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Privacy Policy

 

Last Updated: January 2019

 

Sanguine BioSciences (“Sanguine” “we,” or “us”) has developed this website and mobile app (collectively our “Site”) to facilitate research projects and to help connect patients and researchers seamlessly and conveniently for research studies to advance medical research (our “Services”). We take your privacy very seriously. This privacy policy describes our collection of personal data when you use our Site and our Services. This policy describes our use and disclosure of such personal data, and the steps we take to protect such personal data. “Personal data” means any information relating to an identified or identifiable natural person directly or indirectly, including medical and health-related information. By using our Site and our Services you agree to and consent to the collection and use of your information as described below.

If you do not want us to use your information or your data as stated in this Privacy Policy, please do not use our Site or our Services.

Our Site and our Services are available only to users who can form legally binding contracts under applicable law. By using our Site and our Services you represent and warrant that you are (i) at least eighteen (18) years of age and/or (ii) otherwise recognized as being able to form legally binding contracts under applicable law. If you do not meet these criteria, please do not use our Site or our Services.

 

Information We Collect

When you register for our Services, we ask that you create an account with us.  During that process, we will collect information about you such as your name, age, gender, health information, and contact information (such as your phone number, street address, and email address). Once you have registered with us, and signed our authorization form, we will continue to collect additional information about you, as described in that form, to help researchers evaluate potential research projects and to help us better identify research studies for which you might be eligible and interested.

In addition to the Personal data we collect when you register and use our Services, we automatically collect and store other information about you such as:

  • Information about the device you use to access our Site, such as the type of device you are using to access our Site and Services and the type of browser you are using;
  • Information about your account activity, such as number of times you have logged into your account, your Internet Protocol address (“IP address”), the date and time of your access;
  • Information related to your location;
  • Information about you and your device through cookies, web beacons, and similar technologies. If you access our Site through a web browser, a “cookie” is a small data file sent from a website and stored on your device to identify your device in the future and allow for an enhanced personalized user experience. A “session cookie” disappears after you close your web browser, or may expire after a fixed period of time. A “persistent cookie” remains after you close your web browser and may be accessed every time you use our website. We may use both session and persistent cookies. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to use certain features of our Site. A web beacon is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites or when emails are opened;
  • Information you provide to us when you ask a question or provide us with a comment about our Site or Services;
  • If you agree, we may collect information about you from other sources, such as wearable devices that you own or wear;
  • If you agree, and sign our authorization form, we may collect your medical records from your health care providers on your behalf.

 

How We Use the Information

We may use your contact information, including your email address, to communicate with you for administrative purposes regarding your use of the Site and the Services. We may use your contact information to request additional information from you. We may also use your contact information to communicate with you about a potential research study, to verify information you have provided to us, or to schedule a time to collect a specimen sample from you (if you have consented to that collection). We may use your information for any other purpose that we disclose to you at the time the information is collected, or to which you consent.  We may also use your contact information to communicate with you about topics that may be of interest to you, for example, we may send you educational material related to your health condition, or may provide you with information related to general health topics.

Your participation in any research study is voluntary. You can change your mind and decide not to be in a research study at any time. There will be no penalty to you, and you won’t lose any benefits to which you are already entitled.  As a part of any study you decide to join, you will receive a copy of an informed consent form. If you decide to stop participating in a study, please contact the study staff at the number listed in the informed consent form. If you would like your name to be withdrawn from our contact list for future studies, please contact the study staff at (855) 836-4759. If possible, please make your request in writing and send an email to [email protected].

We use the information that we collect through the Site and our Services to operate, maintain, enhance, and provide all features of our Site and Services. We also use the information to provide services to respond to comments and questions for user support.

We may de-identify and aggregate your information and use and share that information as described below.

We use standard log files and other automatically-collected usage data that is essential for the Site to function effectively, including to: (i) monitor and analyze the Site; and (ii) monitor aggregate Site usage metrics.

 

How We Share the Information

We may work with business partners in making our Site and Services available to you. Our policy is to require companies with whom we do business to support the same privacy policies we do. These parties are not allowed to use Personal data except for the purpose of providing their services to us.

We may share your information with a research site, if you have accepted this Privacy Policy and the Terms of Use, so that you can be considered by that site for a clinical research study.

To the extent permitted by applicable law, we may disclose your information if required to do so by law to comply with state and federal or other relevant laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Site and Services and any facilities or equipment used to make our Site and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

Information may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, to the extent and in the way as prescribed by applicable law.

 

De-identified and Aggregate Information

We may use your information to create de-identified data. De-identified data is information that has all of the identifying information removed from it.

Aggregate information is information that describes the habits, usage patterns and/or demographics of users as a group but does not reveal the identity of particular users. We may use aggregate information within Sanguine to understand the needs of individuals using our Site and Services

 

Do Not Track

For web browser use, you may set your browser to refuse these data collection methods, but we may not recognize or respond to “do not track” technologies employed by your browser. We do not track App users over time and across third party websites or online services to provide targeted advertising, and we do not specifically respond to Do Not Track (“DNT”) signals.

 

Storage of Information Collected

Information may be stored or processed in locations other than the jurisdiction in which you live or work. In such cases we will work to ensure that any vendor we use in that location has the appropriate protections in place. By using our Site and Services, you agree to the collection, storage, and processing of your information to any country in which we may conduct our business operations.

 

Data Security

Sanguine uses appropriate physical, managerial, and technical safeguards that are designed to protect the confidentiality, integrity and security of personal data that we collect and maintain against accidental or unlawful loss, theft and misuse and unauthorized access, disclosure, alteration destruction, or any other type of unlawful processing. Unfortunately, no web site, server or database is completely secure. Sanguine cannot guarantee that your Personal data will not be disclosed, misused or lost by accident or by the unauthorized acts of others.

 

Analytic Tools

We use tools, such as those provided by Google Analytics and FaceBook to help analyze how users use the Site. These analytic tools collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get to improve our Site and Services.

 

Third Party Links

If you are directed to a third party’s website through a link on our Site that third party’s website may collect information about you when you view or click on its website. Sanguine has no control over this collection of information. You should contact the content provider directly if you have any questions about its use of the information collected. The website and services may have their own privacy policies, or no policy at all. We encourage you to review the privacy policies of any third party websites or services before providing any of them with your personal information.

 

California Shine the Light Law

If you are a California resident, California Civil Code Section 1798.83, known as the “Shine the Light” law, permits individuals who are California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We will never disclose your personal information to third parties for direct marketing purposes without your authorization. However, if you would like to make a request for information under the Shine The Light law, please contact us by email at [email protected].  Requests may be made only once a year and are free of charge.

 

Changes to Our Privacy Policy

Sanguine reserves the right to change this Privacy Statement, and when updated, the effective date of the new version will be at the top of this statement.  By continuing to use our Site and our Services you agree to and consent to the collection and use of your information as described above.

 

Governing Law

This Privacy Policy is governed by and incorporated by reference into the Terms of Service and should be interpreted in a manner consistent with that terms of use. Where an inconsistency exists between this Privacy Policy and the Terms of Use, this Privacy Policy shall control the relationship between the parties. If you believe we have violated this Privacy Policy, please contact us at [email protected].

 

Contact

If you have any questions, comments or requests regarding this Privacy Policy or our processing of your information, please contact: [email protected].