Last updated: February 12, 2020
I. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on your relationship with us.
Information You Provide to Us.
Your Communications with Us. We collect personal information from you such as name, email address, phone number, or mailing address when you request information about our Services, register for email alerts, request customer or technical support, apply for a job, or otherwise communicate with us. We may also provide you with opportunities to sign up to receive specific information about our products and research, and we may ask for information (including your name, home address, home phone number or personal email address, and information about specific health conditions, diagnoses, or treatment), so that we can send you specific information about our products, services and specific health conditions, with your consent.
Customer Service and Support. If you call or otherwise interact with Sutro’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives, including for training and quality assurance purposes.
Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Sutro and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Information about Healthcare Providers. We may collect information from healthcare professionals as part of marketing activities to healthcare professionals, including first name, last name, age, gender, home address, home phone number, medical specialization, professional qualifications, license number and/or scientific society membership number.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We may offer interactive features such as forums, blogs, chat or messaging services, or social media pages. Sutro and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Sutro.
Information Collected From Trials and for Regulatory Purposes
Information Collected to Comply with Regulatory Obligations. We are obligated to collect certain personal information to comply with regulatory requirements, including information relating to adverse effects experienced when using our products.
Information Collected Automatically or From Others
Information Related to the Use of the Services. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
II. HOW WE USE PERSONAL INFORMATION.
We use personal information for a variety of business purposes, including:
To fulfill our contracts and provide you our Services, such as:
Providing access to certain areas, functionalities, and features of our Services;
Communicating with you about activities on our Services and policy changes;
Responding to questions, comments, and other requests, including for customer or technical support;
Undertaking activities to verify or maintain the quality or safety of a product or service;
Providing advertising, analytics and marketing services; and
Processing applications and transactions.
For administrative purposes, such as:
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Undertaking research for technological development and demonstration;
Researching and developing our products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control;
Verifying identity and preventing fraud;
Debugging to identify and repair errors that impair existing intended functionality;
Enforcing our terms and policies; and
Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
To provide you with additional content and Services, such as:
Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
Auditing relating to interactions, transactions and other compliance activities; and
Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
Automated profiling. We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
Notice Regarding Third Party Websites and Social Media Platforms. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
We may share any personal information that we have collected from or regarding you as described below:
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; organizations involved with clinical trials and their staff; customer service providers; and vendors to support the provision of the Services.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share personal information with our affiliated companies.
Third Parties. We may share de-identified or aggregated information, including, without limitation, de-identified data, demographic information, information about the computer or device from which you access the Services and other analysis that we create based on information we receive from you and other users, with third parties for research and analysis, promoting the services, demographic profiling and other similar purposes.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
IV. INTERNATIONAL DATA TRANSFERS.
You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
V. YOUR CHOICES.
You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.
“Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Your Privacy Rights.
In accordance with applicable law, you may have the right to request:
Access to/Portability of personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have electronic personal information transferred to another party.
Correction of personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update personal information or we may refer you to the controller of personal information who is able to make the correction.
Deletion of personal information, subject to certain exceptions prescribed by law.
Restriction of (or object to) processing of personal information, including the right to opt in or opt out of the sale of personal information to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
VI. DATA RETENTION.
VII. SECURITY OF YOUR INFORMATION.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
VIII. CHILDREN’S INFORMATION.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
IX. OTHER PROVISIONS.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.