Privacy Notice – Prospective Clinical Trial Participants in the European Economic Area and Switzerland
The PatientWing community engagement and study enrolment pre-screening website at www.patientwing.com (the "Website") provides initial information about clinical trials that we are sponsoring and for which we are looking for participants, and allows you to register as a potential participant in these clinical trials. Comprehensive information about the clinical trials will be provided to you by healthcare professionals if you are eligible to participate in the clinical trials. This Privacy Notice sets out how we use and protect any personal information we collect through this Website.
When we say “we”, “us”, or “our” in this Privacy Notice, we are referring to Arena Pharmaceuticals, Inc., a Delaware corporation whose principal place of business is at 6154 Nancy Ridge Drive, San Diego, California, 92121 (“Arena”) (see https://www.arenapharm.com/).
The Website is hosted by VitalTrax, LLC, a Pennsylvania corporation limited liability company (PatientWing), a patient recruitment company doing business as PatientWing (PatientWing). Clinical trial sponsors such as Arena typically do not access patient recruitment data directly. PatientWing is our processor for the purpose of providing and administering the Website platform and the associated collection and processing of your Personal Data on our behalf. However, as the controller, Arena remains responsible for compliance with this Notice.
If you have any questions about our collection of your Personal Data (as defined below), please contact us at email@example.com.
Any data collected through the Website, including Personal Data, is only used to determine your eligibility for participation in clinical trials we run and to maintain the Website. Once collected, Personal Data will not be used for a different incompatible purpose without your knowledge and, where required by law, consent. Arena is regarded as the Controller of the Personal Data collected through the Website – in other words, we are responsible for deciding how your Personal Data is collected and used.
We take the protection of data privacy very seriously. All Personal Data collected through the Website will only be used and disclosed as set out in this Privacy Notice. Applicable data protection laws shall be respected in full.
Access to and use of the Website are not intended for use by anyone younger than the age of 18 and we do not knowingly collect Personal Data from individuals younger than the age of 18.
Please read this Privacy Notice thoroughly. If you disagree with the way Personal Data will be used, please do not use this Website or provide your Personal Data through the Website.
1. Purpose of data collection
The main purpose for the collection of Personal Data through the Website is to determine if you are eligible to participate in an advertised clinical trial and, if so, to share your Personal Data with healthcare professionals (investigators and members of the study team) involved in conducting that clinical trial. We will assess the Personal Data you provide to determine whether you are eligible for the clinical trial in which you express interest.
With your explicit consent, as an additional purpose, we will also use your Personal Data to determine whether you are eligible for any other or future clinical trials we conduct in which you have not specifically expressed interest. If you explicitly consent, we may contact you about other or future Arena clinical trials in order to provide you with relevant information about such trials. You may unsubscribe from receiving this information about other or future Arena clinical trials at any time by contacting firstname.lastname@example.org.
We may use automated analysis tools to determine whether you are eligible to participate in our clinical trials, which will look at the eligibility requirements of the particular clinical trial and the information you have provided. This may result in you being declared ineligible for a trial in which you expressed interest or eligible for a trial in which you did not specifically express interest. We may use the Personal Data that you provide to contact you to ask if you would like to see if you are eligible for a different Arena trial.
2. What Personal Data do we collect and process?
Personal Data means any information relating to an identified or identifiable natural person (i.e. living individual). For purposes of this Privacy Notice, Personal Data is limited to information about you that is collected through the Website.
We collect the following Personal Data through the Website:
Your Personal Contact Details
We collect certain personal details such as your name, location, email address and telephone number.
Your Health Information
We collect details about your health and any conditions you may have, as well as details of clinical trials you have participated in in the past. We also collect your date of birth so we can determine if you are in the age range eligible for participation in particular clinical trials.
We additionally collect limited Personal Data connected with your use of the Website, e.g., IP address, browser type, Operating System, websites you visit before and after the Website and data on how you use the Website.
3. What lawful bases do we rely on?
We will rely on your explicit consent to use the Personal Data (including your health information), that you submit through the Website to determine your eligibility to participate in the clinical trial for which Arena Pharmaceuticals, Inc. currently is recruiting (including through automated decision making).
We will also rely on your explicit consent to retain your Personal Data in our database for the purpose of matching it with our other or future Arena clinical trials for which you may be eligible.
We will rely on your explicit consent to disclose your Personal Data (including your health information) to third-party healthcare professionals who are conducting our clinical trials and with a clinical research organisation (CRO) that supports us in conducting our clinical trials.
We will rely on your explicit consent before we or any third parties contact you about our future Arena clinical trials that may be of interest to you which are different from the trial(s) for which you registered.
We will rely on your explicit consent to disclose your Personal Data (including your health information) to a third party that purchases, or to which we transfer, all or substantially all of our assets and business.
We will rely on our legitimate interest in ensuring the security of the IT environment which hosts and maintains the Website to use certain Personal Data you provide (such as your browser type or IP address) which is not health information.
Please note that where you have given your consent to any use of your Personal Data, you can withdraw or revoke this consent at any time. To withdraw or revoke your consent, please contact email@example.com. Our use of your Personal Data prior to receipt of such withdrawal or revocation will remain lawful.
The Personal Data set out in Section 2 above is required in order for us to determine, via the Website, whether you are eligible to participate in our clinical trials. However, choosing not to register, or withdrawing or revoking your consent after registration, will not result in any detriment to you. You always have a choice concerning whether or not you provide Personal Data as part of the registration process and you are under no obligation to register. In addition, there are other ways to determine whether you are eligible to participate in our clinical trials. Please visit www.patientwing.com for more information.
4. With whom do we share Personal Data?
Where you are considered to be eligible for one of our trials, we may share your Personal Data with the relevant third-party healthcare professionals (investigator or members of the investigations team) who are carrying out that clinical trial on our behalf. We may also share your Personal Data with a clinical research organisation (CRO) that supports us in conducting the trial.
In such cases, when we share your Personal Data with these healthcare professionals and CRO, they will provide you with the information leaflet together with an informed consent form which sets out the required information about the clinical trial and a separate privacy notice which sets out how they will use your Personal Data.
We may also share your Personal Data to the fullest extent permitted by law with:
We will not disclose your Personal Data to anyone else except where we have separately informed you, and where necessary obtained your consent, or as otherwise stated in this Privacy Notice.
5. Who is processing the Personal Data?
As mentioned at the beginning of this Notice, the services and information provided though this Website are provided on Arena’s behalf by PatientWing, a clinical study recruitment company. PatientWing is our processor for the purpose of supplying and administering the Websites platform and the associated collection and processing of your Personal Data. PatientWing may in turn engage sub-processors, for example to provide hosting of the Websites and data storage. Any processing of the Personal Data by these parties is ultimately in accordance with our instructions.
We may also engage call centre service providers to help us contact you about the running of the clinical trial.
Where the services of third parties for the technical maintenance, administration or processing of data are required, the Personal Data will be accessed by these parties only to the extent that is required to ensure a smooth and secure technical handling of the Website and in compliance with applicable law, including with respect to data confidentiality, privacy and security. You can obtain a list of processors by contacting PatientWing at firstname.lastname@example.org.
6. Your rights relating to your Personal Data
Please contact email@example.com if you want to see any Personal Data stored about you in our records. We will honor your legal right to view your Personal Data in accordance with applicable privacy law. If you think that any of the Personal Data collected through the Website is incorrect, confusing or incomplete, please contact firstname.lastname@example.org. You may also ask us to erase, restrict or port your Personal Data and you may tell us if you object to our use of your Personal Data.
In certain countries you may also have the right to indicate to us how you wish your Personal Data to be used after your death. Please contact email@example.com for further details.
Because we do not have direct access to your Personal Data, we will instruct PatientWing to assist you.
7. Retention of Personal Data
Personal Data will be stored by us in accordance with our applicable data retention requirements and corporate policies. When determining how long to retain your Personal Data, we take into account our legal obligations and regulators' expectations. We will usually fully anonymise or securely erase your Personal Data when we no longer need to use it for the purposes described in this Privacy Notice (usually 2 years after the last clinical trial you have participated in has finished) or if you withdraw your consent or object to our use of your Personal Data.
8. Data Security
We use a variety of methods, such as firewalls, encryption technologies, intrusion detection software and manual security procedures that reflect industry standards, to secure your data against loss or damage and to help protect the accuracy and security of Personal Data and to prevent unauthorised access or improper use. In particular, whenever you are sending Personal Data to us through the Website, your Personal Data (including your health information) is protected by Secure Sockets Layer (SSL) technology. We also restrict the access of our employees or processors to your Personal Data on a need to know basis, with different levels of access authorisations and we keep a record of access logs.
However, please note that no Internet or Wi-Fi transmission can ever by 100% guaranteed as secure and so we encourage you to take care when disclosing Personal Data online and to use readily available tools, such as Internet firewalls, anti-virus and anti-spyware software and similar technologies to protect yourself online.
If you think that the Website or any Personal Data is not secure or that there has been unauthorised access to either the Website or your Personal Data, please contact firstname.lastname@example.org immediately.
Please note that we treat Personal Data as strictly confidential, and will only disclose it as explained in this Privacy Notice.
10. Data Transfers
We or the clinical trial health professionals with whom we share your Personal Data may transfer your Personal Data to countries outside the EU and the UK, namely the USA. The European Commission has not issued a decision that the data protection laws of the USA provide an adequate level of protection for personal information. However we ensure all data transfers comply with applicable legal requirements (for example under intercompany agreements with appropriate contractual). Should you wish to know more about how data is protected or wish to request a copy of the contractual protections please contact email@example.com.
Some web browsers may be configured to send 'Do Not Track' signals to the websites that you visit. There is no consensus among industry participants as to what 'Do Not Track' means in this context. Like many websites, the Website does not alter practices when a 'Do Not Track' signal is received from a visitor's browser. To find out more about 'Do Not Track', please visit www.allaboutdnt.com.
12. Notification of Changes
Should we wish to change this Privacy Notice, if you have already provided Personal Data through this Website, we will contact you to inform you of the new Privacy Notice and, in some circumstances, we may need to obtain your consent to the changes. In other circumstances, any such changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes. If material changes are made to this Privacy Notice, we will notify you by placing a prominent notice on the Website and bringing these changes to your attention by email where reasonably possible for us to do so. We reserve the right to update and amend this Privacy Notice without prior notice to reflect legal and regulatory changes. Continued use of the Website after a change in the Privacy Notice indicates your acknowledgement of the use of Personal Data in accordance with the amended Privacy Notice.
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13. Further Information
For further information on Arena please visit our website – https://www.arenapharm.com/.
If you consider that we are not complying with this Privacy Notice or if you have any questions in relation to this Privacy Notice, please contact firstname.lastname@example.org. You may also lodge a formal complaint with your competent data protection authority.
© Copyright 2020 Arena Pharmaceuticals, Inc. Arena Pharmaceuticals® and Arena® are registered service marks of Arena Pharmaceuticals, Inc. All Rights Reserved.
Effective on October 15, 2020
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