About Us
ArcaScience (referred to as “Company,” “we,” or “our”) respects the relationships we have with our customers and the privacy of all individuals whose Personal Information may be processed by ArcaScience in the performance of our services and business operations. This Privacy Policy (“Policy”) explains how ArcaScience collects, holds, uses, and discloses Personal Information,including the Personal Information of our personnel, consumers, healthcare professionals, patients, medical research subjects, clinical investigators,customers, suppliers, vendors, business partners, and investors. ArcaScience intends that this corporate privacy policy and our implementing standard practices and procedures will support timely compliance with all international privacy laws and regulations worldwide.
Scope
This Policy applies to all Personal Information of Individuals, either in electronic or paper format, received by ArcaScience, including Personal Information of Company Personnel, job applicants, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business contacts and partners, government officials, and investors. ArcaScience endeavors to collect, use, and disclose Personal Information in a manner consistent with the laws of countries in which it does business, and also has a tradition of upholding the highest ethical standards in its business practices.
Definitions
For purposes of this Policy, the following definitions shall apply:
Agent: Any third party that uses Personal Information provided to it by ArcaScience to perform tasks on behalf of and/or under the instructions of ArcaScience or to which ArcaScience discloses Personal Information for use on its behalf.
European Economic Area (EEA): Includes the following thirty countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Ireland, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden (i.e., countries within the European Union) and Iceland, Liechtenstein, and Norway.
Individual: Any natural person.
Personal Information: Any information or set of information about an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) telephone number; (d) email address or online identifier associated with the individual; (e) Social Security number or other similar identifier; (f) employment or financial information; or (g) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person).
Company Personnel: Includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, retiree of ArcaScience and any and all of their respective dependents.
Sensitive Personal Information: Personal Information that reveals or is processed to uniquely identify a person, such as government-issued identification numbers, financial account numbers, background check reports, data elements revealing race, ethnicity, national origin, political opinions, religious or philosophical beliefs, trade union membership, citizenship status, sexual orientation, criminal offense information, workplace geolocation data of healthcare professionals, and information about individuals under the age of thirteen.
Notice of Data Collection and Use
Where ArcaScience collects Personal Information directly from Individuals, it will explain the purposes for which it collects and uses Personal Information about the Individuals, the types of third parties to which ArcaScience discloses that information, and the choices and means, if any, ArcaScience offers Individuals for limiting the use and disclosure of Personal Information about them. Notice will be provided in clear and conspicuous language. This explanation will be provided as soon as practicable and, in any event, before ArcaScience discloses the Personal Information or uses such information for a purpose materially different than that for which it was originally collected or processed. ArcaScience also will provide any additional information required by law for a specific context,product, or service. In general, with exceptions and other lawful bases that may be relevant for any specific product or service notice, ArcaScience processes personal data for its legitimate interests consistent with applicable law. Where an ArcaScience entity receives Personal Information from another ArcaScience entity or other entities, including when acting as an AI company processing Personal Information under the direction of a customer, it will use such information in accordance with the notices provided by such entities and the choices made by the Individuals to whom such Personal Information relates.
In circumstances in which ArcaScience obtains personal data as a service provider for its clients or affiliates, ArcaScience’s clients or affiliates are responsible for providing appropriate notice to the Individuals and, when applicable, obtaining any requisite consent (unless this function has been delegated to ArcaScience).
ArcaScience may collect various categories of Personal Information for the following purposes:
Research Studies-Related Information: For Individuals participating in research studies managed by ArcaScience as an AI company or in other situations where ArcaScience is participating in research studies, including patients, their spouses/partners, caregivers, and relatives, clinical investigators or other study personnel, and other consultants, contractors, managers, and agents (who are natural persons) of the study sponsor and its corporate affiliates, business partners, and third-party service providers, Personal Information may be used to carry out the applicable studies and other study-related services and/or pharmacovigilance. This may include the transfer of such Personal Information to the applicable study sponsor, its corporate affiliates, business partners, and third-party service providers performing services related to the study (e.g., study data management, clinical research monitoring services, safety monitoring, etc.).
Human Resources-Related Information: For Individuals who are Company Personnel, we will process Personal Information to carry out and support our human resources functions and activities, including, but not limited to, (i) evaluation of qualifications for an employment position; (ii) provision of employment benefits; (iii) administration and management of employees, compensation, stock options, grants and purchase plans, bonuses, retirement, training, and career planning; (iv) utilizing employee skills and ongoing employee resource allocation; (v) communicating with employees or their emergency contacts; (vi) administration of the company's business, including budgeting, manpower planning, and organizational design; (vii) authentication of the individual's identity when gaining access to computer system applications; (viii) Personal Information data changes; (ix) employment status changes; (x) travel and expense planning and reimbursement; (xi) evaluation of employee performance and time management; and (xii) management of Personnel performance, and implementation, investigation and reporting on compliance and discipline procedures and matters. ArcaScience may provide Personal Information to Agents to support ArcaScience in performance of these human resources-related activities. Further, information concerning how ArcaScience collects, uses, shares, and safeguards the Personal Information of Company Personnel is available to ArcaScience Company Personnel in ArcaScience’s internal privacy policy. In addition, for job applicants, Personal Information will be used for the evaluation of the suitability of the applicant for a position. ArcaScience may, at its discretion and with the consent of the candidate where required by law or otherwise obtained, perform such background checks as deemed appropriate to evaluate this suitability.
Business Contacts: For Individuals who are business contacts of ArcaScience, ArcaScience may collect Personal Information concerning contact information for such business contacts. This information may be used for purposes consistent with the provision of information by these contacts, which may include marketing activities focused on sales of new products and services, requests to participate in market research that enhances ArcaScience’s product offerings, and other business activities.
Healthcare Professionals: ArcaScience collects information about healthcare professionals directly from the healthcare professionals, from public sources, and from business partners. We use this information in connection with various healthcare activities, including clinical trials, real-world studies of patient treatment, healthcare outcomes analysis, market research activities, and other situations where primary intelligence from healthcare professionals is applicable.
Customers and Program Participant Information: For Individuals sharing Personal Information with ArcaScience to inquire about or otherwise make use of our services or purchase, receive, or seek information, including about any healthcare products and services, opportunities to participate in clinical research, healthcare education, and patient support programs which may be available through ArcaScience, we will use such Personal Information to provide the requested information, products, and/or services. Such uses may include, but are not limited to, processing requested transactions, improving the quality of our services, sending communications about the products and services available through ArcaScience, and enabling our business partners and Agents to perform certain activities on our behalf.
Data Analytics Functions: In certain situations, ArcaScience obtains and processes information about Individuals for various data analytics purposes. In most situations, this data has been anonymized or de-identified and is no longer Personal Information when it is obtained by ArcaScience or whenever transferred. In some situations, ArcaScience receives Personal Information from a customer or other data supplier for the purpose of such anonymization or de-identification. In other situations, the data that is obtained and processed by ArcaScience is pseudonymous. This pseudonymous information may be used for research purposes, primarily in connection with academic partners and with academia, and may be transferred by ArcaScience to the United States as part of these research-related activities. For all of these situations, ArcaScience’s activities are consistent with the notice and choice provided by these customers or data suppliers to Individuals, and ArcaScience’s use of this information is consistent with ArcaScience’s obligation to provide services to these entities. In those situations, and where such information is transferred to the United States, ArcaScience uses such information only in manners consistent with appropriate data transfer mechanisms and the manner in which this data was obtained.
Other Disclosures of Personal InformationIn certain circumstances, ArcaScience may disclose Personal Information:
Legal Obligations: If required by law, court order, or legal process.
Public Authorities: In response to lawful requests by public authorities, including national security or law enforcement requirements.
Litigation: Under the discovery process in litigation.
Policy Enforcement: To enforce ArcaScience policies or contracts.
Debt Collection: To collect amounts owed to ArcaScience.
Preventing Harm: When disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation or prosecution of suspected or actual illegal activity.
Other Necessary Disclosures: In good faith belief that disclosure is otherwise necessary or advisable.
ArcaScience may also transfer Personal Information during significant business events, such as purchase, disposal, merger, joint venture, or acquisition. In such events, ArcaScience will aim to direct the transferee to use Personal Information in a manner consistent with this Policy. ArcaScience will provide Individuals with reasonable mechanisms to exercise their choices as required by applicable law.
Accountability for Onward Transfer
In the performance of our services and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our worldwide organization and to our service providers or agents, including for hosting our databases or provision of data processing services, in accordance with applicable data privacy laws. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice.
ArcaScience may also share an Individual's Personal Information with Agents, including affiliates, in connection with services or business purposes that these individuals or entities perform for, or with, ArcaScience. For example, ArcaScience may provide an Individual's Personal Information to Agents for hosting our databases, for data processing services, or to send to that Individual the information that he or she requested.
ArcaScience may transfer Personal Information for specified, limited purposes to an Agent and will endeavor to obtain assurances that such Agent provides at least the same level of privacy protection as is required by appropriate data transfer mechanisms and this Policy. ArcaScience will notify if it makes a determination that it can no longer meet this obligation.
Where ArcaScience knows that any third party to whom it has provided Personal Information is using or disclosing Personal Information in a manner contrary to this Policy, ArcaScience will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to Agents, and to the extent ArcaScience is responsible for the event, ArcaScience shall remain liable should its Agents process Personal Information in a manner inconsistent with the appropriate data transfer mechanisms and this Policy.
In circumstances in which ArcaScience obtains Personal Information as a service provider for its clients or affiliates, ArcaScience’s clients or affiliates are responsible for protecting individual rights with respect to onward transfers.
Security
ArcaScience will endeavor to take reasonable and appropriate technical, administrative, and physical safeguards designed to protect Personal Information in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information ArcaScience is processing, regardless of whether such Personal Information is in electronic or tangible, hard copy form. We have a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, and concerns, including any potential privacy or security incidents.
Data Retention
The information we collect may be archived or stored periodically by us according to backup processes and will only be retained for as long as required for the purposes for which it was collected, as well as to provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Data Integrity and Purpose Limitation
ArcaScience endeavors to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. ArcaScience will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by ArcaScience for as long as ArcaScience retains possession of such information. ArcaScience’s Personnel have a responsibility to assist ArcaScience in maintaining accurate, complete, and current Personal Information. When acting as an AI company or in other situations where ArcaScience acts on behalf of another entity, ArcaScience endeavors only to process Personal Information that is relevant to the services it provides, and only for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified. Where ArcaScience processes Personal Information as an AI company or otherwise acts under the direction of its customers, ArcaScience works with such customers so that the customers can provide a way for Individuals to correct or update their Personal Information to the extent required by law.
Your Privacy Choices
Depending on your jurisdiction, you may also have certain legal rights in relation to the processing of your Personal Information. These rights may include:
- The right to access your personal information (including a data portability request);
- The right to correct or amend any personal information we have on file about you;
- The right to delete your personal information;
- The right to limit the use of your “sensitive” personal information;
- The right to opt-out of the sale or “sharing” of your personal information;
- The right to opt-out of the use of your personal information for targeted advertising purposes;
- The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
- The right to restrict the use of your personal information for certain automated decision-making (including profiling); and
- The right to revoke your consent (to the extent applicable).
To exercise any of these rights, please fill out this webform or contact us by email at privacyofficer@arcascience.ai with your name, physical address, email address, the email address associated with your interactions with ArcaScience (if different), telephone number, and details about your interactions with ArcaScience (including whether you are a patient or a healthcare professional). You may also designate an authorized agent to submit a request on your behalf. To designate an agent, please also send us a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. Please note that we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we are receiving a request. We will respond to any request you submit in the time period required by applicable law and will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to privacyofficer@arcascience.ai.
Although ArcaScience makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which ArcaScience is unable to provide access, including, but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If ArcaScience determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.
Depending on your jurisdiction, you may also have the right to lodge a complaint with your supervisory authority or challenge our decision with regard to any of your data protection rights. For example, for a list of EU supervisory authorities, please see this directory for contact details: EU Supervisory Authorities.
If you are a California user, you may also have additional rights available to you under the California Consumer Privacy Act. Please review our California Consumer Privacy Act Notice for additional details. If we process your “consumer health data” under Washington’s My Health My Data Act or a similar health privacy law in another jurisdiction, please review our Consumer Health Data Policy.
If you are an EU, Swiss, or UK resident, please review our EU-US DPF Policy that may provide you with additional information regarding your rights in relation to international data transfers.
Recourse, Enforcement, and Liability
ArcaScience encourages Individuals covered by this Policy to raise questions about the processing of Personal Information about them by contacting ArcaScience through the contact information provided below. Any Personnel that ArcaScience determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment, where applicable, in accordance with ArcaScience’s disciplinary procedures.
Any questions or concerns regarding the use or disclosure of Personal Information should also be directed to ArcaScience through the contact information given below. ArcaScience will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Policy.
In circumstances in which ArcaScience obtained or maintains Personal Information as an AI company or other Service Provider, Individuals may submit complaints concerning the processing of their Personal Information to the relevant client, in accordance with the client’s dispute resolution process. ArcaScience will participate in this process at the request of the client or the Individual. ArcaScience will take steps to remedy any issues arising out of any potential failure to comply with this Policy and, where applicable, implement appropriate data transfer mechanisms.
Contact Information
Questions, comments, concerns, or complaints regarding this Policy or ArcaScience’s processing of Personal Information should be submitted to the ArcaScience Chief Privacy Officer at privacyofficer@arcascience.ai.
Reservation of Rights
ArcaScience reserves the right to share an Individual’s Personal Information and contracts with Agents as required or authorized by law or regulation or in response to duly authorized information requests of ArcaScience Privacy Policy
Changes to the Privacy Policy
This Policy may be reviewed and amended from time to time, without advance notice, to ensure that an appropriate level of protection for Personal Information is maintained. All amendments will be posted on this website. Please check back periodically for updates to this Policy.
ARCASCIENCE PRIVACY POLICY EFFECTIVE DATE: March 31, 2024
