Privacy Policy

Version 1.0, 24 May 2018

This Privacy Notice is provided by United BioSource Corporation (“UBC”, “we”, “us” or “our”) to all visitors (“you” or “your”) who use the available pages of the UBC.com website located at http://www.UBC.com/ (the “Site”). This Site is provided to you as a service to share information with the pharmaceutical and biotech industry.

We are firmly committed to protecting the confidentiality of your Personal Information. The term “Personal Information” means any information which can be used to directly or indirectly identify you including by way of example, but not limitation, name, date of birth, mailing address, phone number, cell phone number, e-mail address and/or any device ID (such as your IP address), either by itself or when linked with other Personal Information.

We comply with applicable data protection legislation, including European data protection laws. UBC, LLC. operates the Site and is the data controller in respect of your Personal Information for the purposes of European data protection law. In accordance with these laws, we have appointed UBC Late Stage (UK) Limited (26-28 Hammersmith Grove, London, W6 7HA (UK)) as our representative in Europe.

What does this Privacy Notice cover?

This Privacy Notice describes how we will make use of your Personal Information on the Site and during your interactions with us, including any Personal Information we use to send you direct marketing (for example, to contact you about future clinical studies using Personal Information submitted via the Investigator Registration Page). It also describes your data protection rights – more information about your rights, and how to exercise them.

Summary of How We Collect and Use Your Personal Information

  1. Correspondence: When available, you may sign up for an informational newsletter and/or site updates from UBC by providing your Personal Information through the Site. You may unsubscribe from receiving further such correspondence by following the included opt-out instructions.

  2. Investigator Registration:You may apply to become an investigator on behalf of UBC by submitting an application available through the Investigator Registration Page on the Site. You will first need to review and accept the additional Terms and Conditions (the "Additional Terms and Conditions") associated with the application. If you accept the Additional Terms and Conditions, you can submit Personal Information and other information necessary to determine your applicability for being an investigator with current and future studies. We may then contact you regarding studies on which we believe that you may be a good candidate to participate. By submitting your Personal Information via the Investigator Registration Page, you agree that you would like to receive such emails from UBC – you can withdraw this consent at any time.

  3. Clinical activities: Where you are assisting with a clinical study, Personal Information collected in connection with your participation in the study will be kept on file by UBC so that we can contact you with information about products, services, future study opportunities and events, which may be of interest to you. This Personal Information may include your [name, gender, date of birth, work and/or personal contact details (phone, email and physical address), job title, professional experience, education, performance history, training records, skills etc.]

  4. Cookies and Other Tracking Technologies: We use cookies and other tracking technologies to personalize content and advertising and to make our content function better on the Site. Click here to learn more.

How We Use Your Personal Information and the Legal Grounds for Such Use

We use the information that we collect for the following purposes:

Purpose

Legal grounds for use (EU)

To send you informational newsletters about UBC.

Individuals' consent where required or legitimate interests (i.e. keep you informed of UBC activities)

To communicate with you about opportunities matching your interests – for example, to determine whether you may be a good candidate for a study and to communicate with you regarding the study.

Individuals' consent where required and legitimate interest grounds (i.e. ensure you are provided with meaningful communications about potential studies and recruiting individuals for future clinical trials)

To perform our contractual obligations with study sponsors (including but not limited to administration of client relations and of payment transactions).

Contractual necessity, legal requirements, legitimate interest grounds (i.e. assessing your eligibility for a sponsor project)

To assist us with customizing, analyzing and improving our products and services that are utilized by you as part of a study.

Individuals' consent where required and legitimate interest grounds (i.e. making improvements to our products and services by obtaining feedback from you in relation to those products and/or services that you utilized as part of your involvement in a study)

To compile statistics and analysis about the use of our Site and related services, which statistics are only used to enable us to provide a better service, features and functionality to you and other Site users.

Individuals' consent and legitimate interest grounds (i.e. ensure that our services function smoothly and we understand your interests)

To help prevent fraud and other prohibited or illegal activities.

Legal requirements

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later below.

Wherever we rely on consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by (i) following the instructions in the communication where this is an electronic message, (ii) unsubscribing via the following link https://www.surveymonkey.com/r/Email-Removal.

Cookies and Other Tracking Technologies

Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies:

[Category 1: Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or submitted information cannot be provided.]

[Category 2: Performance Cookies

These cookies collect anonymous information on how people use our Site. For example, we use [Google Analytics] cookies to help us understand how customers arrive at our Site, browse or use our Site and highlight areas where we can improve such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.]

[Category 3: Functionality Cookies

These cookies remember choices you make such as the country you visit our Site from, language and search parameters such as size, color or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other sites.]

[Category 4: Targeting cookies or advertising cookies

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the sites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as [Criteo] to provide you with more personalized adverts when visiting other sites.]

[Category 5: Social Media Cookies

These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.]

We may use different kinds of cookies including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve the Site, Site content, and the services we offer. These cookies are deleted from your hard drive when you close your browser session. Persistent cookies are used to collect information such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks.

Data Sharing

We will share your Personal Information with other UBC group companies (such as UBC Late Stage (UK) Limited – for more details: http://www.ubc.com/contact/locations) as necessary to provide the products and services you have requested and to fulfill any of the other purposes set out above.

We will also share your Personal Information with third party service providers, who will process it on behalf of UBC for the purposes above. Such third parties include, but are not limited to, IT service providers (including customer relationship management vendors), payment providers, expense management, banks, emailing providers, etc.

In certain circumstances, we may be legally compelled to share your Personal Information with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law (for example, in response to a court order, subpoena, search warrant, law or regulation) or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Where information is transferred outside the EEA (e.g. US, Switzerland, Canada) and where this is to a UBC affiliate or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or an appropriate Privacy Shield certification. A copy of the relevant mechanism can be provided for your review on request to the:

Data Retention

Except to the extent prohibited by law, and subject to this Privacy Notice if you are a client/sponsor or individual, we will retain and use your Personal Information for as long as your account is active, as needed to provide you the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we process Personal Information for marketing purposes or with your consent, we process the data until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process Personal Information to perform our contractual obligations with study sponsors, we keep the data in accordance with contractual obligations with the sponsor.

Where we process Personal Information to meet legal requirements, we hold this for as long as the law requires (for examples, we may hold records to help prevent fraud and other prohibited or illegal activities).

Your Rights Regarding Your Personal Information

Where allowed by law, such as in the EEA and Switzerland, you have the right to ask us for a copy of your Personal Information; to correct, delete or restrict (stop any active) processing of your Personal Information; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.

In addition, you can object to the processing of your Personal Information in some circumstances (including where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below.

Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register or otherwise engage with UBC. All other provision of your information is optional.

If you are resident in the European Union and you have unresolved concerns or at any time do not believe that we have complied with this Privacy Notice, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

Linking Policy

Our Site may contain hyperlinks allowing our users to connect to other websites owned by us and our affiliated companies and websites owned by our third-party vendors, distributors, and providers (“Linked Sites”). You may also access our Site through a hyperlink embedded in a Linked Site. We provide hyperlinks to the Linked Sites to enable you to conveniently access websites that may be of interest to you. Please note that once you click on a hyperlink that transfers you from our Site to a Linked Site, you have left our Site, and this Privacy Notice will immediately cease to apply to any subsequent activity on the Linked Site. We are under no obligation to notify you when you have left our Site and have accessed a Linked Site. Use of any Linked Site will be governed by the privacy notice, terms of use, and/or other policies (if any) on the Linked Site. Accordingly, we recommend that you review the privacy notice posted on any website that you may access through our Site. You may, at your option, participate in surveys or provide other information to our affiliates that control a Linked Site, and that information may be shared with us or with others subject to the privacy terms set forth on that Linked Site. Certain information that you choose to provide through a Linked Site (such as comments) that is subsequently provided to us by the Linked Site provider in connection with a service engagement may be identifiable to us as your Personal Information.

Changes in Your Privacy Notice

We use Personal Information within the scope of use described in this Privacy Notice. However, we reserve the right, from time to time in our sole and absolute discretion, to change, to modify, or to add terms or remove terms from this Privacy Notice. Changes to this Privacy Notice will be reflected when we post a new version number and updated revision date. Therefore, we recommend that you check the version number and revision date prior to using the Site, and that you review this Privacy Notice on a frequent basis. Any substantive or material change to the Privacy Notice will be brought to your attention – for example, by including a pop-up notice on the website. Your continued use of the Site after this Privacy Notice has been updated, as shown in the version number and revision date, indicates your agreement and acceptance of this Privacy Notice, including all changes made as of the date of your use of the Site.

Data Protection Officer

In the event that you have a question regarding this Privacy Notice, UBC’s data protection practices/procedures or personal data processing, you can contact our data protection officer at: