Privacy Commitment

This Privacy Policy applies to all websites developed, maintained and operated by SPLASH CLINICAL LLC. You are responsible for carefully reading this Privacy Policy in its entirety. This Privacy Policy describes the information we collect about you and how we keep your personal information safe and confidential.

SPLASH CLINICAL LLC understands that privacy is important to you. The information that we collect about you from our websites will be maintained and used in accordance with this Privacy Policy and applicable laws, rules and regulations. By accessing our websites, you agree to the terms and conditions set forth herein. If you do not agree to any of the terms or conditions in this Privacy Policy, please do not access or use any part of our websites.

By providing us with your Personally Identifiable Information (as defined below), including Personal Health Information (as defined below), you consent to the collection and use of any information you provide in accordance with this Privacy Policy.

SPLASH CLINICAL LLC may share information among its subsidiaries and third parties working with or on behalf of SPLASH CLINICAL LLC, and such information shall be protected in accordance with the terms of this Privacy Policy.


SPLASH CLINICAL LLC is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Information We Collect

We will collect information through the use of Cookies (as defined below), Web Logs (as defined below), or IP Address (as defined below). We will only collect Personally Identifiable Information (as defined below) including Personal Health Information (as defined below) if you voluntarily provide such information to us.


Cookies



We collect non-identifiable web usage data about your use of our website through the use of Cookies. A Cookie is a small piece of information that our server sends to your web browser when you access our websites. Every computer that accesses our websites is assigned a different Cookie by SPLASH CLINICAL LLC. Cookies are capable of storing many types of non-identifiable data. Cookies may be used to help us analyze usage of our websites or to restrict underage use of the website. We do not link basic data from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store Personal Health Information about you.

Most browser software can be set to reject all Cookies. Note, however, that some portions of our websites may not work properly if you reject Cookies.

IP Addresses

We may also receive IP addresses in the normal course of the operation of our websites. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

Web Logs

SPLASH CLINICAL LLC uses standard Web Logs that record basic data about your visit to our websites, such as the date and time of the visit, the pages viewed during the visit and the domain name of your Internet service provider.

We do not normally seek to identify individuals from Web Logs. However, we may use Web Logs to identify an individual whom we suspect tried to damage our websites or use them in an unauthorized way. We may share our Web Logs with law enforcement agencies if we believe there has been a violation of computer security or related laws or as otherwise required in order to comply with applicable law or legal process. In addition, we may share our Web Logs (which do not contain any Personally Identifiable Information) with our partners to assist them in better designing their websites for clinical research studies.

Google Analytics

Our websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google") which uses cookies to help analyze how users use the sites. The information generated by the cookies about your use of the websites (including your IP address) will be transmitted to and stored by Google [on SPLASH CLINICAL LLC’s behalf] under Google’s privacy policies:

Google: http://www.google.com/intl/en/analytics/privacyoverview.html

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our websites. By using our websites, you consent to the processing of your information by Google in the manner and for the purposes set out above.

Use and Disclosure of Personally Identifiable Information and Personal Health Information

Personally Identifiable Information that may be collected via a clinical research study survey is information that can be traced back to an individual. Personal Health Information is a combination of your Personally Identifiable Information with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your name, it becomes Personal Health Information. Examples of Personally Identifiable Information include your name, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information.

You may voluntarily provide Personally Identifiable Information and/or Personal Health Information, and if you choose to do so, you consent to our collection and use of such information as described in this Privacy Policy. We will use the Personally Identifiable Information and Personal Health Information that you provide to determine if you may be eligible for research study participation. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SPLASH CLINICAL LLC. Inaccurate information will affect our ability to properly determine if you may qualify to participate in a research study.

While you may view some of our study websites without providing Personally Identifiable Information, this information will be required to be considered for participation in a research study.

We will not use or disclose Personally Identifiable Information or Personal Health Information of users of our clinical research study websites for any purpose other than those described in this Privacy Policy. If these uses change at any time, we will update the privacy policy on our websites. We use and disclose Personally Identifiable Information and Personal Health Information obtained from users in the following ways:

  • COMMUNICATION WITH REGARD TO STUDY REFERRAL PRE-QUALIFICATION AND/OR OTHER STUDY-RELATED PURPOSES
Personally Identifiable Information will be used by SPLASH CLINICAL LLC to follow-up with the clinical study site about your pre-qualification for and participation in the study. 

  • AGENTS AND SERVICE PROVIDERS

We sometimes employ other companies and individuals to perform functions on our behalf. They may need access to your personal information to perform their functions. With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.

We may also be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, in response to a search warrant, subpoena, court order, or other valid legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or be inconsistent with our legal obligations.

Disclosures may also be appropriate in any of the following circumstances: (a) to protect our legal rights or the rights of users of our websites, (b) to protect the security or integrity of our websites, (c) to take precautions against liability, (d) to enforce this Privacy Policy, (e) if SPLASH CLINICAL LLC undergoes any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, (f) to detect, prevent, or otherwise address fraud, (g) pursuant to your explicit approval, or (h) during emergencies if physical safety is believed to be at risk.

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, SPLASH CLINICAL LLC is potentially liable.

Aggregate Data

We will combine the information you provide with information from other visitors to our websites to create Aggregate Data which does not contain any uniquely identifying information. We will share this Aggregate Data with the sponsors of our websites, and/or their consultants. We will periodically analyze this Aggregate Data and use what we learn to make improvements to our websites. We may also share this Aggregate Data with our partners to assist them in better designing their websites.

Children’s Privacy

We are committed to protecting the privacy of children. Neither SPLASH CLINICAL LLC, nor any of its websites or services, are designed or intended to attract children under the age of 13. We do not collect, solicit, or use Personally Identifiable Information from any person we actually know is under the age of 13. If we learn that we collected Personally Identifiable Information from any child under the age of 13, we will endeavor to delete that information as soon as possible. Please contact SPLASH CLINICAL LLC at info@splashclinical.com or phone number (414)-443-3280 if you have reason to suspect that we have collected Personally Identifiable Information of any child under the age of 13.

Data Security

We maintain generally accepted industry standard technical, physical, and organizational procedures to safeguard Personally Identifiable Information and Personal Health Information against unauthorized or unlawful processing and against accidental loss, alteration, disclosure and access. Please note, however, that there are inherent risks in transmission of information over the Internet and electronic storage of information, and we cannot guarantee that unauthorized access or use of your Personally Identifiable Information or Personal Health Information will never occur.

Links to Other Websites


Our websites may contain links to other websites. Please keep in mind when you access websites operated by other parties, whether through links on our website or otherwise, that we do not control what happens on those websites. You should always check the privacy policy of the website you are visiting in order to be sure you know how the operator of that website will collect information from you and what the operator of that website will do with the information.

Internet Transmission Risks

We acknowledge that no internet transmission is ever 100% secure or error free. It is your responsibility to ensure that the computer you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer, there is a risk that the information you provide could be disclosed to unauthorized third parties. Similarly, despite SPLASH CLINICAL LLC’s efforts to protect your Personally Identifiable Information and Personal Health Information, as noted above, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted. 


Rights to Access, Amend, and Delete Information 


SPLASH CLINICAL LLC acknowledges the EU and Swiss individual’s right to access their personal data. We provide you with reasonable access to the Personally Identifiable Information and Personal Health Information that we maintain about you. Subject to any legal requirements, you are given a reasonable opportunity to correct, amend, or delete information that is inaccurate. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe.

Change Notification

As privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by referring to the "last updated" legend at the bottom of this page. Your use of our websites constitutes your acceptance of the terms of the revised Privacy Policy, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms. 


Retention of Personally Identifiable Information and Personal Health Information

We will only maintain Personally Identifiable Information and Personal Health Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it was collected or processed. We will delete Personally Identifiable Information and Personal Health Information when such time period has ended. 


EU-US and Swiss-US Privacy Shield Frameworks

SPLASH CLINICAL LLC complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. SPLASH CLINICAL LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies 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 https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, SPLASH CLINICAL LLC commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact SPLASH CLINICAL LLC at:

SPLASH CLINICAL LLC

 Attn: Privacy Officer

12200 W. Wirth Street

Wauwatosa, WI 53222

info@splashclinical.com

(414)-443-3280

SPLASH CLINICAL LLC has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint from SPLASH CLINICAL LLC, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.




Privacy Contact Information

Questions or comments regarding this Privacy Policy, our practices, or our Privacy Shield participation should be submitted to:

SPLASH CLINICAL LLC

Attn: Privacy Officer

12200 W. Wirth Street

Wauwatosa, WI 53222

info@splashclinical.com


Reservation of Rights

SPLASH CLINICAL LLC reserves the right to share an individual's information as required by law or to duly authorized information requests of government authorities.

This Privacy Policy was last updated on October 13, 2017.