Privacy policy

EVRIMA TECHNOLOGIES PTY LIMITED – PRIVACY POLICY

Evrima Technologies Pty Limited ABN 78 631 919 698 (we, us or our), understands that protecting your personal information is important. We are the owner, operator and licensor of the website at www.evrima.com (Website). This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our Website and patient recruitment services (Services) to you or when otherwise interacting with you. 

This Privacy Policy takes into account the requirements of the: 

- Australian Privacy Act 1988 (Cth);
- Australian Privacy Principles; 
- New Zealand Privacy Act 2020; and 
- New Zealand Health Information Privacy Code 2020.

The information we collect

Personal information: is information (and in Australia includes an opinion), whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. This includes personal information provided by you directly (whether face-to-face, by telephone, email, online forms, post, through social media or by communicating with us in any way), when you make an enquiry through our Website or over the phone or when you communicate with us during an appointment, you are voluntarily giving us the personal information that we collect.

Why we collect, hold, use and disclose personal information

The types of personal information we may collect about you include:

Candidate

If you are contacting us to participate in a clinical trial or want information about clinical trials (Candidate) then we may collect the following personal information:

• your name; 
• your date of birth; 
• your contact details (including email address, street address and your telephone number);
• your driver’s license, Medicare card and/or other identifying documentation; 
• your sensitive information as defined below including health information or biometric information from documents or images you upload when interacting with our Website or Services;
• personal preferences, interests and behaviours;
• details of services that we have provided to you and/or that you have enquired about and our response to you; 
• support requests submitted to us and our response to you; 
• your location and movements, personal preferences, interests and behaviours; and
• any feedback that you may have provided in relation to our Services. 

Client

If you are contacting us as a researcher or as the host or sponsor of a clinical trial (including on behalf of a contract research organisation) (Client) then we may collect the following personal information:

• • your name; 
  • your contact details (including email address, street address and your telephone number);
  • the name and contact detail of the organisation or company that you work for; 
  • business affairs and study parameters required for us to provide you with the Services; 
  • any feedback that you may have provided in relation to our Services; 
  • details of services that we have provided to you and/or that you have enquired about and our response to you; 
  • support requests submitted to us and our response to you; and

• financial or credit card information. 

When you visit our Website:

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information about your access, your browsing activity, and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; 
• we may collect statistical (non-personal) information about your use of the Website and our Services to improve the features and overall user experience. This may include statistical information such as pages accessed on the Website and the Service, search terms, links that are clicked on, Website and Service visit times, browsers and operating systems, IP address, and cookies; and
• any other personal information requested by us and/or provided by you or a third party.

When you sign up to receive marketing emails from us

If you sign up to receive emails from us, we may collect:

• your name;
• your email address; 
• your interests; and
• your marketing preferences. 

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. 

Sensitive information (Candidate): The types of sensitive information (and health information for the purposes of the New Zealand Health Information Privacy Code 2020) we may collect about you include:

• your medical history including health data, test results, survey results, physical traits and physiological information; 
• genetic traits and specific genetic information; 
• mental traits; 
• economic identity; 
• cultural identity; 
• social identity; and
• any other sensitive information you provide to us. 

Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for an account or for a clinical trial, during an appointment, through the ‘contact us’ form on our Website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our Website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our Website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Why we collect, hold, use and disclose personal information

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

• to enable you to access and use our Services, including to provide you with a login;
• to verify your identity; 
• to provide our Services to you, including matching Candidates with clinical trials; 
• to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms;
• for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
• to comply with our legal and regulatory obligations and resolve any disputes that we may have; and
• if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

• any purposes you consent to;
• the primary purpose for which it is collected, including to enable us to provide the Services by matching Candidates and recruiting Candidates for clinical trials;
• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you; 
• to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and
• if otherwise required or authorised by law. 

Our disclosures of personal information to third parties

We may disclose personal information to:

IT service providers, data storage, web-hosting and server providers;
our employees, contractors and/or related entities;
our existing or potential agents or business partners;
sponsors or organisations responsible for the clinical trials;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses); and
any other third parties as required or permitted by law, such as where we receive a subpoena.
Where you are a Candidate, we may disclose your personal information to:

our Clients when we have matched you to a clinical trial; and
third parties for medical research purposes. 
We limit the information we provide to Clients and third parties to the information they require in order to perform clinical trials or medical research. We will only disclose your personal information to Clients and third parties that are required by law to meet the same privacy standards that are applicable to us. 

Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. 

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here.  To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device. 

Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

If you are located in Australia 

Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

If you are located in New Zealand

Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if: 

• you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the New Zealand Privacy Act 2020; 
• we believe the overseas recipient is subject to the New Zealand Privacy Act 2020; 
• we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the New Zealand Privacy Act 2020; 
• we believe that the overseas recipient is a participant in a prescribed binding scheme; 
• we believe that the overseas recipient is subject to privacy laws in a prescribed country; or 
• we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the New Zealand Privacy Act 2020 (for example, pursuant to a data transfer agreement entered into between us and the overseas recipient).
  

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services. If you do not agree with this Privacy Policy, please discontinue the use of our Services. 

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us. 

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner (if you are in Australia) or the Office of the New Zealand Privacy Commissioner (if you are in New Zealand). 

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. We restrict access to personal information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices.

We commit to the record and reports retention requirements in the ICH Guideline for Good Clinical Practice (the Guidelines). The Guidelines are an internationally accepted standard for the designing, conducting, recording and reporting of clinical trials. The Guidelines are incorporated by reference in the Therapeutic Goods Regulations 1990 in Australia and the Guideline on the Regulation of Therapeutic Products in New Zealand Part 11: Clinical Trials – regulatory approval and good clinical practice requirements in New Zealand. Compliance with the Guideline is a condition of approval for the conduct of a clinical trial.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. 

In case of a security incident or any other breach of security safeguards, such as unauthorised disclosure of personal information under our control, we will respond in accordance with applicable data protection laws.

Cookies

We may use cookies on our Website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

Our Website does not currently recognize Do Not Track (DNT) signals sent by our users’ web browsers.

Links to other websites

Our Website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Website. We recommend you check our Website regularly to ensure you are aware of our current Privacy Policy. Your continued use of our Services will indicate your acceptance of any amendments to this Privacy Policy. 

For any questions or notices, please contact us at:

Australia 
Evrima Technologies Pty Limited ABN 78 631 919 698 

Email: enquiries@evrima.com.au

Last update: 9 May 2023

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