THE HRP CONSULTING GROUP
LAST UPDATED: AUGUST 23, 2018
If you subscribe to our CITI Program or ProtocolBuilderTM services, separate privacy terms apply. Please see https://about.citiprogram.org/en/privacy-policy and http://www.protocolbuilderpro.com/privacy-policy for additional information.
We encourage you to read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.
1. Non-Personal Information
Do you need to submit personal data to use our Sites?
We hope you will use our Sites to learn about services offered by HRP. You can use our Sites without submitting personal information such as your name, postal address, email address(es), and telephone number(s). Please see Collecting Your Personal Data, below, for circumstances where you will be required to provide personal data
Information Automatically Collected.
We automatically log non-personal information about you and your computer or mobile device when you access our Site. For example, when visiting our Sites, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the sections on Cookies and Pixel Tags below.
How do we use the information we automatically collect?
We use gathered information to track user trends and Site usage with the goal of improving our visitor’s experience and upgrading our Sites. The information that we collect in this manner is not linked to anything that identifies you as an individual.
2. Collecting Your Personal Data
What is personal data?
Personal data includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address(es), and telephone number(s). We will require you to submit personal data for specific and limited purposes on our Sites.
If you use our Report Concerns form you will be asked to provide your name and may also provide contact information (e.g. phone number, email address, postal address) so that we may contact you for more information regarding your reported concern.
If you complete our Contact Us form, we will automatically collect your email address and you will be asked to submit personal data including your name, place of work, job title and phone number. We will use this information to respond to any request you have submitted through the Contact Us form.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers on our Sites, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our Sites use the following types of cookies for the purposes set out below:
- Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Sites and how users use Services. The information gathered does not identify any individual visitor, though it includes IP addresses that can be used to do so. It includes the number of visitors to each Site, the websites that referred them to that Site, the pages visited and for how long, the time of day of that session, whether this is a new or repeat visit, and other similar information. We use this information to help operate our Sites more efficiently, to gather broad demographic information, and to monitor the level of utilization of our Services.
- Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button related to our Services, or you link your account or engage with our content on or through a social networking website such as Facebook, Google+, LinkedIn or Twitter. The social media site will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facilities). Many browsers are set to accept cookies until you change your settings. If you wish to find out more about cookies, please visit the Interactive Advertising Bureau’s web site at www.allaboutcookies.org.
If you would like to prevent us from collecting cookies when you visit our site, please update the privacy setting in your chosen web browser. You can directly control cookie acceptance from there:
Google Chrome: https://www.google.com/chrome/browser/privacy/
Mozilla Firefox: www.mozilla.org/en-US/privacy
Internet Explorer: windows.microsoft.com/en-gb/windows/change-internet-explorer-privacy-settings#1TC=windows-7
Google Analytics: https://tools.google.com/dlpage/gaoptout
4. Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites to track the actions of users of our Sites. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Sites, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
We currently do not use other companies to serve third-party advertisements when you visit and use our Sites.
6. Using your personal data
We may use your personal data as follows:
- to operate, maintain, and improve our Sites;
- to respond to your comments and questions and to provide customer service;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by any of the divisions of BRANY;
- to link or combine user information with other personal data;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
7. Sharing your personal data
We may share your personal data as follows:
- Your Affiliated Research Institution. In the event you complete our Principal Investigator Registration form, we may share your personal data with the institution at which you conduct your research, as designated in your completed Principal Investigator Registration form.
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
8. Anonymous Data
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Sites.
9. Third Party Sites
Our Sites may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
10. User Generated Content
If you provide feedback to us, we may use and disclose such feedback on our Sites, provided we do not associate such feedback with your personal data or other identifying information. If you have provided your consent to do so, we may, with your approval, post your first and last name along with your feedback on our Sites.
We seek to use reasonable organizational, technical, and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at email@example.com or by using the details in Section 18 below.
12. Our Policy on Children
Our Sites do not knowingly collect information from minors under 18 years of age without parental consent or parental notification. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 18 below. We will delete such information from our files as soon as reasonably practicable.
13. Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our Sites or otherwise to us. We do not actively collect sensitive personal data.
If you send or disclose any sensitive personal data to us when you submit user generated content to our Sites, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Sites.
14. Your Right to Opt-Out
You may contact us anytime to opt-out of or unsubscribe from: (i) direct marketing communications; or (ii) newsletter subscriptions. Our marketing and newsletter emails will tell you how to “opt-out” or “unsubscribe”. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about our business dealings with you.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at firstname.lastname@example.org or using the contact information in section 18 below. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention
We will post any modifications or changes to the Policy on our Sites. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” date above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our Sites prior to such changes(s) taking effect.
17. Contact Information
We welcome your comments or questions about this Policy. You may contact us in writing at:
Privacy concerns: email@example.com
Security concerns: firstname.lastname@example.org
Biomedical Research Alliance of New York LLC
1981 Marcus Avenue, Suite 210
Lake Success, NY 11042
Attention: Privacy Manager