1. Data Controller
The personal data you provide through this website will be processed by ClinicalTrialsTeam S.L. (hereinafter CTT), with address at Ctra. Canillas 134, 28043 Madrid (Spain), VAT number B-87588893, listed in the Commercial Registry of Madrid, volume 33933 folio 203 section 8 sheet M610682 on June 16, 2016. Email: dataprotection@trialsteam.eu
2. Rationale
CTT respects the privacy rights of all our website’s users whose personal information may be processed by CTT and acknowledges the importance of protecting the information processed.
The purpose of this policy is to inform our Users of the processing of personal data made through this website.
3. Personal data processed when by using our Service
3.1. What kind of data do we collect and process?
CTT collects web users´ data generally through:
IP Address. IP address is a code to identify User´s Internet connexion at a specific time. The User´s Internet provider is the only one able to identify the User to whom an IP was assigned at a specific time.
Due to the intrinsic features of the Server which support our website, the IP user´s address, date and access time are automatically registered in the system.
Notwithstanding, it is not possible to find out the User´s identity without the use of additional information provided by the User throughout different sources and able to be link to the IP address.
Additionally, in this website you may find some personal data collection forms. Each of these forms includes specific information on the processing of personal data provided on them.
3.2 Purpose of the processing
The personal data we collect are used to manage the normal use of the website and to carry out statistical analysis of the web use.
3.3 Recipient of the Information
Unless a legal, judicial or regulatory obligation exists, such as for example a subpoena as consequence of a police investigation or, in case of CTT´s vendors or services providers in charge of the maintenance and managed of the website, CTT does not disclose information to any third party.
3.4 Legal processing
The IP address processing is technically necessary to allow the web connexion through the Internet; thus, the processing is lawful.
3.5 Storage period
The IP address are stored for 1 month
3.6 User rights and how to exercise them
According to data protection regulation you are entitled to the following rights
• Access: Allows the User to know what information is hold, where it has been collected, to whom has been disclose and purposes of processing
• Rectification: Allows the Users to rectify incomplete, outdated or mistaken data.
• Erasure: Allows the User to obtain the erasure of personal data concerning to him/her.
• Objection: Allows the User to stop the processing of his/her data for a specific purpose.
• Restriction: Allows the User marking stored personal data with the aim of limiting their processing in the future.
• Portability: Allows the User, to receive an electronic copy of personal data concerning to him or her and, in specific circumstances, to request the transmission of those data to another controller. The transmission is only applicable when the processing is consent by the User and is carried out by automated means or is necessary for the performance of a contract.
• Consent withdraw: Allows the User to withdraw the consent granted for processing her/his data.
However, to be able to exercise such rights, it has to be feasible to link the data processed by CTT to the identity of the User who made the request.
As a matter of fact, unless the User provides additional documents which allow to identify him/her, such as for instance a certification granted for its Internet provider stating what IP address had the User assigned at a specific day and time, it is actually not feasible to make such link by CTT using only the personal data we processed.
Users may contact the Spanish Data Protection Agency (www.aepd.es) and also contact us by email to dataprotection@trialsteam.eu if they wish more information or if they think theirs rights might have been affected.
Other processing of personal data
4.1 Forms
CTT may also collect personal data through the web forms. Particularly, CTT collect data through the following forms:
4.2 Contact forms
The purpose of the processing of personal data collected by CTT in this form is to answer your queries.
a) Storage period: data are storage for five (5) years as of its consultation in order to be able of attending CTT´s potential legal responsibilities. After that period, data will be erased.
b) Legal ground: subject´s consent
As it is stated in the section “User rights and how to exercise them” of this Privacy Policy, you may withdraw your consent at any time.
4.3 Job application form
The purpose of the processing of personal data collected by CTT in this form is to manage job applications in CTT´s selection process.
a) Storage period: data are storage for 1 year. If the applicant does not want his/her data being kept for one year, rights of erasure and consent withdrawal may be exercised.
b) Legal Ground: subject´s consent.
Mandatory data will be identified as such at time of being requested. Refusal to provide those data may impair the selection process and cause the rejection of the candidate´s application.
As it is stated in the section “User rights and how to exercise them” of this Privacy Policy, you may withdraw your consent at any time, however, this decision will prevent CTT of carrying out the processing and thus, it involves the exclusion of the selection processes.
Third Party data provided by the User
In case third party personal data are provided by the User for any purpose, the User guarantees to have previously informed the affected party and to have obtained its previous consent to communicate those data to CTT.
The User guarantees that the affected parties are older than 14 years-old and the information is accurate and truthful.
The User shall respond of any responsibility that may arise from the non-fulfilment of those conditions
6. Security measures
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, either cause by human action or not, has implemented technical and organisational measures to ensure appropriate personal data security and to avoid its lost, alteration, unlawful or unauthorised processing.
Nonetheless, the User must be aware of security measures on the Internet are not infallible.
Should you have any question on CTT´s Privacy Policy you may contact us in dataprotection@trialsteam.eu