Proactive Technology Systems, LLC 

Privacy Policy

 

 

Effective Date: August 1, 2020

1.         Introduction

Welcome!  Your use of Proactive Technology Systems, LLC. (“ProactiveTech”) website and the services made available through same, including the password protected portal (together, the “Website”) constitutes your acceptance of this Privacy Policy (the “Privacy Policy”), which incorporates by reference our Terms and Conditions of Use located on our website.  If you do not accept this Privacy Policy, you may not use the Website or our Services (as defined below).  If at any time you do not agree to this Privacy Policy, you must cease your use of this Website and our Services.

We value our customers and are committed to protecting their privacy and informing them as to how their personal data will be used.  As a general matter, we collect customer information to provide the services identified on the Website, including specifically for clinical study management and facilitating payment process for clinical study medicine (the “Services”).  We also collect this information in an effort to improve your experience using the Website and that of our other Website users, and to communicate with you about our services and promotions, as well as other matters in which you may be interested. We recognize that we must maintain and use customer information responsibly. We have created this Privacy Policy to address our practices regarding information collected from visitors to, and users of, the Website.

This Privacy Policy does NOT apply to other websites or apps to which we may otherwise link, or to other companies or third-party vendors who provide services to us including providing entities which process pharmacy claims, or entities who might be listed as third-party contacts on this Website, each of which may be governed by their own privacy policies.  This Privacy Policy also does not apply to information we may obtain from other sources about you.  By using the Website and/or by contacting us and providing any personal data, you consent to the collection, transfer, storage, disclosure and use of information by us in accordance with this Privacy Policy.  If we decide to change our Privacy Policy, we will post those changes on this page.

Please do not visit or use this Website from the European Union or European Economic Area, or anywhere else whose laws may conflict with this Privacy Policy; this Website is not intended for your use if you are attempting to use from any of these countries and you do not have permission to use the Website.  Please note that this exclusion is solely because the laws of your country may not conform with our policies as set forth in this Privacy Policy.

 

2.         Why We Collect Information

 

We collect personal data because: (a) it allows us to provide the Services offered through the Website; (b) it allows us to respond to questions you or others may have about the Website or the information provided to you or others on or through the Website; (c) it helps us provide and improve the Website and the information provided from or through the Website; and (d) it allows us, with your consent, to utilize certain data in connection with clinical trials.  In addition, your personal data helps us communicate to you through the Website, as well as to provide additional related information and events about which you might like to hear.  We also may correlate your personal data with information from other sources.  For example, we may correlate this data in connection with clinical trial data analysis and program adherence, as well as potentially cross-check the personal data you provide to us against information that might be otherwise available through other entities in order to prevent or detect fraud.

 

3.         What Information We Collect About You

 

We may collect all types of “personal data.”  For purposes of this Privacy Policy, the term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable, and may specifically include:

  • Names and contact information, including phone number, physical address, and e-mail address;

  • Birthdate and sex;

  • Any other similar information provided to us by you or on your behalf in connection with our Services.

 

You agree that we may collect and process all such personal data that you provide to us to enable us to provide the Services, which, in addition to the Services described above, may also include:

  • Management of the Website and all content and services therein.

  • Responding to or addressing any questions or inquiries from you or otherwise regarding us, any Services we provide, or our Website (whether your question or inquiry was via e-mail, directly on the Website, hard copy otherwise).

 

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

 

  • Updating our records;

  • Monitoring your Website use history, information reviewed and comments or annotations made;

  • Obtaining demographical information of our users;

  • In connection with any application for employment with ProactiveTech;

  • Internal analysis for our business management purposes;

  • Any statutory or regulatory purpose which requires the processing of your personal data;

  • Legal and regulatory compliance;

  • Fraud and crime prevention;

  • Internal or external audits; and

  • Any other purpose for which valid consent is obtained.

 

In addition to the above, we may also collect other data (apart from personal data) from you which is not personal data, such patient or subject number from a pharmaceutical company in connection with a clinical trial or study.

 

Please do not supply the following to us:

  • Any other person's personal data, unless ProactiveTech explicitly asks you to do so;

  • Any categories of your personal data that have not been explicitly requested by ProactiveTech;

  • Any personal medical information that has not been explicitly requested by ProactiveTech;

  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by ProactiveTech to provide; and/or

  • Any confidential, proprietary, secret or legally protected information which you are under any legal obligation to not provide to or share with ProactiveTech.

4.         How We Collect Information About You

 

We collect information about you (including personal data) when:

  • You Give Us Information - You may provide us information when:

    • You set up an account with us;

    • You provide it to us by filling out forms, including consent forms, or filling out any other information or forms on or through the Website;

    • You send us e-mail or submit any inquiry on or through the Website, including in connection with a request or inquiry;

    • You provide information via phone or in person;

    • You provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);

    • You provide us with documentation;

    • You provide us with information which may contain personal data; and/or

    • You provide us with information in connection with seeking employment with ProactiveTech.

  • We Collect Information Automatically – We automatically collect certain types of information when you visit  our Website (as explained below).

  • We Collect Information From Other Sources – We may also obtain information about you from outside   sources.  For example, we may obtain commercially available information about you from our sponsors (i.e.,    pharmaceutical companies, third-party service providers, investigators, research institutions or other entities with whom we have a business relationship). 

5.       Use of Cookies

 

Cookies

Cookies are bits of electronic information that a Website may transfer to a visitor’s device to identify specific information about the visitor’s visits to the Website.  The Website may use a feature known as a cookie, which assigns a unique identification to your device. Cookies are typically stored on your device’s hard drive and are used to help track clicks as you go through the pages within our Website.  We may also use cookies to tell us whether you have previously visited the Website. We also use cookies which may be set by third parties with whom we have entered into agreements which may enable us to obtain analytics information about the use of our Website.  You can set your browser or operating system not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer.

 

Cookies That We Use

 

We use cookies for the following purposes related to the Services we provide for and to you and our users:

  • authentication - we use cookies to identify users of the Website and/or the location of individuals accessing the Website;

  • status - we use cookies to help us to determine if you are logged into our Website;

  • personalization - we use cookies to store information about your preferences and to personalize the Website for you;

  • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our Website and services generally;

  • diagnosis – we use cookies to diagnose problems with our Services and servers;

  • analysis - we use cookies to help us to analyze the use and performance of our Website and Services

           

Cookies Used By Our Service Providers And Vendors

  • Our service providers and vendors may also use cookies and those cookies may be stored on your computer when you visit our Website.  These may include:

  • session cookies – to track the user’s use of the website and our Services.  This allows you to continuously use our Services and the website without having to constantly log in.

  • permanent cookies – this allows you to leave the website or portal, and then return at a later time and after logging in, use the Services in a more consistent manner.  These cookies typically expire within 365 days of the last time you visited the website.

  • third party cookies – our service providers and vendors may also use the same types of cookies listed above which are used by the Company for the same purposes.  

  • The specific cookies used may change from time to time as we use different vendors or service providers to provide some or all of the Services offered or provided by the above services and websites, or additional services we decide to include. 

Managing Cookies

  • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. To obtain more information about managing cookies on your device, please see: https://www.allaboutcookies.org/mobile/ or these links:

6.         How We Use the Information We Collect

We use the information we collect in a variety of ways.  Generally, we use the information we collect, including information provided by you, your personal data, and aggregate/de-identified data, to provide the Services.

We may also use the information we collect internally in our business for many business purposes, such as to: (i) provide the Services you may seek or which are available on the Website; (ii) provide aggregated or other data to third parties concerning the results of your reporting and monitoring on and through the Website, with or without other aggregated data; (iii) analyze trends and conduct research; (iv) provide support and respond to questions from our users, Website visitors and customers; (v) improve our Website; (vi) learn about users’ and customers’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our Website; (viii) track traffic patterns and Website usage; (ix) provide customer service and technical support; (x) correlate information with other commercially available information to identify demographics, reporting and monitoring needs, trail conditions, user impact and any other service or information offered on or through the Website; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website, our partners or customers, or the public; and (xv) process or engage in a sale of all or part of our business/organization(s), or if we go through a reorganization or merger.

 

We may also share personal data and non-personally identifiable information externally with our affiliates and business partners, as well as with other third-party service providers who help us provide operational services for the site and our business, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Policy.

 

We may also use your personal data to contact you in ways other than e-mail or regular mail, such as via telephone contact or facsimile.  All use of personally identifiable information will be as permitted by applicable law.

 

7.         Business Transfers

 

If ProactiveTech or substantially all of its assets were acquired, or in the unlikely event that ProactiveTech goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of ProactiveTech may continue to use your personal data as set forth in this Privacy Policy.

 

8.         Your Choices about the Information We Collect

 

If you do not consent to the way in which we may use your personal data, please do not submit any personal data to us. Please note that if you do not provide us with certain personal data ProactiveTech may be unable to allow you to use or access the Website, or the services and/or information on or through the Website may not be as good as they otherwise could be.

9.         Privacy of Children Who Visit the Website

We recognize the importance of children's safety and privacy. The Website is not designed to attract children and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18.

10.       Your California Privacy Rights

We collect various types of personal data about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us to disclose the categories or personal data of yours which we have shared with third parties, for the third parties’ direct marketing purposes during the prior year. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.

If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below with the words “CALIFORNIA OPT-OUT” in ALL CAPS in the subject line or clearly set forth elsewhere. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form so you may request that your personal data not be disclosed to third parties for their direct marketing purposes.

E-mail Address:

Postal Address:

Proactive Technology Systems, LLC

P.O. Box 2220

Flemington, NJ 08822

Attn: Privacy Officer Greg Miller

 

e-mail: gmiller@proactivetech.com

11.       Visitors to the Website From Outside of the United States

If you are visiting the Website from a location outside of the United States, you should not use this Website and you are not permitted to do so.  Your connection may be through and to servers located in the United States. Please note that the data protection laws in the United States and other countries might not be the same as those in your country.  By using this Website and/or submitting information to us, you specifically consent to the transfer of your information to the United States to the facilities and servers we use, and to those with whom we may share your information.

12.       Security

We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.

While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure.  No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the Website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

13.       Questions / Changes in Notice

If you have questions or concerns with respect to our Privacy Policy, you may contact us at with the words “PRIVACY” in ALL CAPS in the subject line.

We may elect to change or amend our Privacy Policy; in such event, we will post the notice changes in our Privacy Policy on the Website.

 

Contact Information:

Proactive Technology Systems, LLC

P.O. Box 2220

Flemington, NJ 08822

Attn: Privacy Officer

e-mail: gmiller@proactivetech.com