Privacy Policy

The Information We Collect

This privacy notice applies to all information submitted to MediciGlobal via the MediciGlobal’s corporate web site or web sites developed on behalf of clinical trial sponsors. This information is collected in several ways, as described below:

1. On some of our web sites, you can register to receive information from MediciGlobal on an automated "alert" basis. The only personal information collected at this time is your e-mail address. Each time you receive automated e-mail alerts, you have the option of canceling them and removing your e-mail address from the database. To do this, simply click on the “unsubscribe” link at the bottom of the e-mail alert message, and you will no longer receive these alerts.

2. On MediciGlobal’s corporate web site, you have the opportunity to provide personal information to

(a) receive information about MediciGlobal’s services, products, and newsletter;
(b) become a member of the Center for Patient Recruitment®; or
(c) complete an application for possible employment at MediciGlobal. The personal information requested from you is dependent upon the area you select.

3. Also on MediciGlobal’s corporate web site, you can register to receive information specific to your area of therapeutic interest. In order to respond to your request, you will be asked to complete a "Contact Us" form. This form provides you with two options. You may have a MediciGlobal representative contact you directly, or you may have specific information sent to you in the manner that best suits you. The information you provide includes your name, title, company name, address, contact numbers, and e-mail address. Certain information fields are mandatory in order for a response to occur.

4. On certain other web sites developed by MediciGlobal, you can register to obtain access to webcasts, to MediciGlobal’s newsletter Perspectives®, or to information on MediciGlobal’s case studies. Generally, the personal information collected when you register to receive this type of information is your name, company, affiliation, and address. If approved for access, you will receive a password that allows you to obtain more detailed information about MediciGlobal’s products, services, and case studies.

The Way We Use Information

MediciGlobal retains the information you provide in a secure database, which is periodically updated and verified to eliminate outdated information. You may request deletion or updates of your own information at any time. Information provided to MediciGlobal is accessed by employees performing specific functions necessary to accommodate your request. When personal health information is collected for the purpose of a clinical trial, you must provide consent to have this identifiable information shared with third parties, such as clinical research centers. These parties are bound by confidentiality agreements and privacy regulations.

To improve the navigation, content, and design of our web sites, we may from time to time track visitors to evaluate the relevance of the web content. This information is collected in the aggregate and no personal information is specifically used.
Other than the exceptions noted below, your personal identifiable information is used only for the specific purpose for which you have given consent.

Exceptions

Except as noted above, we will not use or disclose personal identifiable information, except in situations required to

(a) correct technical problems and malfunctions related to processing information;
(b) protect the security and integrity of our web sites;
(c) protect our rights and property and the rights and property of others;
(d) take precautions against liability;
(e) respond to a judicial process as required by law; or
(f) provide information to law enforcement agencies as requested.

Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the proper use of personal identifiable information, MediciGlobal has established the appropriate physical, electronic, and managerial procedures to safeguard and secure the personal identifiable information collected online. MediciGlobal’s corporate policy for the protection of the confidentiality of individual identifiable information is in accordance with applicable laws and regulations.

Cookies

“Cookie” is the term given to data used to track your online web activity. A specific “cookie” is placed on the hard drive of your computer when you access a web site that uses this technology. MediciGlobal uses cookies on its web sites in order to

(a) allow site visitors to personalize their experience by accessing information, products, and services relevant to their areas of interest;
(b) track a user session within the confines of a MediciGlobal developed web site;
(c) allow site visitors to access specific study screeners one time only; and
(d) collect data obtained from market research surveys.

An IP address is a number assigned to you by your Internet service provider so you can access the Internet. MediciGlobal receives IP addresses in the normal course of operating its web sites. No personal identifiable information is obtained from this IP address.

Our Commitment to Children's Privacy

Protecting the privacy of the very young is especially important to MediciGlobal. We take every precaution not to collect or maintain information from those we determine to be under 13 years of age. MediciGlobal web sites that specifically offer the ability to self-screen for a clinical research study exclude minors based on age specifications.

How You Can Access or Correct Your Information

To protect your privacy and security, we take reasonable steps to verify your identity before updating, correcting, or removing your information from our database. The information you provide is archived in accordance with our Standard Operating Procedures.

Links to Other Web Sites

Our web site may contain links to other web sites. You should carefully review the privacy policies and practices of other web sites, as we cannot control or be responsible for their privacy practices.

Notification of Changes

As more services are offered on various web sites developed and managed by MediciGlobal, and as privacy laws and regulations evolve, it may be necessary to periodically revise our Privacy Policy. Within 30 days in advance of a substantial change to our Privacy Policy, MediciGlobal will take reasonable steps to notify you through e-mail or regular post mail. We will also post any substantial changes on the home page of our corporate web site.

BBBOnLine® Promoting Trust and Confidence on the Internet

Your privacy is important to us. By participating in the Council of Better Business Bureau's BBBOnLine Program, we have made a commitment to meet the program's strict requirements regarding how we treat your information and have it verified by BBBOnLine. Further information about this program is available at www.bbbonline.org.

The BBBOnLine Program accepts complaints regarding the misuse of personally identifiable information by a web site operator. Participants are required to work with the program's dispute resolution process. For more information about the BBBOnLine Program dispute resolution process visit www.bbbonline.org/privacy/dr.asp.

Dispute Resolution

Individuals are first encouraged to contact MediciGlobal directly with any concerns or complaints. During the initial call to the call center, the customer service representative first seeks authorization from the subject to include the subject’s personal information in the database. Those who so consent are then advised that they may contact MediciGlobal via a toll free telephone number. Visitors to MediciGlobal website are advised likewise, via MediciGlobal's privacy and security policy. Internet users may also contact MediciGlobal via email.

When MediciGlobal receives a complaint or concern regarding the privacy of individual health information, the chief privacy officer will direct the investigation of the complaint/concern. MediciGlobal is dedicated to providing a timely response to any concern. Nonetheless, MediciGlobal recognizes that the initial resolution may not be satisfactory to some individuals. Therefore, MediciGlobal is committed to cooperating with the Data Protection Authorities (DPAs). In the event that a complaint is escalated to the DPAs, MediciGlobal will cooperate with the investigation and resolution of such complaints. MediciGlobal is firmly committed to ensuring that appropriate actions are taken to comply with Safe Harbor Principles, including appropriate remedial or compensatory measures in response to instances of non-compliance. In the event that such measures are necessary, MediciGlobal will provide the DPAs with written confirmation of such action.

Safe Harbor

The company is self-certified to and abides by the principles of the Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. For more information about the Safe Harbor program, please visit the U.S. Department of Commerce's Safe Harbor Web site http://export.gov/safeharbor/.

How to Contact Us

You may update or remove the information you provided to MediciGlobal by contacting our Privacy Officer at 1.877.271.6914 or sending an e-mail to PrivacyOfficer@MediciGlobal.com.

This privacy policy was last updated on July 14, 2009.

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