SMART-TRIAL (also referred to as “Company”, “we”, “our” or “us”) is committed to protect and safeguard our customers', visitors’ users’ personal data and privacy.
This Policy applies to information collected;
- Through the websites www.smart-trial.com, www.smart-trial.co, any subdomains of smart-trial.co and smart-trial.com, and our services (also referred to as “SMART-TRIAL”).
- In e-mail, text and other electronic messages between you and SMART-TRIAL; and
- When you interact with our advertising, third-party websites or services.
By accessing or using our websites and services, you agree to this Policy. If you disagree with this Policy, you should discontinue using our services.
We highly encourage you to visit our website regularly as we might amend the Policy from time to time. Such amendments will be effective upon posting on the website. Your continued use of our services is deemed an acceptance of those changes.
SMART-TRIAL controls the processing of personal data as described in this Policy. Our contact information is:
K. Christensens Vej 2L
9200 Aalborg SV
CVR no. 35 13 97 10
What Information we Collect and How we Collect it
We may collect general and sensitive information, such as:
- Name, address, e-mail, telephone number;
- Credit card and other payment information (such as bank account information);
- Occupation, home country, professional field;
- Information provided by you to us in e-mail, text and other electronic messages; and
- Information about your internet connection, the equipment you use to access our services.
- Geolocation and information obtained from public records searched (“yellow pages” or other publicly available registries etc.)
The information is either; supplied directly by you, automatically or by third parties.
INFORMATION PROVIDED BY YOU
SMART-TRIAL may collect and use all personal information that you choose to share or disclose directly to us.
We will collect your information when you are in touch with our customer success or service team, or reach out to us through other means (such as social media and advertising).
We will collect records and copies of your correspondence, if you contact us in any way (including mail, e-mail, text or electronic messages on our “Contact Us page”, your response to surveys that we might ask you to complete for research purposes, details of services you request and etc.).
If you have an actual or prospective business relationship with SMART-TRIAL (including actual or prospective customer, vendor, supplier or service provider), you may be required to provide us with additional information such as ID/registration number, bank and account details as well as other financial data considered necessary.
INFORMATION COLLECTED AUTOMATICALLY
We will collect your information automatically as you navigate through our websites and use our services. This may include your:
- Geolocation and ZIP code, IP-addresses, language settings, hardware, software and internet browser, date and time accessing our services; and
- Age, gender, preferences, click behaviour and other respective data collected through cookies and other tracking technologies.
PERSONAL DATA RECEIVED FROM THIRD PARTIES
We may collect information about you from third parties. These include business partners, public records and other independent third parties.
Anything we may receive from them, may be combined with information provided directly by you.
The technologies we use for automatic data collection may include:
- Device IDs. A device ID (device identification) is a unique device identification associated with a device. It may be possible to limit device ID tracking by adjusting the settings on your device. However, if you limit device ID tracking you may be unable to access our services or certain features offered in our services.
- Cookies.A cookie is a small file placed on your computer or mobile device.
- Web Beacons. Pages of the Website and electronic communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened a message and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). Some web beacons may be disabled by adjusting the settings in your browser or email settings or by installing browser add-ons. However, if you disable web beacons, you may be unable to access our services, the websites, or certain features offered in our services or websites.
- Server Logs. A server log is a log file (or several files) that are automatically created and maintained by a server that track activities performed. Users cannot disable server logs. These server logs are critical for maintaining security and minimise any performance issues of our services.
IP ADRESSES AND COOKIES
We may collect information about your computer including, where available, your IP-address, operating system and browser type for system administration. This is statistical data about our user’s browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file, which is stored on the hard drive of your computer.
To make our website and services work properly, we may place small data files called cookies on your device. This is common practice for most websites and web applications.
What are cookies?
A cookie is a text file containing information that is downloaded to your computer or mobile device when you visit a website. Cookies are useful because they allow websites to recognise a user's device. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. You can find more information about cookies at: www.allaboutcookies.org.
When we refer to cookies throughout this Policy, we intend to cover all similar devices including web beacons and log files.
What type of cookies do we use?
When you use our website and services, the following categories of cookies may be set on your device:
These cookies are primarily set by our services, such as SMART-TRIAL®. For the most part, they are strictly necessary to enable you to use our services and website.
In addition to our use of these applications, certain third parties and affiliates may set and access cookies on your computer in conjunction with web beacons. Some of which are only used for monitoring of our services (SMART-TRIAL), others are used for monitoring our websites.
Google Analytics (used in SMART-TRIAL services and on all websites)
Click here to opt-out of Google Analytics.
Hotjar web analytics (only websites)
This Website uses Hotjar web analytics service. Hotjar may record mouse clicks, mouse movements and scrolling activity where we use this information to improve user experience. Hotjar collects information regarding pages visited, actions which are taken, country, device used, operating system, and browser used. Hotjar does not collect personal information that you do not voluntarily enter in this Website. Hotjar does not track your browsing habits across web sites which do not use Hotjar services. For more information about cookies used by Hotjar you may visit: hotjar.com
If you do not want to be tracked by Hotjar on websites, you can turn it off with a “do not track” header or visit https://www.hotjar.com/legal/compliance/opt-out.
Google Ads (only websites)
The Google Ads cookie is used to track conversions from ads in the Google search and on the Google Display network, as well as retargeting. The retargeting is anonymous targeting of ads across the Google display network.
Click here to opt-out of Google AdWords.
Facebook (only websites)
The Facebook cookie is used for online behavioral advertising and for conversion tracking in connection to Facebook Ads.
Click here to opt-out of Facebook Ads.
HubSpot (only websites)
This Website uses Hubspot cookies for certain functional purposes as well as for tracking visitors’ identity, sessions and activity on the Website and authentication. For information on Hubspot cookies you may visit: hubspot.com. We use some but not all of the cookies listed in the above link. Note that we do use the Hubspot feature that gives users the choice to opt out of cookies. Thus we always place a small cookie on your computer only to remember your cookie preferences on our websites.
LinkedIn (only websites)
This website uses LinkedIn cookies for online advertising and for conversion tracking in connection to LinkedIn Ads. Please see linkedin.com for opt-out of LinkedIn cookies.
Microsoft Advertisement (only websites)
This website uses Microsoft Advertisement cookies for online advertising and for conversion tracking in connection to Microsoft Advertising. Please see microsoft.com to opt-out of Microsoft Advertisement.
Microsoft Azure App Insights (used in SMART-TRIAL services and on all websites)
How to manage cookies
We will only set cookies on your device if you have provided consent. At no time can the cookie read any information from your hard drive, and you can remove it from your machine at any time. If you don't want to receive certain categories of cookies on our websites, you can use the tool provided by DAA to opt-out.
SECURITY AND CONFIDENTIALITY
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We have implemented appropriate technical and organizational measures designed to secure your personal information from accidental loss, deletion, unauthorized access, use, alteration and disclosure.
We store your personal information at controlled facilities on computers with limited access.
Only authorized personnel are permitted to access personal data during their work.
We will retain your personal data for as long as we deem it necessary to;
- enable you to use our services,
- provide our services to you,
- comply with applicable law,
- comply with the research procedures,
- resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities
Please review the SMART-TRIAL service and security statement for more information on our service specific security procedures.
WHY DOES SMART-TRIAL COLLECT AND USE YOUR PERSONAL DATA?
SMART-TRIAL collects and uses information for the below mentioned purposes:
- Customer service; sharing and using relevant information (such as account information) when you need our help.
- Services and materials; to protect our materials and content. To operate and deliver the SMART-TRIAL service and other services that you have requested. And to improve, calibrate and customize our products and services;
- Account facilities; to administer your account (including information, products, services & billings).
- Marketing activities; to provide you with materials, products or services that we feel may interest you, where you have consented to be contacted for such purpose.
- Communication with you; there may be situations where we contact you (by e-mail or phone);
- responding to and handling any requests from you,
- to notify you about changes to the Website and services,
- to help us improve, calibrate, customize and optimize our products and services,
- Market research; sometimes we will ask for your assistance regarding;
- historical, statistical or research purposes,
- Legal purposes; we may need your information to carry out our legal and contractual obligations.
- Other purposes; other actions compatible with the abovementioned actions.
It is voluntary to provide information to SMART-TRIAL. However, some services are only possible if you provide us with certain personal data.
LEGAL BASIS FOR COLLECTING AND PROCESSING
The collection and processing is necessary for;
- the performance of a contract,
- the compliance with legal obligations and applicable law (such as lawful law enforcements requests),
Where the collection and processing is not due to the performance or compliance with a contract or legal obligation, we will obtain your prior consent.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you (except all service specific data, such as SMART-TRIAL user and study data) may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EAA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or process.
We will take all the steps reasonably necessary to ensure that the transfer of your data is compliant with data protection laws and this Policy.
DISCLOSURE OF THE INFORMATION
We may disclose your personal information to third parties;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, subject to their entering into appropriate confidentiality undertakings,
- If SMART-TRIAL or substantially all of its assets are acquired by a third-party, in which case personal data held by us about you may be disclosed to the third-party buyer,
You should not provide us with your information if you do not want your information collected, used or disclosed as described in this Policy.
MINIMIZING THE USE OF INFORMATION
We only collect and process personal data that is necessary. Data that is no longer necessary will be deleted or anonymized.
CORRECTING AND DELETING THE INFORMATION
We rely on you to ensure that your personal data is complete, accurate and current. Please inform us promptly if any changes occur.
On your request, we will change, correct and erase any personal data we hold about you. In most cases, you will be able to make such changes yourself. If we realize that the data is no longer correct, we will change it and notify you. Bear in mind, this only relates to the data that you deliver to us.
We will retain your information as long as we deem it necessary unless legal regulation requires otherwise. When the information is no longer necessary, we will delete or anonymize it in such a way that it cannot be linked back to its origin. We have established procedures for erasing and anonymizing personal data.
For any request regarding correction and erasing please e-mail us at: email@example.com.
Your consent is optional and can at any given time be withdrawn by contacting us at the above contact information. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason (other than consent) for doing so;
CHILDREN UNDER THE AGE OF 18
The services offered by SMART-TRIAL are not intended for children under the age of 18 years. We are however dependent on the users own identification and SMART-TRIAL will assume no liability if the user’s age was not stated properly or at all.
If we learn that we have collected or received personal information from a child under the age of 18 without parental or guardian consent, we will delete that information.
You are entitled to;
- know what data we collect and process about you, where they originate from and the purpose for processing,
- know how long we store the data and who receives the data,
- object to particular ways in which we are processing your personal data (you have the right to ask us not to process your personal data for marketing purposes),
- move data that you deliver to us to a third party (the right to data portability) or receive your personal information in a structured, commonly used and machine-readable format, where this is technically feasible. Please note that this right only applies to personal information which you have provided to us;
- access and inspect information held about you
You can exercise your right at any time by contacting us.
In some cases, we will have an obligation to delete your personal data, for example if you withdraw your consent, and we do not have any other legal ground for processing. Please note, that this only applies to the data that you deliver to us.
If you are a subject or participant in a SMART-TRIAL study/project then you will have to contact the study owner to exercise your rights on data correction, deletion and other information.
If you believe your data is no longer necessary for the purpose of processing you can demand them to be deleted. You can also contact us if you believe your personal data is being processed in violation with current legislation.
We will delete your personal information when it is no longer necessary for the purpose that it was collected for.
If you believe that, we have violated current GDPR legislation you are entitled to submit a complaint to “Datatilsynet”, Borgergade 28, 5. Sal, 1300 København K, tlf.: 33193200 or pr. e-mail: firstname.lastname@example.org.