Privacy Policy
This Privacy Policy applies to https://www.reifyhealth.com, https://www.ca.studyteamapp.com, and https://www.studyteamapp.com, which are owned and operated by Reify Health, Inc. (collectively, “We”, “Us”, “Our” or “Reify”). This Privacy Policy describes how Reify collects, uses, shares, and secures the personal information you provide. This Privacy Policy (“Privacy Policy”) is incorporated into and made part of our Terms of Service. All capitalized terms used but not defined herein have the meanings given to them in our Terms of Service. This Privacy Policy describes Reify’s processing of information, including personally identifiable information (“Personal Information”), that Reify collects in connection with your access or use of any Site or Service and all other data and content that is accessed, utilized, input, or generated in connection with any Site or Service. By accessing or using any Site or Service, you consent to the collection, use, and disclosure of your information, including, but not limited to, Personal Information, in accordance with this Privacy Policy. The use of information collected through our Sites and Services shall be limited to the purpose of providing the Services for which the Client has engaged Reify.
Data Controller
The data controller of your Personal Information is Reify Health Inc. If you have any questions, comments or requests regarding this Privacy Policy, please contact the Reify Health Privacy Officer at:
Reify Health, Inc.
Attn: Privacy Officer
Address: 33 Arch St, 17th Floor, Boston, MA 02110
Email: privacyofficer@reifyhealth.com
Privacy Shield
Your Personal Data may be transferred from any EU Member States to Reify’s servers located in the US only under the specific guarantees established by the Privacy Laws.
Reify Health, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Reify Health, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you can contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
What Types of Personal Information Does Reify Gather?
Services may include programs such as StudyTeam in which users with access to Restricted Areas of Reify’s Sites (each, a “Registered User”) communicate information about clinical research needs and capabilities and monitor and manage the performance of clinical research activities. Reify may collect any information provided or input by you or authorized by you to be provided by a third party in connection with any Site or Service, which information may include, but is not limited to, your name, email and physical address, and telephone number and the name, medical record number, email and physical address, and telephone number of a patient. We collect information from you when you use Sites or Services, when you fill out a form, upload information, create or use an account, or otherwise supply information to us. When you send email or other communications to us, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve our services.
Privacy and Cookies Policy
We may also automatically collect information regarding your interaction with, and use of, any Site or Service. We may use a variety of methods to collect this information, including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools (“Automatic Data Collection Tools”) to administer the Sites and Services, inform user support efforts, and analyze user trends to inform improvements to the Sites and Services user trends to support. These Automatic Data Collection Tools collect certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and click-stream behavior. You may have the ability, through your Internet browser settings, to receive notices regarding, or turn off, certain Automatic Data Collection Tools; however, please note that turning off Automatic Data Collection Tools may negatively impact the functionality or performance of the Sites and Services.
Information may be collected by us or by our vendors who provide internet hosting for the Sites or Services. We may combine information you give us with other information from Reify sources, transactions and communications. We may also combine that information with data from third parties, such as the name of your site or your site’s preferred business phone number from your website. This helps us to update, expand, and analyze our records and engage you about new products, services, and features that are most relevant to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or from third parties and combined with information we already have about you, may include:
- The address of your business;
- A phone number associated with your business.
We partner with third parties that help us analyze user activity for the purpose of improve the Service for you, providing support to you, and monitoring the performance of the Service. Our third party partners may use cookies or similar technologies to help us do that. If you wish to opt out of this use of information, click here [or, if located in the European Union, click here].
Users may allow, block or disable the use of cookies which have been stored in their devices at any time, by means of changing their browser’s privacy settings. These procedures are subject to updates and modifications made by the developers of web browsers and therefore we cannot guarantee its fully adherence to the latest version available.
In the event that the User decides to disable all cookies, the quality and speed of the service could diminish, and user may lose access to some of the services or features available on the Site.
Basis for Processing
Your Personal Information will be processed by Reify on the basis of a lawful “justification” for such processing, to the extent required by or permissible under applicable law.
In the majority of cases, the processing of your Personal information will be justified on one of the following bases:
- It is provided for in the Agreement and therefore necessary to give effect to it;
- You have given us your consent; or
- It is necessary for us to comply with a legal obligation
How Does Reify Use Your Personal Information?
We use Personal Information to facilitate your use and receipt of the Sites and Services, and any products or services related thereto, and as further described in this Privacy Policy.
Facilitate Your Use of the Sites and Services. We may use your Personal Information to communicate with you regarding the Sites or Services, your account information or other customer service matters; to respond to your questions and instructions; and, with your prior consent, to enhance, customize, and personalize your experiences and communications with us.
Operate and Improve the Sites and Services. We may use your Personal Information to operate, provide, improve, and maintain the Sites and Services, including analyzing User behavior and trends to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users; to send you administrative messages and other information about Reify and the Sites and Services, including critical updates and notifications; to investigate or take action regarding violations or suspected violations of applicable law or our Terms of Service; and to maintain the integrity of the Sites and Services and our network and address security issues.
Marketing and Promotion Purposes. With your prior consent, we may use your Personal Information to communicate with you about the Sites and Services and other related products and services; and display relevant marketing to you. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in the marketing emails we send to you.
Special Circumstances. We may also access, use, copy or disclose Personal Information in the event of any Special Circumstances (as described below).
Aggregated Data. Information collected from any source may be combined to create aggregated data (“Aggregated Data”) to provide or improve the Sites and Services and facilitate a more targeted, tailored user experience. Reify may use Aggregated Data for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes.
With Whom Does Reify Share Your Personal Information?
With your prior consent, we may provide your Personal Information to our subsidiaries and affiliates (which today includes and is limited to Reify Health, Inc., and herein is called the “Reify Companies”). Unless not permitted by applicable law, all companies within the Reify Companies may share Personal Information collected through any Site or Service and may contact you directly.
We do not sell, trade, or otherwise transfer to third parties your Personal Information unless we provide you with advance notice and obtain your prior consent, except as described herein. The term "outside parties" does not include Reify Companies, our website hosting partners, and other parties who assist us with the administration of the Sites or Services, conducting our business, or servicing you, so long as those parties agree to maintain reasonable security measures to safeguard the confidentiality, security, and integrity of your Personal Information. Outside parties may have access to Personal Information as reasonably necessary to perform their functions.
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
These services may include:
- Providing customer service
- Sending marketing communications
- Conducting research and analysis
- Providing cloud computing infrastructure
We may disclose Personal Information when we believe disclosure is appropriate to comply with applicable law by public authorities, including to meet national security or law enforcement requirements; comply with a subpoena or other legal process;
enforce or apply this Privacy Policy or other agreements to which we are a party or which are related to any Site or Service; protect the rights, property or safety of our company, our Registered Users or others (collectively, “Special Circumstances”); or respond to a government request.
If our company is acquired by or merged with or into another entity, or if our assets or business is sold or transferred to another entity, your Personal Information may be transferred to such entity as part of the transaction, and that entity and its affiliates may use your Personal Information under the terms of their own privacy policies which may differ from this Privacy Policy. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Access and Choice
Upon request Reify will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at support@reifyhealth.com. We will respond to your request within a reasonable timeframe.
Data Retention
We may store and use your Personal Information for as long as you continue to access or use any Site or Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Reify Health may retain your Personal Information for the purposes of audits and review in the course of providing the Services and for the substantiation of other data in the system.
Rights
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your personal information, and to request access to, rectification, portability or removal of your own personal information. Requests can be made to our Privacy Officer whose contact details are set forth in the introduction section of this Privacy Policy.
In the event your Personal Information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Furthermore, you have the right to lodge complaints relating to the processing of your Personal Information with your relevant data protection supervisory authority.
Information Security
Information security is important to Reify. We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use your Personal Information. In particular, we have obtained the Privacy Shield certification which implies that Reify commits to comply with the Framework’s requirements that can be accessed here. However, like other companies, Reify cannot guarantee the 100% security or confidentiality of your Personal Information. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we cannot warrant or guarantee the absolute security of any Personal Information you transmit to, from or through any Site or Service.In the event that we become aware of a security breach involving your Personal Information stored by or for us, we may notify you by posting details of the breach to the applicable Site or Service or via email, to the extent available in connection with such Site or Service. We will provide you with a copy of our StudyTeam Security Overview upon request. You should be aware that Reify has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third party site appears on any Site or Service. In addition, Reify does not control or continuously monitor the activities of users of any Site or Service, and such users may have the ability to provide, access, use and/or disclose data and information, such as your Personal Information, in connection with the Sites and Services.
Please note that some of the content we deliver to or receive from you through the Sites and Services, specifically that of emails and text messages, is unencrypted. And so, transmissions may be unknowingly or unintentionally intercepted by third parties. We do not maintain or have access to your device, phone, e- mail server, or networks outside of our domain and control; therefore, we bear no liability or responsibility for the security or control of content or communications, once delivered to you.
If you have any questions about the security of your personal information, you can contact us at support@reifyhealth.com.
Platform Data Collection and Practices
Reify collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Upon request Reify will provide you with information about whether we hold any of your personal information. Reify 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 Reify’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Reify will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Privacy Policies
Once you leave a Site or Service, whether independently or via links, the privacy policies of the websites to which you migrate will apply. This Privacy Policy applies solely to your interactions with, and information collected through, the Sites and Services.
International Users
Our operations are conducted within the United States. Regardless of where you live, you consent to have your Personal Information transferred, processed and stored in the United States, and allow Reify to use and collect your Personal Information in accordance with this Privacy Policy. Please note that the Sites and Services are not intended for use by a person in any state or country where such use would be contrary to any applicable laws or regulations.
International Users: If you access any Site or Service outside the United States, your connection may be through and to servers located in your country or the United States. Any Personal Information you provide may be processed and maintained in the United States on servers or other network systems operated by or for Reify’s benefit. IF THE JURISDICTION IN WHICH YOU ARE LOCATED OR YOUR COUNTRY OF ORIGIN HAS LAWS OR REGULATIONS WHICH REQUIRE THAT YOUR PERSONAL INFORMATION BE RECEIVED, USED, SAVED, TRANSFERRED OR OTHERWISE HANDLED IN A MANNER DIFFERENT THAN AS STATED IN THESE THIS PRIVACY POLICY, THEN YOU ARE NOT AUTHORIZED TO UTILIZE ANY SITE OR SERVICE. If you access any Site or Service from or reside outside of the United States, your information may be stored, transmitted and shared in accordance with U.S. data privacy laws, which may not be equivalent to those in effect in your country. YOU EXPRESSLY AGREE THAT YOU WILL NOT USE ANY SITE OR SERVICE WITH ANY EXPECTATION OF GREATER PRIVACY RIGHTS THAN THOSE TO WHICH YOU HAVE EXPRESSLY AGREED AS STATED IN THIS PRIVACY POLICY.
Notice to Residents of the State of California in the United States of America
In addition to the other rights described in this Privacy Policy, if you are a customer residing in California, you have the right to request information regarding the third parties with whom Reify has shared customer Personal Information for direct marketing purposes during the past year. You have the right to submit a request to Reify and receive the following information within 30 days of its receipt of that request: (1) the types of Personal Information disclosed to third parties during the immediately preceding calendar year, (2) the names and addresses of third parties that received the Personal Information, and (3) if the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of its products or services. You are entitled to receive a copy of this information in a standardized format. Information provided will not be specific to you individually. All such requests must be in writing and sent to Reify’s designated address set forth in the “Contact Us” Section.
Children’s Privacy
The privacy of children is important to Reify. The Sites and Services are not directed at children, and we do not knowingly collect Personal Information from children under the age of 16 through the Sites and Services. Children under the age of 16 may not access, use or submit any Personal Information through any Site or Service.
By using any Site or Service, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to Reify will be treated as if provided by an adult. If a child has provided us with Personal Information, a parent or guardian of that child may send an e-mail to business@reifyhealth.com with "Request for Child Information Removal" on the subject line and the name and age of the child in the body of the message. Upon verification, we will remove the child’s Personal Information from our applicable databases.
Changes
We may update this Privacy Policy from time to time without prior notice. Any changes to our Privacy Policy will become effective upon posting of the updated Privacy Policy on our website located at https://studyteamapp.com/StudyTeam_Privacy_Policy.html. If we change this Privacy Policy, we will revise the “last modified” date at the bottom of this Policy. For material changes to this Privacy Policy, we will notify you by placing a notice on Reify’s log-in page(s) or the home page of Reify, or by sending you a notification directly. We encourage you to bookmark our Internet sites and to periodically review them to ensure familiarity with the most current version of our Privacy Policy. We may ask you to affirmatively acknowledge consent to any changes to this Policy (e.g., by checking a box or clicking a button).
Contact Us
If you have any questions, comments or requests regarding this Privacy Policy, please contact the Reify Health Privacy Officer at:
Reify Health, Inc.
Attn: Privacy Officer
Address: 33 Arch St, 17th Floor, Boston, MA 02110
Email: privacyofficer@reifyhealth.com
Last Modified: 16 September 2019
This Privacy Policy applies to www.reifyhealth.com ("Corporate Site"), www.studyteamapp.com, and https://www.eu.studyteamapp.com ("StudyTeam" and together with the Corporate Site, each a "Site" and together the "Sites"), which are owned and operated by Reify Health, Inc. (collectively, "We", "Us", "Our" or "Reify"), and aims to describe, as required by the EU General Data Protection Regulation 2016/679 ("GDPR") and EU Member States’ local applicable legislation (together with the GDPR, 'applicable privacy laws'), how Reify processes, shares and secures, when acting as a data controller, the personal data collected in connection with the use and browsing of the publicly accessible areas of the Sites ("Personal Data"). This Privacy Policy ("Privacy Policy") is incorporated into and made part of our Terms of Service.
1. THE ROLE OF REIFY
Reify Health Inc, with its business address at 33 Arch St, 17th Floor, Boston, MA 02110, United States of America, is the data controller, pursuant to the Privacy Laws in force, with exclusive reference to the Personal Data provided by you and/or collected by us through the Corporate Site and the publicly accessible areas of StudyTeam (collectively, "Open Sites"), namely any area or feature which is not restricted to only those StudyTeam users who are granted access to password protected areas in accordance with the applicable Terms of Service ("Restricted Areas").
In respect of the Personal Data collected and processed in connection with StudyTeam clinical research related products and services ("Services"), within StudyTeam’s Restricted Areas, the data controller shall, depending on the nature and purpose of the particular processing, be either in certain cases the clinical research site, and in other cases the sponsor using StudyTeam for the purpose of a clinical trial (both such entities, the "Client"). The role of Reify, in relation to the processing of Personal Data taking place within the Restricted Areas, shall be exclusively that of data processor on behalf of the Clients.
Therefore, any reference made below to the Sites (and not only to the Open Sites) shall solely be in the context of the processing of personal data for which Reify acts as data controller (e.g. newsletter, web security management, cookie-based activities) and which therefore does not derive from, and is not connected with, the data processing conducted by the Clients within the Restricted Areas for which Reify acts as a data processor.
Upon receipt of requests for more detailed information regarding the processing of Personal Data for the purpose of clinical trials within StudyTeam’s Restricted Areas, we will transmit any such requests to the competent data controllers, with which we have entered into agreements in accordance with applicable privacy laws.
If you are a customer, consumer or patient of one of our Clients that use the Services and would no longer like to be contacted by this Client, please contact them directly.
2. CONTACT DETAILS
If you have any questions, comments or requests regarding the Personal Data processing carried out through the Corporate Site or the non-Restricted Areas of StudyTeam, please contact:
Reify Health, Inc’s EU representative
Attn: Navigant Germany GmbH, Life Sciences
Station: Friedrichstraße
Address: Albrechtstraße 10 c, 10117 Berlin, Germany
Email: navigant@reifyhealth.com
Reify Health, Inc
Attn: Data Protection Officer
Address: 33 Arch St, 17th Floor, Boston, MA 02110
Email: privacyofficer@reifyhealth.com
3. WHAT TYPES OF PERSONAL DATA DOES REIFY GATHER?
Reify collects Personal Data from visitors who browse or use our Open Sites ("Users"), e.g. by filling out a form, uploading information, scheduling a meeting with us, applying for a specific job position, or otherwise supply information to us. When you send email or other communications to us, we may use those communications in order to process your inquiries, respond to your requests, and improve our services.
The categories of personal data processed by Reify as controller are the following:
- name;
- username;
- email address;
- phone number;
- business address;
- operating system;
- browser type;
- cookie data (for more information please see section "Automated Data Collection Tools")
- IP address;
We may also automatically collect information regarding your interaction with and use of our Sites, using a variety of methods including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools ("Automatic Data Collection Tools"), which allow us to gather certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and click-stream behavior. More detailed information regarding "Automatic Data Collection Tools" are set out in paragraph 8.
4. PURPOSES AND LEGAL BASES OF THE PROCESSING OF PERSONAL DATA
Your Personal Data will be processed by Reify, as controller, provided that at least one legal ground exists for such processing in accordance with the applicable Privacy Laws.
The purposes for which Reify will process Users’ Personal Data and the relevant applicable legal bases are the following:
- To fulfill a User’s requests, we may use your Personal Data to respond to your queries and provide you with the services and contents you have requested to us (e.g. through "Contact" or "Support" forms, or application for job positions). This includes sending you administrative messages and other non-commercial information about Reify and the Sites, including critical updates and notifications;
- When a User has given his/her consent, we may use your Personal Data for the following purposes:
- to improve the Sites and to enhance, customize, and personalize your experiences and communications with us, including analyzing your behavior and trends, through Automatic Data Collection Tools, to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users;
- if you are not a Client of Reify, we may deliver you promotional newsletter and commercial communications, e.g. via email, SMS or other automated means regarding other products and services different from those referenced herein;
- Based on our legitimate interest, we may process your Personal Data:
- to maintain the integrity of the Sites and our network and address security issues;
- to combine the information collected from any source to create aggregated data ("Aggregated Data") to provide or improve the Sites and Services and facilitate a more targeted, tailored user experience. Reify may use Aggregated Data, as long as such data no longer allow the re-identification of any individual, for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes;
- if you are already a Client of Reify, we may deliver you promotional newsletter and commercial communications regarding our Sites and services. You are provided an opportunity to accept such communications upon the collection of your data and if you accept such communications, you have the right to reject such communications at any time thereafter;
- to investigate or take action regarding violations or suspected violations of applicable law or our Terms of Service and to establish, exercise or defend of legal claims.
- When it is necessary for us to comply with a legal obligation and in any of the Special Circumstances described in paragraph 5 below.
5. WITH WHOM DOES REIFY SHARE YOUR PERSONAL DATA?
We do not share your Personal Data with third parties unless we provide you with advance notice and obtain your prior consent, except when such third parties, which provide services on our behalf to help with our business activities, enter into appropriate data processing agreements with us. These agreements require, among other things, third parties to maintain suitable security measures to safeguard the confidentiality, security, and integrity of your Personal Data. These companies are authorized to use your Personal Data only as necessary to provide these services to us. These services may include but are not restricted to:
- providing customer service
- sending marketing communications
- conducting research and analysis
- providing cloud computing infrastructure
We may disclose Personal Data when we believe disclosure is necessary to comply with Privacy Laws, including to meet national security or law enforcement requirements, or with a subpoena or other legal process, or to protect the rights, property or safety of Reify or of our Clients (collectively, "Special Circumstances"), or respond to a government request.
6. INTERNATIONAL DATA TRANSFER
Your Personal Data may be transferred from any EU Member States to Reify’s servers located in the US only under the specific guarantees established by the Privacy Laws.
Reify Health, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Reify Health, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you can contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
7. CHILDREN’S PRIVACY
The privacy of children is important to Reify. Our Sites are not directed at children, and we do not knowingly collect Personal Data from children who have not reached the age of majority in accordance with the applicable laws.
8. AUTOMATIC DATA COLLECTION TOOLS
As anticipated above, we may collect and process your Personal Data through cookies and other types of Automatic Data Collection Tools used on our Sites. The information gathered by such tools constitute data that, in certain cases, may allow Reify to identify the User by associating such data with other information kept by third parties (such as, for example, the IP address, DNS and registration numbers of the computers used by users connecting to the Sites).
See our Cookie Policy for additional information.
9. THIRD PARTY PRIVACY POLICIES
Once you leave a Site or Service, whether independently or via links, the privacy policies of the Sites to which you migrate will apply. This Privacy Policy applies solely to your interactions with, and information collected through, the Sites and Services.
10. DATA RETENTION
We may retain and process your Personal Data for as long as you continue to access or use any Site and, in general, for the period necessary to achieve the purposes set out above. Where permitted or required by applicable laws, we will retain your Personal Data to comply with our legal obligations, resolve legal disputes and enforce our agreements.
11. YOUR RIGHTS
In relation to the processing of Personal Data covered by this Policy (i.e. when Reify acts as controller), you can at any time exercise your rights in accordance with the Privacy Laws, including:
- the right to access by asking us to provide you with information on how we process your Personal Data and to obtain copies of your Personal Data;
- the right to have incorrect Personal Data duly rectified;
- the right to have your Personal data deleted, in the cases provided for by the applicable Privacy Laws;
- the right to restrict the processing of your Personal Data, where applicable;
- the right to withdraw your consent at any time, in the event your Personal Data is processed based on consent, without affecting the lawfulness of processing based on consent before its withdrawal;
- the right to request portability of the data provided to us or collected through the Open Sites, i.e. receiving them in a structured, commonly used and machine-readable format;
- the right to object to processing that we carry out in our legitimate interests (please see our processing activities listed in section "Basis for Processing" above);
- the right to lodge a complaint relating to the processing of your Personal Data with the competent data protection authority.
You also have a right to object to processing that we carry out in our legitimate interests (please see the processing activities listed in paragraph 4, c) above). To exercise these rights, or for any further information and/or clarifications about this Privacy Policy and the processing of your Personal Data, please write to privacyofficer@reifyhealth.com.
12. CHANGES
We may update this Privacy Policy from time to time without prior notice. Any changes to our Privacy Policy will become effective upon posting of the updated Privacy Policy on our Sites. If we change this Privacy Policy, we will revise the "last modified" date at bottom thereof. For material changes to this Privacy Policy, we will notify you by placing a notice on our Sites’ log-in page(s) or in the relevant home pages, or by sending you a notification directly. We encourage you to bookmark our Internet sites and to periodically review them to ensure familiarity with the most current version of our Privacy Policy.
Last Modified: 04 December 2019
This Privacy Policy applies to the collection of personal information in and from Australia by Reify Health, Inc. (collectively, "we", "us", "our" or "Reify") including through https://www.reifyhealth.com, https://www.studyteamapp.com, and https://www.au.studyteamapp.com, which are owned and operated by Reify(each a "Site"). This Privacy Policy describes how Reify collects, uses, shares, and secures the personal information we collect. This Privacy Policy ("Privacy Policy") is incorporated into and made part of our terms of service for the provision of our services. This Privacy Policy describes Reify's treatment of information, including personally identifiable information ("Personal Information"), that you send us and Personal Information that Reify collects in connection with your access or use of any Site or any service provided by Reify ("Service") and all other data and content that is accessed, utilized, input, or generated in connection with any Site or Service. By accessing or using any Site or Service, you consent to the collection, use, and disclosure of your information, including, but not limited to, Personal Information, in accordance with this Privacy Policy. The use of information collected through our Sites and Services shall be limited to the purposes identified below. Where Personal Information is input in connection with any Services we have been engaged to provide to third party such as a clinical research site ("Client") that information will only be used for the purpose of providing the Services for which the Client has engaged Reify.
Contact Details
If you have any questions, comments or requests regarding this Privacy Policy, please contact the Reify Health Privacy Officer at:
Reify Health, Inc.
Attn: Privacy Officer
33 Arch St., 17th Floor
Boston, MA 02110
Email: privacyofficer@reifyhealth.com
Legal Compliance
Reify Health, Inc. assists Clients engaged in clinical trials in various countries around the world. Reify participates in and has certified its compliance with the EU-U.S and Swiss-U.S. Privacy Shield Framework. Reify Health, Inc is committed to subjecting all personal data received from Australia in accordance with all applicable Australian laws including the Privacy Act 1988 (Cth), and the Australian Principles that form part of that Act ("APPs").
Where medical records or other health information is input into any of our Sites in the course of the provision of Services, that data will be dealt with in accordance with the Australian laws applicable to the protection of those medical records. Where Reify is providing Services to a State government entity within Australia, Personal Information collected in accordance with the provision of those Services will be treated in accordance with all applicable Australian legislation which may include privacy legislation within the relevant State.
What Types of Personal Information Does Reify Gather?
Services may include programs such as StudyTeam in which users with access to Restricted Areas of Reify's Sites (each, a "Registered User") communicate information about clinical research needs and capabilities and monitor and manage the performance of clinical research activities. Reify may collect any information provided or input by you or authorized by you to be provided by a third party in connection with any Site or Service, which information may include, but is not limited to, your name, email and physical address, and telephone number and the name, medical record number, email and physical address, and telephone number (if a patient). We collect information from you when you use Sites or Services, when you fill out a form, upload information, create or use an account, or otherwise supply information to us. When you send email or other communications to us, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve our services.
Reify will also collect Personal Information in the course of its usual business activities. This will include in our communications with potential Clients, in recruiting personnel, in operating our Sites and in fulfilling our legal obligations in each jurisdiction where we carry on business.
If you do not provide Personal Information requested by us we may not be able to provide relevant Services or respond to a communication (including any application) from you.
Privacy and Cookies Policy
We may also automatically collect information regarding your interaction with, and use of, any Site or Service. We may use a variety of methods to collect this information, including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools ("Automatic Data Collection Tools") to administer the Sites and Services, inform user support efforts, and analyze user trends to inform improvements to the Sites and Services user trends to support. These Automatic Data Collection Tools collect certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and click-stream behavior. You may have the ability, through your Internet browser settings, to receive notices regarding, or turn off, certain Automatic Data Collection Tools; however, please note that turning off Automatic Data Collection Tools may negatively impact the functionality or performance of the Sites and Services.
Information may be collected by us or by our vendors who provide internet hosting for the Sites or Services. We may combine information you give us with other information from Reify sources, transactions and communications. We may also combine that information with data from third parties, such as the name of your site or your site's preferred business phone number from your website. This helps us to update, expand, and analyze our records and engage you about new products, services, and features that are most relevant to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or from third parties and combined with information we already have about you, may include:
- The address of your business;
- A phone number associated with your business.
See our Cookie Policy for additional information or to modify your cookie preferences.
How Does Reify Use Your Personal Information?
We use Personal Information in accordance with consents that we have received and also to facilitate the use and receipt of the Sites and Services, and any products or services related thereto, and as further described in this Privacy Policy.
Facilitate Your Use of the Sites and Services. We may use your Personal Information to communicate with you regarding the Sites or Services, your account information or other customer service matters; to respond to your questions and instructions; and, with your prior consent, to enhance, customize, and personalize your experiences and communications with us.
Operate and Improve the Sites and Services. We may use your Personal Information to operate, provide, improve, and maintain the Sites and Services, including analyzing user behavior and trends to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users; to send you administrative messages and other information about Reify and the Sites and Services, including critical updates and notifications; to investigate or take action regarding violations or suspected violations of applicable law or our Terms of Service; and to maintain the integrity of the Sites and Services and our network and address security issues.
Marketing and Promotion Purposes. With your prior consent, we may use your Personal Information to communicate with you about the Sites and Services and other related products and services; and display relevant marketing to you. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in the marketing emails we send to you.
Dealing with Communications. If you communicate with us, whether via a Site or otherwise, we will use any Personal Information you provide to us for the purpose it was provided. For example, if you apply for employment with us, we will use the Personal Information you provide to consider your application. If you request information we will respond to your request. We will also use that Personal Information as permitted by the applicable laws in Australia.
Other Circumstances. We may also access, use, and copy Personal Information as permitted by Australian law.
Aggregated Data. Information collected from any source may be combined to create aggregated data ("Aggregated Data") to provide or improve the Sites and Services and facilitate a more targeted, tailored user experience. Reify may use Aggregated Data for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes.
With Whom Does Reify Share Your Personal Information?
With your prior consent, we may provide your Personal Information to our subsidiaries and affiliates (which today includes and is limited to Reify Health, Inc., and herein is called the "Reify Companies"). Unless not permitted by applicable law, all companies within the Reify Companies may share Personal Information collected through any Site or Service where you have agreed to this Privacy Policy or where you otherwise consent to that sharing.
We do not sell, trade, or otherwise transfer to third parties your Personal Information unless we provide you with advance notice and obtain your prior consent, except as described herein. The term "outside parties" does not include Reify Companies, our website hosting partners, and other parties who assist us with the administration of the Sites or Services, conducting our business, or servicing you, so long as those parties agree to maintain security measures to safeguard the confidentiality, security, and integrity of your Personal Information to a standard that complies with the APPs. Outside parties may have access to Personal Information as reasonably necessary to perform their functions.
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
These services may include:
- Providing customer service
- Sending marketing communications
- Conducting research and analysis
- Providing cloud computing infrastructure
We may disclose Personal Information where we have the consent of the person(s) concerned and otherwise as permitted by Australian law including:
- where we are required or permitted to disclose Personal Information to public authorities, including to meet national security or law enforcement requirements;
- to comply with a subpoena or other legal process;
- to enforce or apply this Privacy Policy or other agreements to which we are a party or which are related to any Site or Service;
- to protect the rights, property or safety of our company, our Registered Users or others;
If our company is acquired by or merged with or into another entity, or if our assets or business is sold or transferred to another entity, your Personal Information may be transferred to such entity as part of the transaction, and that entity and its affiliates may use your Personal Information under the terms of their own privacy policies which may differ from this Privacy Policy. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Transfer of Personal Information outside Australia
Subject to any specific arrangements agreed with our Clients, we may transfer Personal Information collected in Australia to our server located in the United States of America. We may also disclose Personal Information to related bodies corporate or service providers that are located overseas. As a result your Personal Information may be disclosed to a recipient in a foreign country including the USA.
Reify Health, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Reify Health, Inc may be required to disclose personal data in response to lawful requests by public authorities in the USA, including to meet national security or law enforcement requirements.
Access and Choice
Upon request Reify will provide you with information about whether we hold any of your Personal Information. You may seek to access, correct, or update your Personal Information by contacting us at support@reifyhealth.com. We will respond to your request within a reasonable timeframe.
We will comply with any request to access, correct or update your Personal Information except where the Privacy Act 1988 (Cth) or the APP's allow us to refuse to do so. There is no fee for making a request to access, correct or update your Personal Information but we may charge a fee for giving you access to your Personal Information in a mutually agreed format, usually by citing the accessible information held on our records.
If we refuse any request to correct your Personal Information we will notify you of our reason for doing so unless it would be unreasonable to do so and, upon request from you, we will attach a note recording the correction that you sought to the relevant information so that it can be read with that information.
Data Retention
We may store and use your Personal Information for as long as you continue to access or use any Site or Service and to comply with our legal obligations, resolve disputes, and enforce our agreements. Reify may retain your Personal Information for the purposes of audits and review in the course of providing the Services and for the substantiation of other data in the system.
Information Security
Information security is important to Reify. We will take reasonable technical and organizational steps to ensure that the Personal Information we hold is:
- accurate, complete, up-to-date, relevant and not misleading;
- stored in a secure environment; and
- protected from misuse, interference and loss as well as unauthorized access, modification or disclosure.
We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use your Personal Information. In particular, we have obtained the Privacy Shield certification which implies that Reify commits to comply with the Framework's requirements that can be accessed here. However, like other companies, Reify cannot guarantee the 100% security or confidentiality of your Personal Information. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we cannot warrant or guarantee the absolute security of any Personal Information you transmit to, from or through any Site or Service. In the event that we become aware of a security breach involving your Personal Information stored by or for us we will comply with our obligations under Australian law in relation to the notification of that breach. We may also notify you by posting details of the breach to the applicable Site or Service or via email, to the extent available in connection with such Site or Service. You should be aware that Reify has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third party site appears on any Site or Service. In addition, Reify does not control or continuously monitor the activities of users of any Site or Service, and such users may have the ability to provide, access, use and/or disclose data and information, such as your Personal Information, in connection with the Sites and Services.
Please note that some of the content we deliver to or receive from you through the Sites and Services, specifically that of emails and text messages, is unencrypted. And so, transmissions may be unknowingly or unintentionally intercepted by third parties. We do not maintain or have access to your device, phone, e- mail server, or networks outside of our domain and control; therefore, we bear no liability or responsibility for the security or control of content or communications, once delivered to you.
If you have any questions about the security of your personal information, you can contact us at support@reifyhealth.com.
Platform Data Collection and Practices
In the course of providing Services, Reify collects information under the direction of its Clients, and has no direct relationship with the individuals whose Personal Information it processes. Reify may not have the right to access Personal Information held on behalf of particular Clients without their permission. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Upon request Reify will provide you with information about whether we hold any of your Personal Information. Where Reify processes information on behalf of a Client, and has no direct relationship with the individual whose Personal Information it holds, Reify may not have the authority to action requests for access and correction of the information except with the Client's consent. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to Reify's Client.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Reify will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Privacy Policies
Once you leave a Site or Service, whether independently or via links, the privacy policies of the websites to which you migrate will apply. This Privacy Policy applies solely to your interactions with us and information collected through the Sites and Services.
Location of Data and Consents
Our operations are conducted primarily within the United States. Regardless of where you live, unless you have received a specific commitment from us to keep your Personal Information within a specified jurisdiction, you consent to have your Personal Information transferred, processed and stored in the United States. You also agree to and allow Reify to use and collect your Personal Information in accordance with this Privacy Policy. Please note that the Sites and Services are not intended for use by a person in any state or country where such use would be contrary to any applicable laws or regulations.
When you access any Site or Service, your connection may be through and to servers located in your country or the United States. Unless we have specifically agreed to keep your Personal Information within your jurisdiction, any Personal Information you provide may be transferred to, processed and maintained in the United States on servers or other network systems operated by or for Reify's benefit. IF THE JURISDICTION IN WHICH YOU ARE LOCATED OR YOUR COUNTRY OF ORIGIN HAS LAWS OR REGULATIONS WHICH REQUIRE THAT YOUR PERSONAL INFORMATION BE RECEIVED, USED, SAVED, TRANSFERRED OR OTHERWISE HANDLED IN A MANNER DIFFERENT THAN AS STATED IN THIS PRIVACY POLICY, THEN YOU ARE NOT AUTHORIZED TO UTILIZE ANY SITE OR SERVICE. YOU EXPRESSLY AGREE THAT YOU WILL NOT USE ANY SITE OR SERVICE WITH ANY EXPECTATION OF GREATER PRIVACY RIGHTS THAN THOSE TO WHICH YOU HAVE EXPRESSLY AGREED AS STATED IN THIS PRIVACY POLICY OR IN A SEPARATE AGREEMENT WITH REIFY.
Children's Privacy
The privacy of children is important to Reify. The Sites and Services are not directed at children, and we do not knowingly collect Personal Information from children under the age of 16 through the Sites and Services. Children under the age of 16 may not access, use or submit any Personal Information through any Site or Service.
By using any Site or Service, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to Reify will be treated as if provided by an adult. If a child has provided us with Personal Information, a parent or guardian of that child may send an e-mail to privacyofficer@reifyhealth.com with "Request for Child Information Removal" on the subject line and the name and age of the child in the body of the message. Upon verification, we will remove the child's Personal Information from our applicable databases.
Changes
We may update this Privacy Policy from time to time without prior notice. Any changes to our Privacy Policy will become effective upon posting of the updated Privacy Policy on our website located at https://www.au.studyteamapp.com/StudyTeam_Privacy_Policy.html#au-privacy-policy. If we change this Privacy Policy, we will revise the "last modified" date at the bottom of this Policy. For material changes to this Privacy Policy, we will notify you by placing a notice on Reify's log-in page(s) or the home page of Reify, or by sending you a notification directly. We encourage you to bookmark our Internet sites and to periodically review them to ensure familiarity with the most current version of our Privacy Policy.
Requests and Complaints
You have rights to access and correct your Personal Information under Australian legislation including the APPs. If you have any requests or any comments or complaints about how we handle your Personal Information you can contact us using the contact details set out above in this Privacy Policy. We will consider and respond to any request or complaint notified to us within a reasonable time. We will always endeavor to answer your requests efficiently and correctly and try to resolve any complaint you may have about our privacy handling procedures to your satisfaction. In the case of dissatisfaction you may decide to contact the Office of the Australian Information Commissioner ("OAIC"). The contact details for the OAIC are as follows:
Office of the Australian Information Commissioner
Box 5218
Sydney, New South Wales, 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Last Modified: 11 April 2019
This Privacy Policy applies to the collection of personal information in and from New Zealand by Reify Health, Inc. (collectively, "we", "us", "our" or "Reify") including through https://www.reifyhealth.com, https://www.studyteamapp.com, and https://www.au.studyteam.com, which are owned and operated by Reify (each a "Site"). This Privacy Policy describes how Reify collects, uses, stores, shares, and secures the personal information we collect. This Privacy Policy ("Privacy Policy") is incorporated into and made part of our terms of service for the provision of our services. This Privacy Policy describes Reify's treatment of information, including personally identifiable information ("Personal Information"), that you send us and Personal Information that Reify collects in connection with your access or use of any Site or any service provided by Reify ("Service") and all other data and content that is accessed, utilized, input, or generated in connection with any Site or Service. By accessing or using any Site or Service, you consent to the collection, use, storage and disclosure of your information, including, but not limited to, Personal Information, in accordance with this Privacy Policy. The use of information collected through our Sites and Services shall be limited to the purposes identified below. Where Personal Information is collected in connection with any Services we have been engaged to provide to third party such as a clinical research site ("Client") that information will only be used for the purpose of providing the Services for which the Client has engaged Reify.
Contact Details
If you have any questions, comments or requests regarding this Privacy Policy, please contact the Reify Health Privacy Officer at:
Reify Health, Inc.
Attn: Privacy Officer
33 Arch St., 17th Floor
Boston, MA 02110
Email: privacyofficer@reifyhealth.com
Legal Compliance
Reify Health, Inc. assists Clients engaged in clinical trials in various countries around the world. Reify participates in and has certified its compliance with the EU-U.S and Swiss-U.S. Privacy Shield Framework. Reify Health, Inc is committed to treating all Personal Information received from New Zealand in accordance with the Privacy Act 1993 ("Privacy Act"), and any associated codes of practice.
Where medical records or other health information is input into any of our Sites in the course of the provision of Services, that data will be dealt with in accordance with the Privacy Act and Health Information Privacy Code 1994 ("Health Information Privacy Code"), as applicable. Where Reify is providing Services to a government entity within New Zealand, including a District Health Board, Personal Information collected in accordance with the provision of those Services will be treated in accordance with the Privacy Act, Health Information Privacy Code and applicable government policies.
What Types of Personal Information Does Reify Gather?
Services may include programs such as StudyTeam in which users with access to Restricted Areas of Reify's Sites (each, a "Registered User") communicate information about clinical research needs and capabilities and monitor and manage the performance of clinical research activities. Reify may collect any information provided or input by you or authorized by you to be provided by a third party in connection with any Site or Service, which information may include, but is not limited to, your name, email and physical address, and telephone number and the name, medical record number, email and physical address, and telephone number (if a patient). We collect information from you when you use Sites or Services, when you fill out a form, upload information, create or use an account, or otherwise supply information to us. When you send email or other communications to us, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve our services.
Reify will also collect Personal Information in the course of its usual business activities. This will include in our communications with potential Clients, in recruiting personnel, in operating our Sites and in fulfilling our legal obligations in each jurisdiction where we carry on business.
If you do not provide Personal Information requested by us we may not be able to provide relevant Services or respond to a communication (including any application) from you.
Privacy and Cookies Policy
We may also automatically collect information regarding your interaction with, and use of, any Site or Service. We may use a variety of methods to collect this information, including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools ("Automatic Data Collection Tools") to administer the Sites and Services, inform user support efforts, and analyze user trends to inform improvements to the Sites and Services user trends to support. These Automatic Data Collection Tools collect certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and click-stream behavior. You may have the ability, through your Internet browser settings, to receive notices regarding, or turn off, certain Automatic Data Collection Tools; however, please note that turning off Automatic Data Collection Tools may negatively impact the functionality or performance of the Sites and Services.
Information may be collected by us or by our vendors who provide internet hosting for the Sites or Services. We may combine information you give us with other information from Reify sources, transactions and communications. We may also combine that information with data from third parties, such as the name of your site or your site's preferred business phone number from your website. This helps us to update, expand, and analyze our records and engage you about new products, services, and features that are most relevant to you. If you provide us Personal Information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of Personal Information that may be obtained from public sources or from third parties and combined with information we already have about you, may include:
- The address of your business;
- A phone number associated with your business.
See our Cookie Policy for additional information or to modify your cookie preferences.
How Does Reify Use Your Personal Information?
We use Personal Information in accordance with consents that we have received and also to facilitate the use and receipt of the Sites and Services, and any products or services related thereto, and as further described in this Privacy Policy.
Facilitate Your Use of the Sites and Services. We may use your Personal Information to communicate with you regarding the Sites or Services, your account information or other customer service matters; to respond to your questions and instructions; and, with your prior consent, to enhance, customize, and personalize your experiences and communications with us.
Operate and Improve the Sites and Services. We may use your Personal Information to operate, provide, improve, and maintain the Sites and Services, including analyzing user behavior and trends to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users; to send you administrative messages and other information about Reify and the Sites and Services, including critical updates and notifications; to investigate or take action regarding violations or suspected violations of applicable law or our Terms of Service; and to maintain the integrity of the Sites and Services and our network and address security issues.
Marketing and Promotion Purposes. With your prior consent, we may use your Personal Information to communicate with you about the Sites and Services and other related products and services; and display relevant marketing to you. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in the marketing emails we send to you.
Dealing with Communications. If you communicate with us, whether via a Site or otherwise, we will use any Personal Information you provide to us for the purpose it was provided. For example, if you apply for employment with us, we will use the Personal Information you provide to consider your application. If you request information we will respond to your request. We will also use that Personal Information as permitted by the Privacy Act.
Other Circumstances. We may also access, use, and copy Personal Information as permitted by the Privacy Act
Aggregated Data. Information collected from any source may be combined to create aggregated data ("Aggregated Data") to provide or improve the Sites and Services and facilitate a more targeted, tailored user experience. Reify may use Aggregated Data for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes.
With Whom Does Reify Share Your Personal Information?
With your prior consent, we may provide your Personal Information to our subsidiaries and affiliates (which today includes and is limited to Reify Health, Inc., and herein is called the "Reify Companies"). Unless not permitted by Privacy Act, all companies within the Reify Companies may share Personal Information collected through any Site or Service where you have agreed to this Privacy Policy or where you otherwise consent to that sharing.
We do not sell, trade, or otherwise transfer to third parties your Personal Information unless we provide you with advance notice and obtain your prior consent, except as described herein. The term "outside parties" does not include Reify Companies, our website hosting partners, and other parties who assist us with the administration of the Sites or Services, conducting our business, or servicing you, so long as those parties agree to maintain security measures to safeguard the confidentiality, security, and integrity of your Personal Information to a standard that complies with the Privacy Act. Outside parties may have access to Personal Information as reasonably necessary to perform their functions.
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
These services may include:
- Providing customer service
- Sending marketing communications
- Conducting research and analysis
- Providing cloud computing infrastructure
We may disclose Personal Information where we have the consent of the person(s) concerned and otherwise as permitted by the Privacy Act including:
- where we are required or permitted to disclose Personal Information to public authorities, including to meet national security or law enforcement requirements; or
- to comply with a subpoena or other legal process.
We may also disclose Personal Information to:
- enforce or apply this Privacy Policy or other agreements to which we are a party or which are related to any Site or Service; or
- protect the rights, property or safety of our company, our Registered Users or others.
If our company is acquired by or merged with or into another entity, or if our assets or business is sold or transferred to another entity, your Personal Information may be transferred to such entity as part of the transaction, and that entity and its affiliates may use your Personal Information under the terms of their own privacy policies which may differ from this Privacy Policy. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Transfer of Personal Information outside New Zealand
Subject to any specific arrangements agreed with our Clients, and in accordance with our obligations under the Privacy Act, we may transfer Personal Information collected in New Zealand to our server located in the United States of America. We may also disclose Personal Information to related bodies corporate or service providers that are located overseas. As a result your Personal Information may be disclosed to a recipient in a foreign country including the USA.
Reify Health, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Reify Health, Inc may be required to disclose Personal Information in response to lawful requests by public authorities in the USA, including to meet national security or law enforcement requirements.
Access and Choice
Upon request Reify will provide you with information about whether we hold any of your Personal Information. You may seek to access, correct, or update your Personal Information by contacting us at support@reifyhealth.com. We will respond to your request within a reasonable timeframe.
We will comply with any request to access, correct or update your Personal Information except where the Privacy Act allows us to refuse to do so. There is no fee for making a request to access, correct or update your Personal Information but we may charge a fee for giving you access to your Personal Information in a mutually agreed format, usually by citing the accessible information held on our records.
If we refuse any request to correct your Personal Information we will notify you of our reason for doing so unless it would be unreasonable to do so and, upon request from you, we will attach a note recording the correction that you sought to the relevant information so that it can be read with that information.
Data Retention
We may store and use your Personal Information for as long as you continue to access or use any Site or Service, and for any other purposes for which we may lawfully store and use your Personal Information. You authorize that Reify may store and use your Personal Information to comply with our legal obligations, resolve disputes, and enforce our agreements. Reify may retain your Personal Information for the purposes of audits and review in the course of providing the Services and for the substantiation of other data in the system.
Information Security
Information security is important to Reify. We will take reasonable technical and organizational steps to ensure that the Personal Information we hold is:
- accurate, complete, up-to-date, relevant and not misleading;
- stored in a secure environment; and
- protected from misuse, interference and loss as well as unauthorized access, modification or disclosure.
We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use your Personal Information. In particular, we have obtained the Privacy Shield certification which implies that Reify commits to comply with the Framework's requirements that can be accessed here. However, like other companies, Reify cannot guarantee the 100% security or confidentiality of your Personal Information. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we cannot warrant or guarantee the absolute security of any Personal Information you transmit to, from or through any Site or Service. In the event that we become aware of a security breach involving your Personal Information stored by or for us we will comply with our obligations under the Privacy Act in relation to the notification of that breach. You should be aware that Reify has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third party site appears on any Site or Service. In addition, Reify does not control or continuously monitor the activities of users of any Site or Service, and such users may have the ability to provide, access, use and/or disclose data and information, such as your Personal Information, in connection with the Sites and Services.
Please note that some of the content we deliver to or receive from you through the Sites and Services, specifically that of emails and text messages, is unencrypted. And so, transmissions may be unknowingly or unintentionally intercepted by third parties. We do not maintain or have access to your device, phone, e- mail server, or networks outside of our domain and control; therefore, we bear no liability or responsibility for the security or control of content or communications, once delivered to you.
If you have any questions about the security of your Personal Information, you can contact us at support@reifyhealth.com.
Platform Data Collection and Practices
In the course of providing Services, Reify collects information under the direction of its Clients, and has no direct relationship with the individuals whose Personal Information it processes. Reify may not have the right to access Personal Information held on behalf of particular Clients without their permission. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Upon request Reify will provide you with information about whether we hold any of your Personal Information. Where Reify processes information on behalf of a Client, and has no direct relationship with the individual whose Personal Information it holds, Reify may not have the authority to action requests for access and correction of the information except with the Client's consent. An individual who seeks access, or who seeks to correct inaccurate data should direct his or her query to Reify's Client.
We will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client, and for any other purposes for which we may lawfully store and use Personal Information You authorize that Reify may retain your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Privacy Policies
Once you leave a Site or Service, whether independently or via links, the privacy policies of the websites to which you migrate will apply. This Privacy Policy applies solely to your interactions with us and information collected through the Sites and Services.
Location of Data and Consents
Our operations are conducted primarily within the United States. Regardless of where you live, unless you have received a specific commitment from us to keep your Personal Information within a specified jurisdiction, you consent to have your Personal Information transferred, processed and stored in the United States. You also agree to and allow Reify to use and collect your Personal Information in accordance with this Privacy Policy. Please note that the Sites and Services are not intended for use by a person in any state or country where such use would be contrary to any applicable laws or regulations.
When you access any Site or Service, your connection may be through and to servers located in your country or the United States. Unless we have specifically agreed to keep your Personal Information within your jurisdiction, any Personal Information you provide may be transferred to, processed and maintained in the United States on servers or other network systems operated by or for Reify's benefit. IF THE JURISDICTION IN WHICH YOU ARE LOCATED OR YOUR COUNTRY OF ORIGIN HAS LAWS OR REGULATIONS WHICH REQUIRE THAT YOUR PERSONAL INFORMATION BE RECEIVED, USED, SAVED, TRANSFERRED OR OTHERWISE HANDLED IN A MANNER DIFFERENT THAN AS STATED IN THIS PRIVACY POLICY, THEN YOU ARE NOT AUTHORIZED TO UTILIZE ANY SITE OR SERVICE. YOU EXPRESSLY AGREE THAT YOU WILL NOT USE ANY SITE OR SERVICE WITH ANY EXPECTATION OF GREATER PRIVACY RIGHTS THAN THOSE TO WHICH YOU HAVE EXPRESSLY AGREED AS STATED IN THIS PRIVACY POLICY OR IN A SEPARATE AGREEMENT WITH REIFY.
Children's Privacy
The privacy of children is important to Reify. The Sites and Services are not directed at children, and we do not knowingly collect Personal Information from children under the age of 18 through the Sites and Services. Children under the age of 18 may not access, use or submit any Personal Information through any Site or Service.
By using any Site or Service, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to Reify will be treated as if provided by an adult. If a child has provided us with Personal Information, a parent or guardian of that child may send an e-mail to privacyofficer@reifyhealth.com with "Request for Child Information Removal" on the subject line and the name and age of the child in the body of the message. Upon verification, we will remove the child's Personal Information from our applicable databases.
Changes
We may update this Privacy Policy from time to time without prior notice. Any changes to our Privacy Policy will become effective upon posting of the updated Privacy Policy on our website located at https://www.au.studyteamapp.com/StudyTeam_Privacy_Policy.html#nz-privacy-policy. If we change this Privacy Policy, we will revise the "last modified" date at the bottom of this Policy. For material changes to this Privacy Policy, we will notify you by placing a notice on Reify's log-in page(s) or the home page of Reify, or by sending you a notification directly. We encourage you to bookmark our Internet sites and to periodically review them to ensure familiarity with the most current version of our Privacy Policy.
Requests and Complaints
You have rights to access and correct your Personal Information under the Privacy Act. If you have any requests or any comments or complaints about how we handle your Personal Information you can contact us using the contact details set out above in this Privacy Policy. We will consider and respond to any request or complaint notified to us within a reasonable time. We will always endeavor to answer your requests efficiently and correctly and try to resolve any complaint you may have about our privacy handling procedures to your satisfaction. In the case of dissatisfaction you may decide to contact the Office of the Privacy Commissioner ("OPC"). The contact details for the OPC are as follows:
Office of the Privacy Commissioner
PO Box 10 094,
The Terrace,
Wellington 6143
Telephone: 0800 803 909
Email: enquiries@privacy.org.nz
If you’re unable to resolve a privacy dispute, you can file a compliant with New Zealand's Privacy Commission.