Privacy Policy
MedAvante Privacy Policy
Introduction
MEDAVANTE, Inc. (“MedAvante”) is a global provider of centralized, expert psychological rating services to the pharmaceutical, biotechnology, and medical device industries.
Protecting consumer privacy is important to MedAvante. MedAvante (hereinafter collectively referred to as “MedAvante,” “we,” “us” or “our”) adheres to the EU Safe Harbor and Swiss Safe Harbor Agreements concerning the transfer of personal data from the European Union (“EU”) and Switzerland to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to personal information received by MedAvante whether in electronic, paper or verbal format.
This Privacy Policy covers our collection, use and disclosure of information we collect through our websites www.medavante.com and www.medavante.net and our service platforms MAVTAB, QCAT and eLearning.The use of information collected through our service platforms shall be limitedto the purpose of providing the service for which the Client has engaged MedAvante.
MedAvante has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@medavante.com. If you are not satisfied with our response, you can contact TRUSTe here by fax at 415-520-3420, or via mail here. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of the company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaints shared with the company. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, please visit TRUSTe or request this information from TRUSTe at the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. Any questions, comments or complaints about the data practices (including without limitation compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) of a hosted online OnBoarding software customer or partner for whom MedAvante processes data should be addressed to that customer or partner.
Definitions
“Personal Information” shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.
“Processing of personal information” (‘processing’ or ‘processes’) shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
“Third Party Agent” shall mean any party that has entered into a formal agreement with MedAvante for the purposes of processing, analyzing or storing personal data either manually or electronically. The agreement between MedAvante and the Third Party Agent requires them to observer our Privacy Policy and respect your confidentiality.
“Client” shall mean a party that MedAvante has entered into a formal agreement with to facilitate the processing of personal information for the purpose of supporting regulated clinical trials.
Information We Collect from Visitors
Visitors to our Web sites (www.medavante.com or www.medavante.net) can access the Web site's home page, and browse the site, without disclosing any personally identifiable information. If you wish to contact us via our website, we will collect your name, address, and email address. We will only use this information to respond to your inquiry.
Information We Collect on Behalf of a Client
MedAvante collects and processes clinical assessment information which may include personally identifiable and/or sensitive personal information in support of regulated clinical trials. MedAvante collects and processes information under the direction of its Clients. MedAvante has no direct relationship with the individuals whose personal data it processes. MedAvante works with its Clients to help them provide notice to their customers concerning the purpose for which personal information is collected.
Access to Data Controlled by our Clients
MedAvante has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the MedAvante Client (the data controller).
Access to Data Controlled by MedAvante
MedAvante shall allow an individual access to their personal information and allow the individual to correct, amend or delete inaccurate information except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
If your personally identifiable information changes, you may correct, update or delete it by emailing our Privacy Officer at privacy@medavante.com or by contacting us by postal mail at the contact information listed below. We will respond to your request within 30 days.
Storage of personal information
Use of Cookies on Services Platforms
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.
We use session ID cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser.
Principles
The privacy principles included in this statement are based on the Safe Harbor Privacy Principles that can be found on the U.S. Department of Commerce website where you can learn more about the Safe Harbor program and view MedAvante’s certification, http://www.export.gov/safeharbor/. These privacy principles apply to information MedAvante collects directly from individuals. When MedAvante collects and processes your information on behalf of a Client, we will work with the Client to ensure adherence to these principles.
Notice
MedAvante or Client shall inform an individual of the purpose for which it collects and uses personal information. MedAvante or Client shall provide the individual with the choice and means 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 MedAvante, or as soon as practicable thereafter, and in any event before MedAvante uses or discloses the information for a purpose other than for which it was originally collected or processed.
Choice
MedAvante does not sell, share, rent or trade your personal information with third parties other than as disclosed within this privacy policy. MedAvante or Client will offer individuals the opportunity to choose (opt out) whether their personal information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, MedAvante or Client will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.
Onward Transfers
We shall notify an individual of disclosure of personal or sensitive personal information to a third party and allow the individual the choice (opt out) of such disclosure. MedAvante shall ensure that any third party for which personal or sensitive personal information may be disclosed subscribes to the Principles or are subject to laws providing the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection.
Data Security
MedAvante shall take all reasonable steps to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. MedAvante has appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
When logging in to your account to participate in MedAccess, please note that this is a secure login; we use SSL encryption.
Data Integrity
MedAvante shall only process information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, MedAvante shall take reasonable steps to ensure that information is accurate, complete, current and reliable for its intended use.
Enforcement
MedAvante uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. You may raise questions or concerns regarding MedAvante’s collection, processing, storage or disclosure of Information by using the contact information below. We will investigate and attempt to resolve any concerns and disputes regarding misuse or improper disclosure of your information in accordance with the principles contained in this policy. When applicable, corrective and preventive action will be implemented to resolve any concern or dispute and appropriate follow-up action will be taken to verify that the expressed concern or dispute has been resolved.
Amendments
If we decide to change our privacy policy, we will post the changes to this privacy statement, on our website so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently.
Information Subject to Other Policies or Agreements
MedAvante is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of MedAvante that may differ in some respects from the general policies set forth in this privacy policy.
Links to Other Sites
If you click on a link to a third party site, you will leave MedAvante’s site and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as we would. We encourage you to review the privacy statements of any other service provider from whom you request services. If you visit a third party website that is linked to our site, you should read that site’s privacy statement before providing any personally identifiable information.
Contact Information
Questions, comments or complaints regarding MedAvante’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:
MEDAVANTE, Inc.
Privacy Officer
100 American Metro Blvd. Suite 106
Hamilton, NJ 08619
privacy@medavante.com
Effective date: February 24, 2012