PRIVACY POLICY OF REAL LIFE SCIENCES, LLC
Updated 26 March 2024
Real Life Sciences, LLC (“RLS,” “we” or “us”), obtains certain information about Data Subjects from its clients, users of RLS Protect (“the Application”), and/or from rlsciences.com (“the website”) and such information may be considered Personal Data. This Privacy Policy discusses how RLS collects, processes, and stores Personal Data and, where applicable, discusses the rights that Users and Data Subjects have with respect to their Personal Data.
Users and Data Subjects may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, you can refer to the “applicability” section below.
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Owner and Data Processor
Real Life Sciences, LLC: www.rlsciences.com
How to Contact Us
If you have any questions about this policy, or to exercise any of your rights or to make a complaint, contact us at: compliance@rlsciences.com, or
+1-484-537-5700, or
+1-888-651-1551 (toll-free in USA and Canada), or
via postal mail at 565 E. Swedesford Road, Suite 205, Wayne, PA 19087 USA, attn: Privacy Compliance
Types of Data collected
The Personal Data collected by RLS, whether by itself or through the use of the Application or the website, includes: cookies; usage data; first name; last name; email address; physical address; and the user’s state/country.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User(s), or, in the case of Usage Data, collected automatically when using the Application or the website.
Unless specified otherwise, all Data requested by the Application is mandatory and failure to provide this Data may make it impossible for the Application to provide its services. In cases where the Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by the Application or by the owners of third-party services used by the Application, or the website, serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through the Application or via the website and confirm that they have the third party's consent to provide the Data to the Owner.
In addition to the Personal Data referenced above, Owner also collects data from its clients that has been pseudonymized when it is provided to Owner. That data may include personal health information of Data Subjects and other information that may be considered Personal Data; however, using this information as provided to Owner, it is not reasonably practical nor is it in the scope of the Services to assign the data to a specific Data Subject or otherwise re-identify the Data Subject.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Application or the website (administration, sales, marketing, legal, system administration), or external parties (such as third-party technical service providers, email carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users and Data Subjects if one of the following applies:
· Users or Data Subjects have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User or Data Subject objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
· provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
· processing is necessary for compliance with a legal obligation to which the Owner is subject;
· processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
· processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's or Data Subject’s location, data transfers may involve transferring the Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
If broader protection standards are applicable, Users and Data Subjects are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users and Data Subjects can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the “How to Contact Us” section of this policy.
Disclosure of Personal Data to Third Parties
The Owner may disclose Personal Data to third parties, such as our service providers or subcontractors, in order for those third parties to analyze or process Personal Data for us. When we disclose Personal Data for such a purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Data, requires the receiving party to keep the Data confidential and subject to the same privacy protections that Owner places on the Data, and obligates them not to use the Data for any purpose other than performing the services according to their agreement with us.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
· Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
· Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users and Data Subjects may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User or Data Subject has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User or data subject is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, and Performance of Contracts with Clients. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data.”
Detailed information on the processing of Personal Data
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
GOOGLE ANALYTICS (GOOGLE LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of the Application or the website, to prepare reports on its activities and share them with other Google services.
GOOGLE ANALYTICS WITH ANONYMIZED IP (GOOGLE LLC)
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States
Contact in the User of the Application and/or the website
By filling in the contact form with their Data, the User authorizes the Application or the website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: address; company name; email address; first name; last name; state; website.
Performance of Contracts with Clients
As referenced above, Owner obtains certain information regarding Data Subjects in pseudonymized format and that information is processed to fulfill Owner’s contractual obligations owed to its clients, for the purpose of anonymizing the data, analyzing the results of clinical trials and medical research, and related activities.
Personal Data processed for Performance of Contracts with Customers includes but is not limited to: date of birth, sex, race, medical history and related health information, all in pseudonymized format.
The rights of Users and Data Subjects
Users may exercise certain rights regarding their Data processed by the Owner.
Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.
In particular, Users have the right to do the following:
· Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
· Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
· Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
· Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
· Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
· Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
· Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
· Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Data Subjects for whom Owner obtains pseudonymized data may, to the extent possible, exercise the same rights as Users; however, because in most instances Owner does not and/or is unable to re-identify any particular Data Subject, Owner may not be able to fulfill such requests. If a Data Subject requests that Owner fulfill one of the above-enumerated rights, and Owner is unable to do so, Owner will provide the Data Subject with a written explanation as to why the request cannot be fulfilled.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know, however, that should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification by emailing accounts@rlsciences.com.
How to exercise these rights
Any requests to exercise User or Data Subject rights can be directed to the Owner through the contact details provided in the “How to Contact Us” section of this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Applicability of broader protection standards
While most provisions of this document concern all Users and Data Subjects, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.
Such broader protection standards apply when the processing:
· is performed by an owner based within the EU;
· concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
· concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.
Additional information about Data collection and processing
Legal action
The User's or Data Subject’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Application, the website, or the related Services.
The User or Data Subject declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, the Application or the website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, the Application, the website, and any third-party services may collect files that record interaction therewith (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information in the “How to Contact Us” section of this document.
How “Do Not Track” requests are handled
Neither the Application nor the website supports “Do Not Track” requests.
To determine whether any of the third-party services the Application uses honor the “Do Not Track” requests, please read their privacy policies.
Privacy Framework and Personal Information from Outside the U.S.
The Privacy Framework administered by the U.S. Department of Commerce and its European Union (“EU”), Swiss, and United Kingdom (the “UK”) counterparts govern the transfer to the United States and subsequent use, retention and further transfer of personal information collected from data subjects located in the EU, Switzerland and UK (collectively, “the GDPR Jurisdictions”).
From time to time, and as may be required by contracts with our clients, Owner receives transfers of personal information collected from data subjects in the GDPR Jurisdictions. Those transfers are undertaken in accordance with the Privacy Framework, and we have certified to the U.S. Department of Commerce that we adhere to the Privacy Framework Principles. If there is any conflict between the terms in this privacy policy and the Privacy Framework Principles, the Privacy Framework Principles shall govern. To learn more about the Privacy Framework program, and to view our certification, please visit: https://www.dataprivacyframework.gov. The Privacy Framework is predicated on the seven core principles listed below.
The United States Federal Trade Commission (“FTC”) has jurisdiction over our compliance with the Privacy Framework and we are subject to the FTC’s investigatory and enforcement powers. Our adherence to the Privacy Framework may be limited to the extent required to satisfy legal obligations including national security or law enforcement requirements. If there is any conflict between the policies in this privacy policy and the Privacy Framework principles, the Privacy Framework principles shall govern with respect to personal information collected from data subjects in the GDPR Jurisdictions.
Inquiries or complaints regarding our Privacy Framework compliance can be directed to us at the email or physical address or phone number found above in the “How to Contact Us” section of this policy. Directing such inquiry/complaint to the specific attention of “Privacy Framework Inquiries and Complaints” will facilitate a more prompt response.
Unresolved complaints under the Privacy Framework will be referred to EU Data Protection Authorities. If you do not receive timely acknowledgment of your complaint from us, or if your complaint is not satisfactorily addressed, please visit the below for more information and to file a complaint:
For individuals based in the UK: https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/
For individuals based in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt/kontaktformular_uebrige.html
For individuals based in the other GDPR Jurisdictions: https://edpb.europa.eu/about-edpb/about-edpb/members_en
We will cooperate with the independent dispute resolution mechanism to resolve any complaint that is not resolved through our internal processes. Please note that if an individual’s complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available.
Definitions
PERSONAL DATA (OR DATA)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
USAGE DATA
Information collected automatically through the Application (or third-party services employed in the Application), or the website, which can include: the IP addresses or domain names of the computers utilized by the Users who use the Application or website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application or website) and the details about the path followed within the Application or website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
USER
The individual using the Application or website who, unless otherwise specified, coincides with the Data Subject.
DATA SUBJECT
The natural person to whom the Personal Data refers.
DATA PROCESSOR (OR DATA SUPERVISOR)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
DATA CONTROLLER (OR OWNER)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application.
SERVICE
The service provided by the Application or the website as described in the relative terms (if available) and on this site/application.
COOKIES
Small sets of data stored in the User's device.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by posting a revised policy on this page and possibly within the Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.