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Data Privacy Policy
Institut de Recherches Internationales Servier
("SERVIER" or "We"), a company
registered under the laws of France under, having its registered office at 22, route 128,
91190 GIF-SUR-YVETTE
–
FRANCE, registered with the Register of Commerce and
Companies of Nanterre under number 319 416 756,
–
France uses this mobile
application (hereinafter referred to as th
e “App”)
in order to collect data of patients
enrolled in clinical studies sponsored by SERVIER.
We respect the privacy of everyone who uses the App and only collect and use personal
data in ways that are described here, and in a manner that is compatible with our
obligations and your rights under the law. This Privacy Policy only applies to your use
of the App.
1.
What data do we collect?
According to the General Data Protection Regulation ("GDPR"), personal data means
any information that can directly or indirectly identify you.
This Servier study requires that participants register into the App. This registration
occurs without providing direct identifiers.
We collect all data communicated during registration and use of the App.
No directly Personal Identifying Information will be collected from study participants
using Our App and we ask that you please refrain from communicating any directly
Personal Identifying Information when using the App.
The App does not use GPS or tracking cookies. Cookies are used solely for
session/state management and there is limited tracking of IP address information for
system security and audit logging purposes: these cookies are strictly necessary for
the App to function correctly.
2.
How do we use your data?
As already specified in the Informed Consent form you signed for the participation to
the study:
Use of your data for the purpose of the study and/or in connection with the product or
your disease:
Your data will be observed and used for the purpose of the study. They may be used
after the end of the study in connection with the product and/or your disease.
The processing of your personal data is based on the legitimate interest of SERVIER
necessary for scientific research or based on your consent if the regulations of your
country require it.
The use of your data is mandatory: it is not possible to participate in the study without
having your personal data processed.
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Use of data for other purposes:
Your data, including the data generated as a result of the study, may be used after the
end of the study as part of future scientific research to advance science, medicine and
public health. These data may also be processed to anonymize them in such manner
that you are no longer identifiable.
In these cases, the data may also be shared with private or public third-parties (such
as academic, researchers, partners) with appropriate safeguards. In no case your name
nor any direct identifier will be disclosed. These uses may have to be approved by
Ethics Committees and Competent Authorities beforehand.
The processing of your personal data is based on the legitimate interest of SERVIER
necessary for scientific research or based on your consent if the regulations of your
country require it.
We do not further process the data in a manner that is incompatible with the purposes
described above.
3.
What are your rights?
If applicable, you have the right to request access and obtain information about your
personal data; update/correct; and delete your personal data; restrict or object to the
processing of your personal data. You can withdraw your consent to participate in the
study. In that case your personal data previously collected will still be used as it is
necessary for the purpose of the study.
To exercise your rights, please contact your study Doctor. His/Her contact information
can be found in the informed consent form.
If need be, you may also contact the SERVIER Data Protection Officer (DPO) at the
following address, bearing in mind that they will not have access to your identity:
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by email, at the following address: dataprivacy@servier.com
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or by mail, at the following address:
Data Protection Officer
Institut de Recherches Internationales Servier
50, rue Carnot
92284 Suresnes Cedex
France
Should you have any cause for complaint regarding our use of your personal data, you
have the right to lodge a complaint with the competent data protection authority of your
country or to the supervisory authority to which the sponsor is subjected (www.cnil.fr).
4.
How long do we keep your personal data?
Your personal data collected during the study through the App will be kept for a
minimum of 25 years after the end of the study. The duration will be defined according
to the applicable regulatory requirements.
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5.
How do we safeguard your personal data?
We have put in place appropriate and commercially reasonable technical and
organisational security measures to store your personal data that we collect and keep
confidential and to protect them against unauthorised or unlawful disclosure or access,
accidental loss, destruction, alteration or damage taking into consideration the state of
art of technology and the cost of implementation.
Furthermore, no directly identifying information is processed through the App.
6.
Who accesses your data?
Your name and surname will be known only by your study doctor and the site staff as
well as authorized persons in charge of controlling the quality of the study and
managing the App. For other people involved in the study (including the sponsor,
SERVIER), you will be identified by a unique participant number (coded data) without
mentioning your name.
Your personal data processed will only be accessible by a limited list of recipients on a
need to know basis or where required by law, taking into account the aforementioned,
including but not limited to:
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The departments and personnel of SERVIER and other legal entities of the
Servier Group with a need to know.
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The suppliers and service providers of SERVIER, particularly those responsible
for hosting and maintaining the App, who may be called upon to access the
personal data of users for purposes strictly necessary for their work.
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The investigators, such as your study doctor and the site staff for the study you
are enrolled in.
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The competent authorities such as health authorities in certain legally defined
cases.
Your personal data may be used by people located inside or outside your country, such
as the Web App that is managed securely by a US based provider. For countries that do
not provide an adequate level of protection of personal data, the sponsor ensures that
all transfers are carried out with appropriate safeguards offering the same level of
protection as defined in the applicable data protection laws and regulations. To find
out which countries your data will be transferred to and the safeguards mechanism
used to secure your data, please contact your study doctor.