jurisdiction over Courante’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.
XV. CONTACT US & WITHDRAWING CONSENT
If you have any questions regarding this Privacy Policy, questions or complaints about the processing of your personal date or questions concerning this policy and/or the certification of the Courante’s compliance, please contact:
Data Protection Officer
Courante Oncology
202 Water Street, Suite 201, Excelsior, MN 55331, USA
[email protected]
Last Updated: This Privacy Policy was last updated on Monday, March 25, 2024.
I. CONSENT
By accessing our website, you accept our Privacy Policy and Terms of Use, and you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. In addition, by using our website, you are accepting the policies and practices described in this Privacy Policy. Each time you visit our website, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use and disclosure of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this Privacy Policy.
II. INFORMATION WE COLLECT
In the context of the work that Courante performs, personal data refers to any information that relates to an identified or identifiable individual such as a name, email, mailing address, phone number, or any information related to an individual’s health for the purpose of healthcare research. We collect personal data provided directly by you during direct communication with us either through email or by phone. We collect your name, email address, phone number and the reason for your communication. For the purpose of our research, we do not collect your personal data directly. Your personal data is collected through the partners (“Clinical Site”) that manage the clinical trials that we support. They collect your personal data as a participant of the clinical trial or as a Clinical Site employee or contractor involved in the clinical trial.
With respect to our website, we may collect both “Non-Personal Information” and “Personal Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, referring/exit pages and URLs, and number of clicks. “Personal Information” includes information that can be used to personally identify you, such as your name, address, contact numbers and email address, but it may also include other information you may choose to provide us with (for example, to provide a requested service, where consulting services are being pursued or where a health professional is interested in participating in a clinical trial).You may voluntarily provide us with Personal Information to receive additional information about Courante, if you are interested in pursuing a consulting opportunity with Courante, or if you are interested in providing clinical trial investigator services to Courante or to receive customized information (usually through the “Contact Us” form). Personal Information does not include information that is anonymized such that an individual cannot be identified.
In addition, we may also track information provided to us by your browser when you view or use the website, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the website, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the website, to maintain the quality of the website, to provide general statistics regarding use of the website and for other business purposes. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. Courante may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of the Service may not work properly.
III. HOW WE USE AND SHARE INFORMATION
Personal Information and Disclosure:
In general, we do not sell, trade, rent or otherwise share your Personal Information with third parties without your consent or in a manner inconsistent with applicable law or this Privacy Policy. We may use your Personal Information to respond to inquiries and/or supply requested information on Courante’s services. We may share your Personal Information with vendors and other third-party providers who are performing services for Courante. In general, the vendors and third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide for Courante.
In addition, we may need to disclose your Personal Information to law enforcement, regulatory bodies or courts, in response to legal requests by public authorities including to meet national security or law enforcement requirements or when we are required to do so under applicable laws and regulations.
Companies working as agents of Courante are required to sign confidentiality agreements whereby they will commit to only process Personal Information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
If disclosure of your Personal Information under the conditions above involves transfer of your Personal Information to countries that were not recognized as providing an adequate level of protection of Personal Information pursuant to the rules applicable in your country, Courante will set up appropriate guarantees to secure your Personal Information in the context of such transfer, including but not limited to Standard Contractual Clauses.
Data Retention:
Your Personal Information is retained by Courante for no longer than is needed for performance of the respective purpose of its processing as described under this Privacy Policy. For example, we retain personal data from clinical trials in accordance with the local laws of the country/region where the trial has taken place for legal and legislative reasons. Records of payments made and received will, likewise, have a statutory period in the country/region where we must store it for any inspection from the authorities or regulators. It may however be retained for a longer duration, as archive, for the purpose of proof management in prevention of any claim.
IV. HOW WE PROTECT INFORMATION
We implement reasonable precautions and follow industry best practices in order to protect your Personal Information and ensure that such Personal Information is not accessed, disclosed, altered or destroyed. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using our website, you acknowledge that you understand and agree to assume these risks.
V. YOUR RIGHTS YOU CAN EXERCISE REGARDING THE USE OF YOUR PERSONAL INFORMATION
Subject to any exceptions provided by law, you have the right to request access to, update of or deletion of your personal data. You also have the right to request restriction of or object to the processing of your personal data. And you have the right to request to have your data transferred to another organization in a commonly used format. On each particular case we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal or contractual requirements. During a clinical trial your rights to access, update or delete your pseudonymized personal data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and accuracy of the research for reasons of public interest in public health and for archiving purposes.
Pursuant to the Data Privacy Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
VI. DATA PRIVACY FRAMEWORK COMPLAINT RESOLUTION MECHANISM
In compliance with the EU-US Data Privacy Framework Principles and the UK Extension to the EU-US DPF, Courante is committed to resolving DPF Principles-related complaints about your privacy and our collection and use of your personal information transferred to the United States pursuant to the DPF Principles. European Union and United Kingdom individuals with DPF inquiries or complaints regarding our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF should first contact Courante at [email protected].
In compliance with the EU-US Data Privacy Framework Principles and the UK Extension to the EU-US DPF, Courante commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF.
If you reside in the EU and want to lodge a complaint with a Supervisory Authority (Data Protection Authority) you may do so in the Member State where you reside, where you work or where you may have experienced an issue with the processing of your personal data. You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.
VII. ONWARD TRANSFERS TO THIRD PARTIES
Courante’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Courante remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages with to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Courante proves that it is not responsible for the event giving rise to the damage.
VIII. WEEBLY
Our website is hosted by Weebly, Inc. (“Weebly”). Your information, including Personal Information, may be stored through Weebly’s servers. By using the website, you consent to Weebly’s collection, disclosure, storage, and use of your Personal Information in accordance with Weebly’s privacy policy available at https://www.weebly.com/privacy.
IX. LINKS TO OTHER WEBSITES
We may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
X. AGE OF CONSENT
By using the website, you represent that you are at least 16 years of age.
XI. CHANGES TO OUR PRIVACY POLICY
Courante reserves the right to change this Privacy Policy and our Terms of Use at any time. If we decide to change this Privacy Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. It is your sole responsibility to check this website from time to time to view any such changes to the terms of this Privacy Policy. If you do not agree to any changes, if and when such changes may be made to this Privacy Policy, you must cease access to this website. If you have provided your email address to us, you give us permission to email you for the purpose of notification as described in this Privacy Policy.
XII. MERGER OR ACQUISITION
In the event we (or Weebly) undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our (or Weebly’s) assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes here so that you may opt out of the new information practices. We suggest that you check this Privacy Policy periodically if you are concerned about how your information is used.
XIII. EMAIL COMMUNICATIONS & OPTING OUT
Based upon the Personal Information that you provide us, we may communicate with you in response to your inquiries to provide the services you request. We will communicate with you by email or telephone, in accordance with your wishes. We may also use your Personal Information to send you updates and other promotional communications. If you no longer wish to receive those email updates, you may opt-out of receiving them by following the instructions included in each update or communication.
XIV. WORLDWIDE TRANSFER OF PERSONAL DATA
Your personal data may be transferred to, stored, and processed in a country other than the one in which it was provided (i.e., a ‘Recipient’ country). When Courante does so, it transfers the personal data in compliance with applicable data protection laws. Courante will follow the applicable laws to use such lawful mechanisms for the transfer as are approved by the applicable data protection authority of your jurisdiction prior to transferring any of your personal data (e.g., the Standard Contractual Clauses for transfers from the European Economic Area (EEA) and the United Kingdom’s International Data Transfer Agreement as applicable).
Courante complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the U.K. Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Courante has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprovacyframework.gov/.
The Federal Trade Commission has jurisdiction over Courante’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.
XV. CONTACT US & WITHDRAWING CONSENT
If you have any questions regarding this Privacy Policy, questions or complaints about the processing of your personal date or questions concerning this policy and/or the certification of the Courante’s compliance, please contact:
Data Protection Officer
Courante Oncology
202 Water Street, Suite 201, Excelsior, MN 55331, USA
[email protected]
Last Updated: This Privacy Policy was last updated on Monday, March 25, 2024.