Privacy Policy

The categories of Personal Information we may collect and our privacy practices depend on the nature of the relationship you have with WCG and the requirements of applicable law. We endeavor to collect information only relevant for our business needs.

• Information you submit. We collect information whenever you provide it to us directly, such as when you submit Personal Information through our “Contact Us” page, seek to partner with us, sign up as a clinical trial volunteer, speak or attend a WCG event, create an account, or sign up for any of our newsletters or publications. Such information may include demographic and contact information such as your name, your affiliated company or institution and position, email address, gender, location, clinical focus, and other information regarding your interest in us.
• Cookies and similar technologies.  We, as well as third parties that provide content or other functionality, may use cookies and other technologies to automatically collect information.  Our uses of these technologies fall into the following general categories:
• Operationally Necessary. This includes technologies that identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality.
• Performance Related.  This includes technologies to assess the performance of our websites, including analytic practices to help us understand how our visitors use our websites. For example, we may use Google Analytics to collect information regarding visitor behavior on our Site to aid website content development. This analytics data is not tied to any Personal Information.  You can opt out of tracking and Google Analytics processing here.
• Functionality Related.  This includes technologies that allow us to offer you enhanced functionality when accessing our websites.  This may include identifying you when you sign in or keeping track of your specified preferences, interests, or past items viewed. Targeting-Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.  For example, we use Google’s DoubleClick product. For more information about Google’s use of your personal information, please visit Google’s privacy policy. To learn more about how to control Google’s use of your information for ads, please click here.

When you view content provided by WCG through our Services, we may automatically collect and store certain information in server logs. This may include Internet Protocol (IP) address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, and cookies that may uniquely identify your browser.

For more information regarding your choices with respect to these technologies, please see “Transparency and Choice” below.

• Provide our Services. We primarily use Personal Information to advance our Services or to support our relationship with you.  We may also use information to develop, maintain, and improve our Services and to protect WCG and our users and partners.
• Administrative purposes. WCG may also use Personal Information and other information collected for administrative purposes, including, without limitation, to: (a) measure interest in WCG’s Services and our website content; (b) comply with regulatory requirements; (c) manage our agreements and your relationship with us; (d) verify or maintain data integrity or quality; (e) process payments and transactions; and (f) detect and prevent potentially prohibited or illegal activities, such as malicious, deceptive, fraudulent or illegal activity.
• Site analytics and improvement. WCG uses cookies to identify return visitors, record user preferences, and measure the effectiveness of our site.  
• Other uses. WCG may also use the information we collect to: generally manage information and accounts; respond to questions, comments and requests; provide access to certain areas and features of the WCG sites; ensure internal quality control; verify individual identity; enable individuals to register for events or participate in seminars; communicate about individual account and activities; at WCG’s discretion, make changes to any WCG policy; process applications and transactions; market our Services; comply with law or regulatory requirements; undertake activities to verify or maintain the quality or safety of a Service, and to improve, upgrade, or enhance the Service; undertake internal research for technological development and demonstration; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity; identify and repair errors that impair existing intended functionality; and for purposes disclosed at the time that individuals provide information or otherwise with consent.
• De-identified and aggregated Information. We may use Personal Information to create de-identified and/or aggregated information, such as information about the device from which you access our Services, or other analyses we create. 

We do not sell Personal Information or disclose it to companies, organizations, and individuals outside of WCG unless one of the following circumstances applies:

• Consent.  We will disclose Personal Information to companies, organizations, or individuals outside of WCG when we have your consent to do so.
• Service Providers. We may disclose your Personal Information to our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners.  We may disclose Personal Information to our business partners to advance business initiatives or to jointly administer projects.
• Disclosures to Protect Us or Others.  We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• Agents for External Processing.  We provide Personal Information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. With respect to onward transfers to agents under the Data Privacy Framework, the Data Privacy Framework requires that WCG remain liable should its agents process Personal Information in a manner inconsistent with the Data Privacy Framework Principles.
• Business Transactions.  We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, purchase or sale of assets, transition of service to a provider, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, WCG will endeavor to direct the transferee to use Personal Information in a manner that is permitted by law and/or contract and/or consistent with this Privacy Policy.

Where you have consented to WCG’s use of your Personal Information or sensitive Personal Information, you may withdraw that consent at any time and opt out by contacting us. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out as required by applicable law.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our terms or this Privacy Policy).
• “Do Not Track” / “Global Privacy Control.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as either a “Do Not Sell” request or a request to limit the sale or sharing of Personal Information for targeted advertising depending on the law applicable to your jurisdiction. Note that we do not currently engage in any data sales or targeted advertising.

Cookies and similar technologies. You may stop or restrict the placement of cookies and similar technologies on your device or remove them by using the controls we make available in our cookie banner or adjusting your preferences as your browser or device permits. However, note that if you adjust your preferences, our Services may not work properly. Please note you must separately opt out in each browser and on each device.

You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.  Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Services and for other legal purposes as described above.  In accordance with applicable law, you may have the right to:

• Access to Personal Information about you, consistent with legal requirements.  This includes (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information; and (iii) receiving an electronic copy of Personal Information that you have provided to us or asking us to send that information to another company in a structured, commonly used, and machine-readable format.
• Request Correction of your Personal Information where it is inaccurate or incomplete.  In some cases, we may provide self-service tools that enable you to update your Personal Information or, if applicable, we may refer you to the business that controls your Personal Information to make the correction.
• Request Deletion of your Personal Information, subject to certain exceptions prescribed by law.
• Object to Processing of your Personal Information where the processing of your Personal Information: (i) is based on our legitimate interest for direct marketing; (ii) involves processing or sharing of your sensitive Personal Information for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects that concern you. Please note that we do not engage in such types of profiling.
• Lodge a Complaint, while we are always willing and eager to listen and respond to your concerns about this Privacy Policy or our data practices, at any time you have the right to lodge a complaint with the data protection authority or other regulatory body in charge of enforcing data protection laws in your jurisdiction.

To make a privacy rights request, please use the contact information located at the end of this Privacy Policy. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. You may also designate an authorized agent to make a request on your behalf. To designate an authorized agent, please contact us.

WCG’s Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect Personal Information from children.  If you learn that your child has provided us with Personal Information without your consent, please contact us.  If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information unless we are legally obligated to retain it to protect our rights and terminate the child’s account.

WCG complies with the requirements of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, as set forth by the U.S. Department of Commerce. WCG has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. Data Privacy Framework and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. Data Privacy Framework. WCG has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. Data Privacy Framework. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. Data Privacy Framework Principles and/or the Swiss-U.S. Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view WCG’s certification, please visit https://www.dataprivacyframework.gov/.

If you are located in the European Economic Area, the United Kingdom, or Switzerland you may seek confirmation regarding whether WCG is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been processed in violation of the Data Privacy Framework Principles. Where otherwise permitted by applicable law, you may use any of the methods set out in this Privacy Policy to request access to, receive (port), object to processing (including in some cases automated decision making and/or profiling), restrict processing, seek rectification, or request erasure of Personal Information held about you by WCG. Although WCG makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which WCG is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If WCG determines that access should be restricted in any instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. In situations where another method of making requests applies (such as in the context of research), we will provide you with information about how to make requests at the time you contact us that are consistent with the information you received when you provided your Personal Information. Such requests will be processed in line with local laws. 

In compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, WCG commits to resolve Data Privacy Framework Principles-related complaints about our collection and use of your Personal Information.  EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework should first contact our Chief Privacy Officer. We will respond to your inquiry promptly. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, WCG commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework to JAMS Data Privacy Framework, an alternative dispute resolution provider based in the United States, Canada and the United Kingdom. In compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, WCG commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework in the context of the employment relationship. If you do not receive timely acknowledgment of your Data Privacy Framework Principles related complaint from us, or if we have not addressed your Data Privacy Framework Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS Data Privacy Framework Dispute Resolution are provided at no cost to you. If any request remains unresolved, you may contact the appropriate data protection authorities listed above.  If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms as described on the Data Privacy Framework Program’s site here.

As explained above in “How WCG Discloses Personal Information” we sometimes provide Personal Information to third parties to perform services on our behalf. If we transfer Personal Information received under the Data Privacy Framework to a third party, the third party’s access, use, and disclosure of the Personal Information must also be in compliance with our Data Privacy Framework obligations, and we will remain liable under the Data Privacy Framework for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

WCG is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose Personal Information that we handle under the Data Privacy Framework in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We store the Personal Information we collect as described in our Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. We endeavor to retain all such Personal Information in accordance with legal requirements.

The security of all Personal Information provided to WCG is important to us, and WCG takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while WCG strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to WCG, and you do so at your own risk. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Our Privacy Policy does not apply to services offered by other companies or individuals, or other sites linked from our website. Our sites may contain links to other websites for your convenience and information. WCG does not control such third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. WCG does not endorse or make any representations about third-party websites. Any Personal Information you choose to give to unrelated third parties is not covered by this Privacy Policy. WCG encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their users’ Personal Information with WCG; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

WCG may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, WCG will notify you as required by applicable law. WCG encourages you to review this Privacy Policy periodically to be informed regarding how WCG is using and protecting your information and to be aware of any policy changes. Any changes to this Privacy Policy take effect after being posted or otherwise provided by WCG.

Contact Us

WCG Clinical, Inc.
Attn: Chief Privacy Officer
212 Carnegie Center, Suite 301
Princeton, NJ 08540
Phone: +1 (360) 252 – 2428
Email: [email protected]

NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN JURISDICTIONS

UNITED STATES

This Notice at Collection and Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time (collectively, “Applicable State Laws”).

As more fully described in the section titled “Information We Collect”, the sources from which we collect Personal Information include directly from you when you interact with us, and automatically from you when you use our sites and Services.

Depending on how you use our Services, the information we may have collected about you, as well as the categories of third parties with whom we have disclosed this information, are described in the table below.

We may use or disclose Personal Information for the purposes outlined in “How We Use Information We Collect” above. These purposes include:

• To provide the Services to you; 
• For our administrative purposes (including security, fraud detection and protection, and improve our Services); 
• To process your requests; 
• With your consent; and 
• To comply with law and enforce our rights and the rights of others. 

Where required under applicable law, we will not collect additional categories of Personal Information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes without first providing you notice.

For purposes of certain state laws, WCG does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. However, that being said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising and targeted advertising. To the extent that such sharing is considered a “sale” or “sharing” or disclosing for targeted advertising under California or other Applicable State Law, you may limit such sharing by contacting us.

The table below contains a list of the primary legal bases on which we rely when processing personal data from the EU and EFTA states.