Last Updated: January 9, 2023

1.0 INTRODUCTION

Altasciences (“we,” “us,” or similar) understands the importance of privacy and we take our responsibility to protect your personal information seriously.  This Privacy Policy (“Policy”) describes the types of personal information we collect, how we use and disclose the information, and certain rights and options individuals have regarding their information.  This policy applies to information we collect through our websites (collectively, the “Website”). 

For the purposes of this website, personal information means any information relating to an identified or identifiable natural person.  Please review this Policy carefully before sharing information with us so you understand our practices with regard to personal information.  By visiting or using the Website, communicating with us via the Website, or submitting information to us via the Website, you agree to the terms of this Policy. 
 

2.0 COLLECTION AND USE

2.1 WEBSITE VISITORS

If you are a Visitor to our website only, and not a registered Participant for our studies, then this section is relevant for you.

2.1.1 Information Collected Directly From You

When you visit or use this Website, you may choose to provide us with personal information about yourself in a variety of different ways, including when you fill out forms, provide information where prompted on the website, and communicate with us through functionality on the website.  The categories of personal information we may collect from you include the following categories. 

• Contact information – first name, last name, mailing address, email address, job title, company name, company address, company email address, country where you are located, country where your company is located, and telephone number.
• Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Customer account and web portal information – username and password for access to account and log-in portals on the website
• Communications information – copies of communications and inquiries you have submitted to us through features available on our website, including our “Contact Us” forms located throughout the Website.
• Device and usage information – details regarding how and when you use our website, including the geolocation data of your device, the device used to connect to our website, your IP address, the frequency and duration of your usage, the pages you view and related pageview activity, what websites or search terms referred you to the website, and information about your interaction with our website.
• Job applicant information – current employer, current position, prior work history and education, resume information, and qualifications for employment.

We typically determine the purposes and means of processing the information we collect directly from visitors to our website and, as such, are the “data controller” for such information under the EU’s General Data Protection Regulation (“GDPR”). If you are a UK or EU resident, see the “EU/UK Resident” section below. 

2.1.2 Anonymized and Third-Party Information

We may aggregate or anonymize the data we collect directly from Website visitors such that they are no longer capable of identifying an individual, in which case they are no longer considered “personal information” and may be used for any purpose, to the extent permitted by applicable law. 

2.1.3 Cookies and Other Technologies

Like most companies, we use various technologies to automatically collect information about website visitors.  The technologies we use, how we use them, and options for managing the information collected through the technologies are described below.

• Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes.  Cookies may be unique to the browser or mobile application you are using.  We use cookies to personalize visitors’ experiences on our website, provide content that we may believe may be of interest, track visitor trends and patterns, identify specific pages that you click on and where you scroll, locate the country where you are visiting from, engage in marketing and advertising, and otherwise analyze our website traffic.  For further information, see our Altasciences Cookie Policy.
• Log Files and Device Identifiers.  We use log files to track actions occurring on the website and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Web beacons and other technologies.  We may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
• Analytics Tools. Our website may also use third-party analytics tools such as Google Analytics.  Analytics are used to create reports and statistics on the performance of our website and present you with content tailored to your interests.  Analytics can be used to collect information such as IP address, type of device, operating system, referring URLs, country information, date and time of page visits, and which pages you visit the most.  You can find more information about how data is collected and processed in connection with the Google Analytics service here.  You can also read Google’s privacy policy here. Google has developed an opt-out browser that you can use here. 

2.1.4 Purpose of Processing Personal Information

Altasciences uses the personal information it collects for the following purposes. 

1. Communicating with visitors, including responding to inquiries submitted through our website, providing you with information that you may request about our business and services, and otherwise communicating with you about our services. 
2. Sending promotional or marketing communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
3. Customizing content for visitors, including improving your experience on our Website, ensuring content is presented to you in the most effective manner, and otherwise improving our website. 
4. Administering our services, including communicating with customers or potential customers. 
5. Inviting you to seminars, webinars, or similar events that we are hosting or sponsoring.
6. Preventing or detecting fraud, hacking activities, security breaches, or safety risks in connection with our website.
7. Notifying you about changes to our website and material changes to this Policy.
8. Performing other functions as otherwise described to you at the time of collection or to which you otherwise specifically consent.
    

2.2 STUDY PARTICIPANTS

This section applies to those participating, or having a wish to participate, in our studies (collectively, “Study Participants”). The information provided below is in addition to the collection, use and sharing practices described elsewhere in this Policy. 

2.2.1     Information Collected Directly From You

When you register for a clinical study using the Website, Altasciences may collect, record, and analyze information about you, including the following categories: 

• Contact information – first name, last name, mailing address, email address, country where you are located, and telephone number.
• Eligibility and study information – the information we collect for determining eligibility for a study and as a participant in a study will vary depending on the nature of the study but could include Sensitive Personal Data (as defined by the GDPR) such as medical and biological information. 
• Marketing information – details regarding your communication preferences and willingness to participate in future studies, and copies of communications and inquiries you have submitted to us.
• Account and web portal information – username and password for access to account and log-in portals on the website.

Our customers and sponsors typically determine the purposes and means of processing the information we collect directly from Study Participants and, as such, we are the “data processor” for such information under the EU’s General Data Protection Regulation (“GDPR”). If you are a UK or EU resident, see the “EU/UK Resident” section below. 

We may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying an individual, in which case they are no longer considered “personal information” and may be used for any purpose, to the extent permitted by applicable law. 

2.2.2 Purpose of Collecting and Processing Personal Information

Altasciences uses eligibility information collected from Study Participants purely for determining Participants’ eligibility for studies they may wish to participate in and for customizing the display of studies for participants. If the participant volunteers for a study and goes through the screening process, then the Personal Data collected from the Participant becomes part of the record of the study even if the participant does not pass the screening process or otherwise drops out of the study.

Altasciences may also use the information it collects to respond to a request to participate in a study, responding to inquiries submitted through our website, and providing Study Participants with information about other clinical trials in which they may be interested.

Altasciences does not share personal information for Study Participants except with business affiliates participating in the running of the study, or as pseudonymized data as part of the study record and as required by regulations.

3.0 SHARING PERSONAL INFORMATION

Except as noted above, we may share your personal information with the following categories of recipients: 

• Our corporate affiliates for our legitimate administrative and business purposes as permitted by law. 
• Our customers in the performance of our obligations pursuant to our customer agreements. 
• Suppliers, service providers, and other third-party vendors who perform services on our behalf, such as our email service provider, IT security providers, website hosting service provider, and other similar companies that support our business. 
• Buyers or successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred. 
• Owners or successors if Altasciences (or part of its business) is sold or otherwise changes control, where new owners would have access to your personal information.
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
• Analytics vendors in order to understand our website traffic and usage patterns, optimize our website, and identify potential new customers.
• Other website visitors when you provide us with a review or comment. By providing us with a review or comment, you authorize us to publish it on all of our websites. You also authorize us to aggregate it with other reviews.
• Other parties for any purpose we disclose at the time you provide the information.

We may disclose personal information if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your personal information if the disclosure is necessary for the prevention, detection, or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.  

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

4.0 INTERNATIONAL TRANSFERS

Please be aware that Altasciences has operations in the United States, Canada, and elsewhere. As a result, your information may be transferred to the United States, Canada, or jurisdictions where Altasciences has operations. The data protection laws in these locations may be different from your home country. Altasciences has adopted, and has caused to be adopted by its affiliates,  reasonable physical, technical, and organizational safeguards which substantially mirror the EU and Quebec safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use or processing of the data subject’s data in Altasciences’ possession. Altasciences will promptly notify the data subject in the event of any known unauthorized access to, or use of, the data subject’s data.

As indicated above, Altasciences may process personal information of EU data subjects [as a “controller” (in the case of Website visitors) and a “processor” (in the case of Study Participants], as defined in the EU’s General Data Protection Regulation (“GDPR”). All personal information of data subjects residing in the EU will be stored exclusively in secure data centers located in Canada where possible, which has received an Adequacy Decision from the EU (Commission Decision 2002/2/EC) or in locations that comply with the Standard Contractual Clauses in accordance with GDPR regulations. 

5.0 YOUR RIGHTS

You have the right to:

• Withdraw consent to data processing at any time;
• Access your personal information, including confirming Altasciences is processing personal information about you and requesting a copy of your personal information;
• Correct any inaccuracies in your personal information; 
• Erase your personal information;
• Data portability, meaning to request a transfer of your personal information from us to any other person or entity as chosen by you; 
• Restrict the processing of your personal information. 
• Object to the processing of your personal information; and
• Lodge a compliant with a supervisory authority.

You can manage your account settings in the Participant Lounge on our Website (“Portal”). You can also request deletion your account at any time. Please note that if you are a Study Participant, your Portal data may be deleted but your personal information will be kept in accordance with applicable laws, rules, and regulations.

You will not typically need to pay a fee to exercise any of the rights, but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.  Alternatively, we may refuse to comply with your request in such circumstances.

Subject to exceptions, if you wish to exercise one of the rights identified above with regard to personal information subject to this Policy, you may do so by submitting a request to privacyofficer@altasciences.com.  Once we have received your request, we will review it and contact you within 30 days of our receipt of your request, but we will notify you of any delay and, in any event, will reply within three (3) months.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).  We may request proof of your identity before providing this information.  Please note that certain legal requirements, including those applicable to Altasciences’ study conduct, accounting, processing of claims, and mandatory data retention, may prohibit Altasciences from complying with a data subject request, including the deletion or anonymization of personal information.

6.0 RETENTION AND DELETION

Altasciences stores your data on its servers located in Canada (this may include locations that are located outside of Quebec) and the United States. We make the security of your data our priority and have various measures to ensure safety that are in line with industry best practices, including firewalls, proxy servers and security monitoring at all times. Altasciences will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. In accordance with regulations, if you have been screened for, or participated in, a study then your data may not be deleted and must be kept on file. If you have applied to participate in a study and then requested that your data be deleted, even if you have not participated nor been screened for a study as noted above, you will be ineligible to apply for another study for a period of one year, and your name will be kept on file for one year to ensure that the eligibility requirement is met but all other information will be deleted immediately. Website data and collected information, if not currently being used for legitimate business purposes as described and explained in this document, will be deleted after three years.

We may not be able to allow you to access certain personal information in some cases. For example, if your personal information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information.

7.0 EU/UK RESIDENTS

7.1 LAWFUL BASIS UNDER GDPR where possible

As a “controller,” our lawful basis for processing your information is typically either to (1) fulfill our legitimate business interests (such as ensuring the safety, security, and functionality of our website), (2) comply with a legal obligation, or (3) conduct processing to which you have specifically consented. 

When we process your personal information as a “controller” for the purposes described in Sections 2.1.3.c and 2.1.3.f - h above, our lawful basis is our legitimate interest to present and optimize our Website, detect, and prevent potential security issues on our Website, and develop and improve our service offerings.  Likewise, when we process your personal information for the purposes described in Sections 2.1.3.a and 2.1.3.d - e, our lawful basis is our legitimate interest to monitor the efficacy of our marketing efforts, respond to inquiries about our business and services, and promote our service offerings.  When we send promotional communications to you as described in Section 2.1.3.b, our lawful basis is typically your express consent.  Where we use your personal information for our legitimate interests, we evaluate any potential impact of the processing on your rights and freedoms as required by the GDPR.

If you are located in the EEA and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA.  

8.0 CALIFORNIA RESIDENTS

If you are a California resident, please refer to our Privacy Notice for California Residents  for a description of rights available to you under California Law.

California’s “Shine the Light” law allows California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding year.  If you are a California resident and wish to make such a request, please send an email with “California Shine the Light” in the subject line to the email and/or regular mail address provided below under “Contact Details.”

9.0 LINKS TO OTHER SITES

Our Website may also contain links to websites that are not operated by Altasciences or its affiliates. This Policy does not apply to personal information collected through such websites. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through those websites, nor any association with their operators. Altasciences does not control these websites and is not responsible for their data practices. Any information you provide to third parties via their websites is covered under such third parties’ privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information.

10.0 CHANGES TO THE POLICY

We may modify this Privacy Policy at any time and without prior notice. We will notify you of material changes to how we use your personal information prior to implementing them by banner or other conspicuous method on our Website. By using our services and Website after we post these changes, you are indicating that you accept them.

11.0 CHILDREN

Altasciences does not knowingly collect personal information from minors. If we become aware that a minor is attempting to submit personal information, we will remove this information from our records. If you believe we have collected or obtained information from a minor, contact us at the “Contact Details” information provided below.

12.0 DO-NOT-TRACK DISCLOSURE

Please note that we do not alter our website’s data collection and use practices when we see a “Do Not Track” signal from your device.

13.0 CONTACT DETAILS/DATA PROTECTION OFFICER

The Privacy Officer for Altasciences is Simon Lane, VP, Information Technology. To exercise your rights, or if you have questions about our privacy practices or need assistance with exercising or understanding your privacy choices, please contact us using the following information.

Altasciences
Attn: Privacy Officer
Email: privacyofficer@altasciences.com
575 Armand-Frappier blvd.
Laval (Quebec) H7V 4B3

14.0 CONTACT DETAILS/DATA AUTHORITIES FOR QUEBEC RESIDENTS

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact:

QUÉBEC (headquarters) Bureau 2.36 525, boulevard René-Lévesque Est Québec (Québec) G1R 5S9
Telephone: 418 528-7741 Fax: 418 529-3102
MONTRÉAL Bureau 900 2045, rue Stanley Montréal (Québec) H3A 2V4
Telephone: 514 873-4196 Fax: 514 844-6170
TOLL-FREE LINE FOR BOTH OFFICES 1 888 528-7741
E-MAIL cai.communications@cai.gouv.qc.ca WEB SITE www.cai.gouv.qc.ca