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Survey Privacy Policy

ORIGINAL TEMPLATE LANGUAGES

Survey Privacy Policy

Overview and Terms of Use

HealthiVibe, LLC (“Company”, HealthiVibe) is the designer, owner and administrator of this survey. This Survey Privacy Policy describes the way in which the Company collects, uses, maintains and discloses information collected from participants in the survey. We take personal privacy very seriously and are committed to protecting your privacy.

Types of Information We Collect

Personal Data

In the course of taking our survey, we may collect personal information which includes medical or diagnostic data, such as conditions and comorbidities.  This information is collected to help our clients gain a better understanding of the patient population and the patient experience.

In addition, with your explicit consent, we may ask for and collect personally identifiable information (PII) such as name, phone number, address and email.  We strictly utilize this information for the purpose explicitly stated in the survey, which may include one or more of the following:
  • Conducting follow-up interviews on behalf of our clients
  • Providing information about the study after completion
  • Reaching out to you with additional clinical trial participation opportunities in areas of therapeutic interest
In all cases, personally identifiable data is stored separately from medical or diagnostic data shared with clients.  Medical data records are linked to personal data through the use of a non-identifiable patient code.  Access to personal data is strictly controlled and restricted to authorized HealthiVibe project staff.

Non-Personal Data

HealthiVibe may also collect non-personal information about the device utilized to access the survey.  This may include information about your browser and operating system versions, device manufacturer, referral address, and access time, but will not include your device’s IP address.  We use this information to monitor and improve the quality of our surveys and to provide general statistics regarding use of our services. 

The above information is maintained in our system logs for analytical purposes to improve our web pages or track for quantitative research data analytics. The logs may be kept indefinitely and used at any time and in any way necessary to prevent a security breach and to ensure the integrity of the data on our servers.

Cookies

Our surveys may use "cookies".  Cookies are small text files stored directly on your device. These are used for purposes of maintaining certain aspects of session state between online survey visits, and are not used to track user activity or for any other purpose.

Data Security

HealthiVibe has in place security to protect any collected personally identifiable information, to prevent access to and misuse of that information or its loss or alteration.

Personally identifiable details of any collected data records are stored in encrypted form in a secure environment.  Access to these records is restricted to authorized HealthiVibe project personnel only.

We implement strong security measures to protect personal or sensitive data collected.  Although unlikely, if we experience a data breach or incident, we will take immediate action to stop the breach, mitigate any harm, communicate with all stakeholders impacted, and work closely with our partners to ensure any notifications follow applicable laws.

Sharing your Personal Information with Third Parties

We may disclose personal information that HealthiVibe has collected or that was provided by you to:
  • Contractors and other third parties i.e. recruitment or technology)  utilized to support business (companies bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose the information).
  • Comply with any court ordered, law or legal process, including to respond to any government or regulatory request.
  • Protect and defend the rights of property of HealthiVibe (including the enforcement of our agreements).
  • Act in urgent circumstances to protect the personal safety of users or the public.
  • And for any other purposed disclosed by us when you provide the information and your consent.
HealthiVibe is liable for inappropriate transfers of personal data to third parties.  HealthiVibe complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.  For more information, please review  https://www.privacyshield.gov/article?id=3-ACCOUNTABILITY-FOR-ONWARD-TRANSFER
 
In certain situations, HealthiVibe may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  Additionally, HealthiVibe is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Retention and Disposal

De-identified data collected as part of this survey, including responses to demographic questions, will be retained for analytic purposes and to provide insight on patient perspectives to the client.

Personal data collected on behalf of a client, for the purpose of receiving study information or to participate in follow-up interviews, will be retained until the conclusion of the project or until the requested information is available and has been provided, whichever is later. 

Personal data collected for the purpose of requesting additional clinical trial opportunities or other information outside the current study will be retained until such time as you request for its removal.

You may contact HealthiVibe at any time to request removal of any and all personal data.

Disclosures of Personal Information

Personal information may be shared within HealthiVibe, and with third parties only when such information sharing is specifically outlined in our project plan developed with the client.

HealthiVibe does not sell, trade or rent personally identifiable information to any third parties. 

On an exceptional basis, we may disclose personal information for the following reasons:
  • When there is reasonable belief disclosure is required by law, including information requested by means of subpoena and court order.
  • Report of what appears to be illegal or fraudulent conduct to law enforcement authorities.
  • If the company at any point transfers assets or operations in connection with a sale, merger, bankruptcy, or other transaction, we may transfer personally identifiable information to the acquiring or merging entity. If so, we will make all reasonable efforts to require that personally identifiable information remains subject to essentially the same protections as contained in this Privacy Policy. 

Your Personal Informational Rights

Participants have the right to access, modify or delete any personally identifiable information stored by HealthiVibe, and to withdraw consent for its use.  Subject to applicable law, you also have the right to (i) restrict HealthiVibe’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority.

Requests may be made either by mail, phone or email, using the following contact information.

In compliance with the Privacy Shield Principles, HealthiVibe commits to resolve complaints about our collection or use of your personal information.  European Union (EU) individuals with inquiries or complaints regarding our Privacy Shield policy should first contact HealthiVibe at: 

Mail:
Chief Information Officer
HealthiVibe, LLC
4201 Wilson Boulevard,
#110-321, Arlington, VA 22203

Phone:
866.961.6400

Email:
privacy@healthivibe.com

International Regulatory Compliance

HealthiVibe complies with all recommendations and guidelines of the General Data Protection Regulation (GDPR).  As an additional safeguard and in response to the invalidation of the International Safe Harbor framework, HealthiVibe stores all personally identifiable information on EU-based servers in Frankfurt, Germany.  The project team has strictly controlled and compartmentalized access to the data, as does the server administration team.  Prior to project execution, HealthiVibe also abides by each country data regulations and implements projects accordingly.

Privacy Shield

HealthiVibe has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

HealthiVibe complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) to the United States.  HealthiVibe has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact HealthiVibe.

If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to the lead supervisory authority in your country of residence.  A link provided below for your convenience:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Where a complaint cannot be resolved by any before mentioned recourse mechanism, individuals may have a right to invoke binding arbitration under the Privacy Shield Panel as a recourse mechanism.

To review our certification on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: 

https://www.privacyshield.gov/list

Updates to this Policy

This Survey Privacy Policy is effective as of 13DEC2018 and may be updated from time to time in light of changing business and legal requirements. We encourage you to review the Survey Privacy Policy prior to responding to any survey.
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