Effective Date: May 25, 2018

Comprehend Privacy Policy

Comprehend Systems, Inc. Privacy Policy

This Website and Comprehend Services Privacy Policy (“Privacy Policy”) covers “Personal Information” (as defined below) collected by Comprehend on behalf of Comprehend’s Clients, and client systems as well as through the user’s access to and operation of websites owned and operated by or on behalf of Comprehend Systems, Inc. and its subsidiaries (“Comprehend,” “We,” “Us,” and “Our/s”), including Comprehend’s corporate website (https://www.comprehend.com) and data collected through a Client’s use of the Comprehend Services. This Privacy Policy describes how Comprehend collects, uses, and discloses Personal Information from (i) Your access to and use of the Website; and/or (ii) Your access and use of the Comprehend Services as authorized by a Client. The use of Personal Information collected through Your access to the Comprehend Services and/or Platform shall be limited to the purpose of providing the service for which the Client has engaged Comprehend.

Throughout this Privacy Policy “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate customers of Comprehend (“Client”) or a user of the Comprehend Website or services provided by Comprehend (“Services”), such as: name, address, email address, phone number, photograph etc. In addition, if You are a natural person located in any European Union (EU) member country, “Personal Information” includes “personal data” as that term is defined in the EU General Data Protection Regulation (“GDPR”); that is, any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

About Comprehend

Comprehend provides Services and tools that allow Clients 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 Our Clients who use these tools and Services. More specifically, Comprehend does not own the information that is submitted to Us through the Services and tools. The information that is submitted through Client Services relationships will be held subject to the lawful requirements specified by the Clients.

This Privacy Policy does not reflect the privacy practices of Comprehend’s Clients and Comprehend is not responsible for Clients’ privacy policies or practices. Comprehend does not review, comment upon, or monitor Clients’ privacy policies or their compliance with their respective privacy policies, nor does Comprehend review its Clients’ instructions to determine whether they are in compliance or conflict with the terms of a Client’s published privacy policy. Accordingly, We operate as a data processor for Our Clients. Comprehend’s Clients act as data controllers. Comprehend maintains only that Personal Information which Our Clients have asked Us to process.

EU – U.S. Privacy Shield: Transfer of Personal Information

Comprehend participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Comprehend is committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List: https://www.privacyshield.gov/list

Comprehend is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf in accordance with Comprehend’s contractual obligations with its customers.. Comprehend complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Comprehend is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Comprehend may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Processing of EU Data

Comprehend is committed to complying with GDPR with respect to all personal data received from natural persons from European Union (EU) member countries. If You are one of such persons and wish to review or delete your Personal Information obtained through Your access to and use of the Comprehend Website, or take it with You, please email us at privacy@comprehend.com. If You wish to review or delete Your Personal Information obtained through Your access to and use of the Comprehend Services, please contact the Comprehend Client who authorized Your access and use of the Services. To learn more about the GDPR, visit the GDPR Home Page https://www.eugdpr.org/.

Comprehend is responsible for the processing of personal data it receives, under the GDPR, and may subsequently transfer such personal data to a third party acting as an agent on Comprehend’s behalf. Comprehend complies with GDPR for all onward transfers of personal data from the EU.

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, email address, or phone number, to respond to Your inquiries or provide You with requested information.

We also collect information provided by Our Clients to provide Our Services to those Clients. 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 Our Clients and for service-related purposes.

Comprehend collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If You are a customer of one of Our Clients and would no longer like to be contacted by one of Our Clients that use Our Service, please contact the Client that You interact with directly. We may transfer Personal Information to companies that help us provide Our Services. Transfers to subsequent third parties are covered by the commercial agreements with Our Clients.

If a Client adds a user to their business or enterprise account, We will ask the Client for the user’s name and email address. We will automatically send the Client’s user a one-time email inviting him or her to visit a designated site for the collection of business information. Comprehend does not store this information, except to the extent permitted by law, and will only use it for the specific reason for which it was provided. If a person believes that a Client has provided Us with Your personal information and You would like to request that it be removed from Our database, please contact us at Privacy@comprehend.com.

Because of the nature of the Services, Comprehend operates as a data processor for Our Clients. Comprehend’s Clients are the data controllers as to the personal data collected when Comprehend is performing the Services. Individuals involved in clinical studies may interact directly with Comprehend’s Clients rather than with Comprehend. Comprehend maintains only the Personal Information Our Clients have asked Comprehend to process. It is the Comprehend Clients’ responsibility to ensure that the data the Client collects can be legally collected in the country of origin. The Comprehend Client 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 Personal Information collected through the Websites, tools, and Services, and use it for any lawful 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 Comprehend in providing services to Clients. We will share Personal Information for such 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. If You do not want us to share Your Personal Information with these companies, You may contact us at: privacy@comprehend.com.

Comprehend may otherwise disclose Personal Information when:

  • We have express consent to share the Personal Information for a specified purpose;
  • We are required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security, 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 the Services to another provider.
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