Professional Case Management Clinical Trials, LLC Privacy Statement 

Table of Contents

1. Who is PCM Trials?

Professional Case Management Clinical Trials, LLC (“PCM Trials”) is part of a group of companies headquartered in Denver, Colorado dedicated to providing mobile research services to clients. When you provide your personal information directly to PCM Trials, PCM Trials will be the controller or co-controller with its affiliates. PCM Trials will act as a processor or service provider when we act or provide services on behalf of an authorized third party.

If you have questions about how we use your personal information or any requests relating to your information, please email PCM’s Data Protection Officer at [email protected]. If you prefer to write or call, additional contact information can be found here, in the “Contact Us” section of this statement.

2. Scope of This Privacy Statement

PCM Trials and its group companies have established a comprehensive privacy program designed to help us respect and protect your privacy rights. When we use your personal information, we use it in a reasonable and responsible way, minimizing the type of information we collect and hold about you, the period of time we store it, and the ways we use it. This Privacy Statement concerns PCM Trials operations including: outreach, client onboarding and care, project management, administration, and the use of our websites and mobile applications.

Our purpose in this statement is to provide our current, former and potential clients with an understanding of:

  • How and why we collect your personal information;
  • The types of personal information we collect;
  • Who we share your personal information with;
  • How we use, process, share, store, and protect your personal information; and
  • Provide contact details so you can request information about the processing of your personal information and your rights to do so.

3. A Few Quick Terms for Reference

  • Controller: is the entity or person who decides what Personal Data to collect and how it is to be used.
  • Data Protection Officer (“DPO”): is the person you will reach out to at PCM to ask questions about your data.
  • E.E.A.: the European Economic Area. This includes all of the countries in the EU (see below) as well as Iceland, Liechtenstein, and Norway.
  • E.E.O.I.C.P.A.: is the Energy Employees Occupational Illness Compensation Program.
  • E.U.: This includes the European Union. This includes the countries of Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.
  • PCM: Professional Case Management, LLC
  • PCM Trials: PCM Trials is a sister company to Professional Case Management, LLC. This Privacy Statement applies to PCM Trials as well as Professional Case Management. Just in case there’s a question, “we,” “us” and “our” means both Professional Case Management and PCM Trials.
  • Processing: it is any use of your Personal Data, including collection, storage, or using your address to send you an email or a flyer in the mail.
  • Processor: is an entity or person who processes (uses) the data for the Controller. Typically, a service provider, such as WordPress, is a Processor.

4. What Personal Data Do We Collect?

PCM Trials collects the following personal information:

Categories Type of Personal Information Who Data is Shared With Why We Collect It
Identifiers
  • Name
  • Title
  • Physical address
  • Email
  • Phone number
  • IP addresses
  • Cookies
  • Impairment Date
  • White Card status
  • Company name
Service Providers:

  • Salesforce
  • Microsoft
  • WordPress
  • WordPress Engine
  • GoToWebinar
  • Mailchimp
  • Provide services requested, e.g., request for information or access to an event
  • General website administration
  • Record keeping
  • Marketing & advertising
  • Survey purposes

Commercial Information, such as transaction history or payment information

  • Records, e.g., a request for services
  • Survey answers
Service Providers including:

  • Salesforce
  • Microsoft
  • Google Analytics
  • Google Adwords
  • WordPress
  • WordPressEngine
  • GoToWebinar
  • Mailchimp
  • Website administration, record keeping, data analysis, testing, surveys, troubleshooting
  • Marketing & advertising
  • Trend (aggregate) monitoring
  • Ensure website security
Internet/Network Activity Information
  • Cookies
  • IP address
  • Browser type
  • Internet service provider
  • Referring/exit pages
  • Files viewed (HTML pages, graphics, etc.)
  • Operating system
  • Date/time stamp
  • Clickstream data
Service providers including:

  • Google Analytics
  • WordPress
  • WordPressEngine
  • DoubleClick
  • Ensighten.com
  • Choozel
  • Adroll.com
  • Mailchimp
  • Internet or network activity for trend (in the aggregate) monitoring
  • Marketing & advertising
  • Ensure website security

As noted in the table above, PCM Trials collects identifiers and commercial information directly from you. We collect Internet or other electronic network activity from your use of our website and its services.

If you reside in the United States, from time to time PCM Trials may ask for your voluntary participation in a survey or poll, such as feedback on Website content or services. Your responses are anonymized unless you opt-in or ask to be contacted.

5. Passive Collection

Certain limited information is automatically collected when you click on our website address. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website.

6. Processing Your Personal Information

PCM Trials will process or use your personal information only if there is a lawful basis for doing so. A “lawful basis” may include consent, contractual necessity (to fulfil a contract) and PCM Trials’ legitimate interests or the legitimate interest of others (e.g. our users) such as:

  • Performing our services and delivering in-home care;
  • Receive access to our services on-line;
  • Obtain information about our services;
  • Participate in surveys or questionnaires posted on our Website;
  • Enable us to respond to your requests;
  • Comply with our legal obligations, resolving disputes with clients, enforcing our agreements;
  • Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal;
  • Support recruitment inquiries;
  • Improving upon our services.

PCM Trials does not sell personal information.

If you do not wish us to continue using your information in this manner, you can request deactivation by contacting us at [email protected], or as noted in the “Contact Us” section below.

7. Marketing and Advertising

If you have previously consented, requested, or had a relationship with PCM Trials, you may receive marketing materials, including emails, from PCM Trials or our affiliates. You may opt-out of those marketing messages at any time by unsubscribing through the “unsubscribe” or “opt-out link” in an email or via the following opt-out form: PCM TRIALS Unsubscribe.

Please note that if you opt-out of receiving our marketing-related emails, PCM Trials may still need to send transactional emails regarding important service communications because of our relationship or contract with you.

8. Your Rights and How to Exercise Them

Residents of the E.U., United Kingdom, Switzerland, the E.E.A., and California have certain rights with respect to their personal information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask for additional personal information in connection with your request if, for example, we need to verify your identity or the nature of your request. PCM Trials will make every effort to respond in a reasonable timeframe with a determination of our responsibilities or seeking verification of the request.

Your Rights:

  • Access: You can request more information about the personal information we hold about you. You can also request a copy of your personal information.
  • Correction: If you believe the personal information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Objection/Opt-Out: You can contact us to let us know that you object to the collection or use of your personal information for certain purposes. You can choose not to disclose your information. However, if you elect to skip such disclosures, our ability to respond to inquiries or provide services will be limited to the information you chose to share.
  • Erasure: You can request the deletion of some or all of your personal information from our systems.
  • Restriction of Processing: You can ask to restrict further processing of your personal information.
  • Portability/Transfer: You can ask for a copy of your personal information in a machine-readable format. You can also request that we transmit the data to another entity where feasible.
  • Withdrawal of Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.
  • Right to File Complaint: You have the right to lodge a complaint about PCM Trials’ practices with respect to your personal information with the supervisory authority of your country or E.U. Member State, or with the California Attorney General’s Office.
  • DO NOT SELL: Applicable to California residents only. However, PCM Trials does not sell any personal information.

To make any of the following requests pursuant to your rights under the GDPR or CCPA, please contact PCM Trials at [email protected] or by using the contact details below in the “Contact Us” section of this Privacy Statement. We will do our best to comply with your request(s) as soon as reasonably practicable.

9. Cookies and Tracking Technologies

Cookies are small data files placed on your device when you visit a website. They enable the website to remember your actions, preferences, and other information related to your visit (IP address, time of visit, number of visits, login data, preferred language, time spent on the website, etc.), for a certain period of time. PCM Trials and our partners use cookies or similar technologies to analyse trends, administer the website, track users’ movements around the website, and gather demographic information about our user base. For information regarding the cookies or similar technologies that PCM Trials uses and how to change your preferences, please review our Cookie Statement.

10. Mobile Application

When you register for certain services, or purposefully download and use our services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your devices such as operating systems and user identification information.

11. Sharing Your Personal Information

PCM Trials does not sell or rent your personal information to third parties for marketing purposes. We do share personal information within PCM Trials and with third-party service providers for data processing or storage.

We also share personal information with business partners, service vendors and/or authorized third-party agents or contractors; however, this sharing is limited to fulfilment of requested information, services, business inquiries, conference registration, and providing customer support. We limit what we share and provide only the minimum amount of information necessary to complete/utilize the requested products, services, or to complete a transaction. These third parties are not permitted to use your personal information except for the limited purpose of providing the requested service or information.

As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal information and other related information, if necessary. We also may use personal information and other related information to establish or exercise our legal rights or defend against legal claims.

We collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of PCM Trials’ terms of service, or as otherwise required by law.

12. Security of Your Personal Information

PCM Trials is committed to protecting the personal information you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal information from unauthorized access, use or disclosure. When we transfer personal information over the Internet, we protect it using multiple encryption methods as required by system protocols.

We recommend you take every precaution in protecting your personal information when you are on the Internet: change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal information, you can contact us at [email protected] or by using the contact details below in the “Contact Us” section of this Privacy Statement.

13. Linked Websites and Disclosure to Third-Parties

We may share your personal information with third parties in connection with their work for or with PCM Trials, for purposes consistent with those listed above and as described below:

Customers: We may share personal information and insights from our work with our customers in connection with providing our services to those customers.

Companies and people who work for us: We contract with other companies and individuals to help us provide services. For example, we may host some of our data on another company’s computers, hire technical consultants to maintain our sites, analyze data, provide marketing assistance, and provide customer service. In addition, we may validate your identity and other information against available databases. In order to perform such services, these other companies may have limited access to some of the personal information we maintain about our users. Other companies may collect information on our behalf through their websites or applications. We require those companies not use your information for any purpose other than fulfilling their responsibilities to us. We also require such companies to comply with applicable laws and work to keep your personal information confidential and secure. PCM Trials’ practice is to (i) perform reasonable and appropriate due diligence on our service providers; and (ii) obtain written contracts regarding the processing of personal information, including that the service provider will only act in accordance with our instructions, adopt adequate technical and organizational measures, and not retain data when it is no longer required. Details concerning our service providers are available from PCM Trials by contacting its Data Protection Officer at [email protected].

Promotional and informational offers: Sometimes we send offers to certain users. To do so we may use third parties working on our behalf. We provide you with a number of ways to let us know you do not want to receive these offers. For example, where required by law, we may provide an opt-in box for customers to receive information that is sent by a third-party and we make clear that, by opting in, you are submitting your data to a third party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out as mentioned or included in each of our programs or communications sent to you.

Business partners. We may share information with prospective or current customers, and other vetted business partners who work with us.

Professional advisors: We may disclose personal information to professional advisors, such as lawyers, bankers and insurers, where necessary in the course of the professional services provided to us.

Business transfers: If we transfer a business unit or an asset (such a website) to another company, we may transfer the personal information collected to the relevant third party.

Legal requirements: We may be obligated to cooperate with various law enforcement inquiries. PCM Trials reserves the right to share or transfer information to comply with a legal requirement, disclose activities or information about you to law enforcement or other government officials as we, at our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, for administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. We may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.

Further, our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Statement. We encourage you to review the privacy policies/statements/notices posted on these (and all) sites you visit or services you use.

14. Transfer and Storage of Personal Information

This website is owned and operated by PCM Trials in the United States. PCM Trials may transfer your personal information to the United States, to any PCM Trials affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. Some of PCM Trials’ companies and third parties may be located in countries that do not require the same level of data protection as the country you reside in.  When transferring personal information across country borders, PCM Trials and its companies utilize appropriate transfer mechanisms as applicable (which may include consent, Standard Contractual Clauses, existing adequacy decisions, etc.). Nevertheless, all PCM Companies are required to treat personal information in a manner consistent with this notice and our internal global privacy policies.  By using our services or providing personal information for any of the purposes stated above, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations, whether provided by you or obtained through a third party, including the hosting of such personal information on servers in the United States.

15. Data Retention

PCM Trials stores your data no longer than necessary. How long we retain your data depends on the type of data and the purpose for which the data was collected and processed. We will typically keep your information for no longer than the purpose(s) for which it was obtained, unless we have a legal obligation to keep it for a longer period or retention is advisable for PCM Trials’ legal position (for example, regarding applicable statutes of limitations, litigation or regulatory investigations).

16. Children’s Online Privacy Information

No part of our website is designed to appeal to anyone under the age of 13, nor is the website intended for minors under the age of 18.  PCM Trials does not knowingly collect personal information from any person under the age of 18, unless a parent or guardian provides consent. Under certain circumstances, PCM Trials may receive the personal information of minors under the age of 18 who are participating in a clinical trial. In those instances, a rigorous protocol of parental consent is managed by the clinical trial site, and questions regarding personal information should be directed to that entity.

If you believe that we have mistakenly or unintentionally collected the personal information of a minor under the age of 18, please notify us at [email protected] so that we may delete the information from our servers.

17. Changes to This Privacy Statement

We may make changes to this Statement from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes made in the future will be posted on this page, accompanied by a notice on our home page that this Statement has changed.

18. List of PCM Companies

Entity Country Location / Contact Info
Act for Health, Inc USA – Colorado 500 E. 8th Avenue, Denver, CO 80203, United States

1-888-886-2281

Professional Case Management Clinical Trials, LLC USA – Colorado 500 E. 8th Avenue, Denver, CO 80203, United States

1-888-886-2281

PCM Clinical Trials International, LTD UK 6th Floor 1 London Wall, London, United Kingdom, EC2Y 5EB

19. Contact Us

Any personal information questions or comments related to this Privacy Statement can be emailed to [email protected], or called in to the PCM Compliance department.

You may also contact us by writing to this address:

PCM Trials
Attention: Privacy – PCM Data Protection Officer
500 E. 8th Avenue
Denver, CO 80203

For any other questions regarding our services or sister companies, please email [email protected] or write to the following address:

PCM Trials
Attention: Outreach Help Center
500 E. 8th Avenue
Denver, CO 80203

EU Representative

We have appointed The DPO Centre Europe Ltd as our EU representative. Their contact details are as follows:

The DPO Centre Europe Ltd
Alexandra House
3 Ballsbridge Park
Dublin, D04C 7H2
Ireland

Email: [email protected]
Tel: +353 1 631 9460

Updated: 10/2021