Privacy Policy

Dated May 10, 2021

 

Thank you for visiting the Solutions for Celiac Website (“Website”). The Solutions for Celiac study (“the Study”) is a clinical trial being sponsored by ImmunogenX, Inc. (“Sponsor,” “We,” “Us”), a company based in the United States of America (“USA”). 

 

This Website’s purpose is to provide information about the study to you, provide a digital platform to evaluate your eligibility for the Study, and help the Sponsor enroll qualified patients into the Study. 

 

The Website is intended for users over the age of 18 in the US. 
 

Scope and Purpose of this Policy

 

This privacy policy (“Policy”) applies to the processing of your personal data by the Sponsor and third party vendors through the Website or other situations and interactions you have with us. This Policy explains:

  • What personal data we collect

  • Your rights to your personal data

  • What providers are involved in processing your personal data

The information we collect is solely used to evaluate your eligibility for the Study, help the Sponsor enroll qualified patients in the Study, and is never sold to third party vendors.
 

Information Collected

  • Personal information you provide to us
    Personal data is information that can be used to identify you as an individual. We explicitly collect the following to determine your eligibility for the Study and to contact you after you submit the pre-screener or an inquiry with us:

  • Contact information (e.g., name, address, phone number, email address)

  • Gender

  • Health information related to study eligibility criteria

  • Any additional information you submit to us

  • Automatically Collected Personal Information
    When you access and use the Website, we will automatically collect certain technical information about your equipment, browsing actions and patterns. Cookies and other related technologies are used to collect this technical personal information. The technical information collected include:
     

    • Internet Protocol (IP) address of computer being used 

    • web pages requested 

    • referring web page 

    • browser used 

    • date and time
       

Our Website does not associate this data to individual user identities and is not sold to other parties.

  • Personal information received from third parties
    Occasionally, we may receive personal data from third parties, including research centers, clinical trial recruitment service providers, and patient advocacy groups, that support Study enrollment or management.
     

How We Use The Information Collected

  • Clinical Trial Recruitment
    When you submit the Pre-screener, submit other forms on the Website, or contact us via phone or email, we collect and store your personal data to help us determine if you are potentially eligible for the Study, provide you with information about the Study, or put you on a list for future contact (with your consent).

    By submitting the Pre-screener, submitting forms, or contacting us, you consent to providing the information in those forms or communications to us. 

    When you have been identified as a qualified candidate for the Study, your personal data and contact information is shared with one of the clinical sites conducting the study (typically the closest one to you).
     

  • Clinical Trial Management
    Access to documents, databases and folders containing personal data is restricted to appropriate staff on a  “need to know” basis to meet stated legitimate business purposes.

    De-identified reports and summaries of Website visitors and Pre-screener submissions are periodically prepared and provided to the Sponsor for conduct and review of Study progress. “De-identified” means these reports and summaries do not include any identifiable information (e.g., name, contact information) about you. 
     

  • Business Administration and Legal Compliance
    Under rare certain circumstances, we may be required by law enforcement, judicial authorities, or regulatory authorities to disclose certain personal information as part of audits, investigations or for litigation purposes. We may disclose personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of the Sponsor company or parts of the company.
     

  • Personal Information that You Provide to Us
    When you submit personal data through the Pre-screener, Contact Form, other forms on our Website, or by direct communication (e.g., email, phone, in-person), we will store your contact information and submitted personal data in order to respond to you regarding the subject of your inquiry. We may also take and store notes from communications with you in order to assess your eligibility for the Study. If you are eligible for the Study, we share your personal information with a matching research center to complete enrollment.
     

  • Automatically Collected Personal Information
    When you visit our Website, information is collected about you automatically using cookies, web beacons and other similar technologies. Cookies are pieces of code that are placed on your device for the purposes of delivering web content specific to individual users' interests and tracking website interactions. We use this information to analyse and improve the performance of advertising campaigns, the website design, and the website content.  This information will also help us better understand our Website visitors.  IP address information may also be used for troubleshooting purposes.

    Sensitive personal information is not stored within cookies. Cookie providers include Wix, Google Analytics, and Facebook. We encourage you to visit these providers’ websites for more information on their cookie policies, privacy practices, and terms of use.

    If you wish to customize what cookies are activated when you interact with our Website, you can review your Internet Browser’s settings and allow, disable, or delete certain cookies. However, doing so may interrupt access or use of important functions or features of the Website.
     

  • Personal Information Received from Third Parties
    Personal information received from third parties will typically have been collected with your consent by the third party before providing to us. Uses are similar to uses under “Personal Information that You Provide to Us.”
     

Third-Party Vendors

  • Website Hosting
    This Website is hosted on the Wix.com platform. Your personal information may be stored through Wix.com’s data storage, databases, and other Wix.com applications. Wix stores data on secure servers behind a firewall. Please visit Wix.com to understand how Wix processes your data: About Privacy | WIX
     

  • Google Analytics
    We use Google Analytics, Google Tags, and other marketing tools provided by Google to track and analyze advertising campaigns and Website traffic. We may also use Google to remarket our Website with you. Re-marketing delivers ads related to a Website you have visited based on certain Website activity you have taken. Please visit Google to understand how it collects and processes your data: 
     


If you wish to opt out of Google’s remarketing cookies, please visit the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page.

 

  • Facebook Pixel
    We use Facebook to advertise on social media. Facebook provides a snippet of code called a “pixel” that is used to track conversions from Facebook ads, optimize ads, build targeted audiences for future ads, and remarket to people who have taken some kind of action on our Website. Facebook ads are delivered on Facebook, Instagram, Messenger, and through their Audience Network. For information on what data the pixel collects, how its used and processed, please visit: https://pixel.facebook.com/about/privacy/ 
     

  • intakeQ
    intakeQ is a clinic patient management platform hosted in the cloud. intakeQ is based in Ontario, Canada. We use intakeQ to administer the Pre-screener and store personal information relevant to Study qualifications. intakeQ is HIPAA compliant and employs strict security measures to protect client and patient personal, health, and business information. For their privacy policies, please visit: IntakeQ - Privacy

  • Visitor Analytics
    Visitor Analytics is a simple website analytics service which measures the traffic on our website and website visitors' general details. We collect statistics like which pages visitors visit and when, where they are approximately located, where they land first or if they are coming from a specific referral, to make our website visitors' experience better .

    As a website operator using Visitor Analytics, we process information about our visitors' device type and screen size/resolution, approximate location, browser, OS, page visits, bounce rate, conversions, conversion funnels, average sessions per visitor, average pages per session, average session duration, time spent on the website and preferably visited content on the website. All this data is pseudonymized and Visitor Analytics will not use the collected data to identify individual users or to match the data with additional information on an individual user.

    Visitor Analytics does not use cookies to collect this data. Instead, so-called fingerprinting technology is used that does not require placing any cookies, files or technology on your device. Fingerprinting relies on your device’s technical attributes and combines them to identify your device as a unique device and allow for reliable analytics.

    Visitor Recordings is an additional feature to Visitor Analytics (described above) in the form of a simple website replay tool that records in statistics where our website visitors scrolled to and what they clicked on our website. We can see this information in playbacks and so called “heatmaps”. Collecting these statistics helps us to make the Website more user-friendly as well as to reproduce and fix technical errors.

    Basically, as a website operator using Visitor Recordings, we are using a snippet of tracking code to collect data about our visitors’ journey on the Website, which subpages they visit, what they clicked on, where they moved their mouse cursor to and where they scrolled. All this data is pseudonymized and Visitor Analytics will not use the collected data to identify individual users or to match it with additional information on an individual user.

    For more information, including how to opt-out of Visitor Analytis tracking, please visit: Visitor Analytics App Privacy Policy.
     

Distribution of Collected Information

Our Website will not disclose, without your consent, personal information collected about you, except for the uses stated above or in certain explicit circumstances in which disclosure is required by law.

Our Website and the Sponsor will not distribute or sell personal information to third-party organizations. 
 

International Transfers of Personal Information

This Study is intended for US participants. We do not knowingly collect information from individuals located outside of the US. 

The Sponsor may work with vendors or collaborators located in different states, provinces, countries or other governmental jurisdictions than where you reside. Personal information may be shared across state lines and international borders as required to service the Study and Website.  In certain circumstances, the Study data and client personal information will be hosted within vendor platforms located in the Internet cloud. Data protection laws may differ in areas outside your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Sponsor and third-party vendors will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
 

Children’s Online Privacy Protection

We do not knowingly collect information from children under the age of 13. This Website is intended for users over the age of 18.
 

Access and Modification of Personal Information

At any time, you may request access to the personal information about you that we have stored. We will provide you with a reasonable opportunity to correct, add, or delete personal information about you if it is inaccurate.

We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, where the rights of third persons would be violated, or overall Study integrity is threatened.

To request, edit, delete, or opt out of personal information collection, you may send a request to info@solutionsforceliac.com. We will process your request within a reasonable time after receipt.
 

Responsibility for External Sites

This Website may contain links to other web sites. Some of those web sites may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of web sites operated by others. 


We are not responsible for the performance of web sites operated by third parties or for your business dealings with them. Therefore, whenever you leave this web site we recommend that you review each web site's privacy practices and make your own conclusions regarding the adequacy of these practices.
 

Confidentiality, Security, and Retention of Your Personal Information

We take confidentiality and security seriously. We take reasonable and appropriate measures to keep the personal information collected about you secure. Only designated/authorized Study team members or third party vendors who need the information to process a specific request are granted access to personally identifiable information.

Access to software and online platforms used to run the Study is limited to designated Study team members. Personal information is protected through Study personnel training, sophisticated software and hardware, and passwords. 

We retain your personal information throughout the Study and for only as long as necessary for the purposes described in this Policy, after which we will delete such personal information from our systems and databases, unless you have authorized us to retain your information for future contact.

Changes to Privacy Policy

We may change this Privacy Policy at any time and for any reason. The date this Policy was last updated is noted at the top. We encourage you to review this Privacy Policy periodically to remain informed.
 

How to Contact Us
If you have questions, complaints, data requests, or related privacy concerns, you may contact us at: info@solutionsforceliac.com