PSI Privacy Notice to California Residents

Last revision of on 30 June 2020

This Privacy Notice for California Residents (“Notice”) from PSI CRO AG and its worldwide affiliates (“PSI”, “we”, “our”) supplements PSI’s Data Protection Policy, the Data Privacy Policy of PSI Pharma Support America, Inc., and PSI’s Cookie Notice. This Notice applies solely to residents of the State of California (“you”, “your”).  PSI adopts this Notice to the extent that the California Consumer Privacy Act of 2018 (“CCPA”) applies to PSI with regard to the collection and processing of personal information of California residents (“CCPA Personal Information”).  

For purposes of this Notice, CCPA Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA Personal Information”).  

As used in this Notice, the term CCPA Personal Information does not include:

  • Publicly available information that is lawfully made available from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA);
  • Information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the United States Food and Drug Administration; and
  • Personal information covered by other sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Driver’s Privacy Protection Act of 1994, and the federal Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act

CCPA PERSONAL INFORMATION PSI COLLECTS

In the past twelve (12) months, PSI has collected the following categories of CCPA Personal Information: 

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, login credentials, social security number, driver’s license number or similar state-issued ID number and information, passport number and information, or other similar identifiers. 
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including signature, physical characteristics or description, address, telephone number, insurance policy number, education, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of protected classifications under California of federal law, such as age, race, national origin, marital status and history, medical condition, physical or mental disability, gender, information relating to pregnancy or childbirth, sexual orientation, or veteran or military status;
  • Internet or other electronic network activity information, including, but not limited to, browsing history, setting preferences, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. 
  • Professional or employment-related information, including but not limited to current employment and employment history, language skills, training history, resume or CV, job title and function, specialty, licenses, professional memberships, certifications, performance evaluations, awards, publications, professional opinions, advice, or consultations, and financial compensation information. 

SOURCES OF CCPA PERSONAL INFORMATION

Depending on your interaction with PSI, PSI collects the above categories of CCPA Personal Information from the following sources:

  • Directly from you. 
  • Directly or indirectly, via the PSI website, including technical and usage information we automatically collect when you use our website. For more information regarding PSI’s collection of information or data via our website, please see PSI’s Data Protection Policy.
  • If you are a healthcare professional potentially interested to participate in clinical studies conducted by PSI, we may obtain the information to contact you from some publicly available, as well as legitimate nonprofit and commercial databases offered by professional networks and communities. We may also receive some personal information from our previous relationship with the sponsors of clinical studies and medical institution where the healthcare professional works, websites of such medical institutions, from scientific publications and academic conferences.

PURPOSES FOR WHICH WE COLLECT AND USE CCPA PERSONAL INFORMATION

We may use CCPA Personal Information for the following business and commercial purposes:

  • To respond to inquiries and manage subscriptions.
  • To provide you with services, and customer support.
  • To bill you for services you request.
  • To identify and contact individuals to ascertain their interest in participating in clinical trials in accordance with their experience, specialty, availability, and other factors. 
  • To enable screening, selection, and hiring of job applicants/candidates and to communicate with them.
  • To manage payroll and benefits of current employees, make decisions regarding employment (promotion, salary reviews, discipline), and for other human resource administration and management purposes.
  • To market services to you.
  • For legal and operational compliance and to conduct audits.
  • To enable and improve our internal processes.
  • To improve the contents of and user experience for our website.
  • As described to you when collecting CCPA personal information or as otherwise set forth in the CCPA.

WITH WHOM WE SHARE CCPA PERSONAL INFORMATION

In the past twelve (12) months PSI has not sold any CCPA Personal Information.  PSI does not sell any CCPA Personal Information. 

PSI may, however, share CCPA Personal Information with the following categories of third parties:

  • PSI’s affiliated companies and their respective staff.
  • PSI’s business partners, clients, suppliers, and service providers.
  • Other third parties as required by law, including lawful requests for disclosure by public authorities, law enforcement agencies, or judicial authorities.
  • Other third parties to whom you have authorized PSI to share CCPA Personal Information.

In the past twelve (12) months, PSI has shared the following categories of CCPA Personal Information:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, login credentials, social security number, driver’s license number or similar state-issued ID number and information, passport number and information, or other similar identifiers. 
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including signature, physical characteristics or description, address, telephone number, insurance policy number, education, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of protected classifications under California of federal law, such as age, race, national origin, marital status and history, medical condition, physical or mental disability, gender, information relating to pregnancy or childbirth, sexual orientation, or veteran or military status;
  • Internet or other electronic network activity information, including, but not limited to, browsing history, setting preferences, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. 
  • Professional or employment-related information, including but not limited to current employment and employment history, language skills, training history, resume or CV, job title and function, specialty, licenses, professional memberships, certifications, performance evaluations, awards, publications, professional opinions, advice, or consultations, and financial compensation information.

YOUR RIGHTS AND CHOICES REGARDING CCPA PERSONAL INFORMATION

The CCPA provides you with the following rights regarding CCPA Personal Information:

Access to Specific Information and Data Portability Rights

You have the right to request that PSI disclose certain information to you about our collection and use of your CCPA Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you.

  • The categories of CCPA Personal Information we collected about you.
  • The categories of sources for the CCPA Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that CCPA Personal Information.
  • The categories of third parties with whom we share that CCPA Personal Information.
  • The specific pieces of CCPA Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your CCPA Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the CCPA Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the CCPA Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that PSI delete any of your CCPA Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your CCPA Personal Information from our records, unless an exception under CCPA applies.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your CCPA Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CCPA Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your CCPA Personal Information if we cannot verify your identity or authority to make the request and confirm the CCPA Personal Information relates to you.  

Making a verifiable consumer request does not require you to create an account with us.  

We will only use your CCPA Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your CCPA Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and provide you with a cost estimate before completing your request.

Non-Discrimination

You have a right not to be discriminated against for exercising any of your CCPA rights, and PSI will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, PSI will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO THIS NOTICE

PSI reserves the right to modify this Notice as needed to reflect changes in laws, PSI practices and procedures, or requirements imposed by data protection authorities. Updates to this Notice will be posted on PSI’s website.  Please check back periodically for updates to this Notice.

Copies of this Notice may be printed from www.psi-cro.com.