Effective Date: January 16, 2014
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.
Comprehend provides its customers with services and tools that allow them to analyze and report on clinical data pulled from multiple, disparate data sources through a single interface. These tools and services are not a part of our corporate website. Comprehend serves as a data processor for the customers who use these tools and services. More specifically, Comprehend does not own the information that is submitted to us through our services and tools. The information that is submitted through our client services relationships will be held subject to the requirements specified by our customers.
Safe Harbor Certification and Processing of EU Data
Comprehend complies with the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks and adheres to the Safe Harbor privacy principles relating to data protection. Information on both Safe Harbors may be found at http://www.export.gov/safeharbor/.
Collection and Use of Personal Information Through Comprehend Client Services and Website
You may visit the websites of Comprehend without revealing any Personal Information. However, in some instances, Comprehend may require certain Personal Information, such as business contact information, to respond to your inquiries or provide you with requested information.
We also collect information provided by our customers to provide services to those customers. This information may include Personal Information about individuals, including health information collected as part of clinical trials. Comprehend will use this information as directed by its customers and for internal and service-related purposes.
Because of the nature of its services, Comprehend operates as a data processor for its customers. Comprehend’s customers act as data controllers. Individuals involved in clinical studies may interact directly with Comprehend’s customers rather than with Comprehend. Comprehend maintains only that Personal Information its customers have asked Comprehend to process. It is the Comprehend customer’s responsibility to ensure that the data the customer collects can be legally collected in the country of origin. The Comprehend customer is responsible for giving its employees and customers the appropriate level of notification that Personal Information is being collected and maintained.
We may anonymize and aggregate data collected through the website, tools, and services, and use it for any purpose.
Comprehend may automatically receive and record certain non-Personal Information from website users and the users of its tools and services. Comprehend may use this information to provide certain functionality, improve the tools and services, and monitor the use of the tools and services.
Information Sharing and Disclosure
Comprehend may disclose Personal Information to its agents and partners who assist the Company in providing services to customers. We will share Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information.
Comprehend may otherwise disclose Personal Information when:
- we have express consent to share the information for a specified purpose;
- required in response to subpoenas, court orders, law enforcement requests, or such other legal process;
- we need to protect the personal safety of the users of our systems or defend the rights or property of Comprehend; or
- we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider.
We are a global corporation with operations in several countries. We have developed global data practices designed to assure Personal Information is appropriately protected. While our primary data centers are in the United States, we may transfer Personal Information to Comprehend offices outside of the United States now or in the future. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to Comprehend employees outside of the United States, we will ensure that such party has agreed to abide by the Safe Harbor principles, or can otherwise assure adequate protection of such Personal Information.
Comprehend’s collection, use, and disclosure of information is generally governed by service agreements with our business customers. Information relied upon to provide these services to our business customers is retained only for as long as we have a valid business purpose and in accordance with applicable law.
In most cases, when Comprehend obtains Personal Information, it does so on behalf of another company (as an agent or data processor). To request access to, correction, amendment, or deletion of this Personal Information, a customer or end user should contact the company to which the data was provided. For other inquiries, please contact us at firstname.lastname@example.org.
Any questions, comments, or complaints about the data practices of a customer for which Comprehend processes data should be directed to that customer (including, without limitation, compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement), although Comprehend will make reasonable efforts to comply or assist with such requests. If Comprehend and its customers are unable to resolve your complaint, Comprehend has agreed to cooperate with the European Union data protection authorities to resolve any privacy complaints related to Personal Information.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we take steps to ensure security on our systems. Please note this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such safeguards.
Comprehend has adopted appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Information we process. Comprehend strives to protect the privacy of the Personal Information it processes, and to avoid inadvertent disclosure.
If Comprehend learns of a security system’s breach, Comprehend maintains an incident response policy that includes notifications consistent with applicable law.
By using this website or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this website.
Changes and Updates
Postal Mail Address:2010 Broadway St. Suite 200
Redwood City, CA 94063
We can be reached via e-mail at email@example.com or you can reach us by telephone at (650)521-5449.