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Global Privacy Statement 

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Introduction  

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NLCR (“NLCR” or “We”) respects the privacy of all individuals whose personal data we process in the performance of our business operations (“Personal Data”) and are committed to protecting it through our compliance with this Global Privacy Policy. 

This Global Privacy Statement describes the types of information we may collect from our clients, personnel, clinical trial participants, patients, investigator site personnel, healthcare providers, service providers, suppliers, and business partners and our practices for collecting, using, maintaining, protecting, and disclosing that information.  Together with additional implementing practices, this Global Privacy Statement supports NLCR’s compliance with applicable international privacy laws and regulations. 

This Global Privacy Statement supplements our Privacy Shield Policy. 

Scope: 

This Global Privacy Statement applies to all Personal Data collected by or on behalf of NLCR, including information collected while using NLCR websites and mobile applications, that relates to our clients, personnel, clinical trial participants, patients, investigator site personnel, healthcare providers, service providers, suppliers, and business partners.  This Global Privacy Statement supplements NLCR's Online Privacy Statement. 

The lawfulness of Processing:  In general, NLCR uses Personal Data for its legitimate interests in compliance with applicable law and regulation.  In certain situations, NLCR may rely on alternative lawful bases for using your Personal Data in specific situations.  In such cases, you will be notified with additional information on the lawful use of your Personal Data (see “Effect of Other Notices” below). 

Personal Data Collected, Purposes, and Use: 

  • Clinical Trial Related Personal Data:  Personal Data may be collected from clients, personnel, clinical study participants (including patients, spouses, caregivers, and legal guardians), investigator site personnel, healthcare providers, service providers, suppliers, and business partners for NLCR to carry out business, operational, and safety activities related to a clinical trial or research study.  Such Personal Data may be disclosed to other entities participating in the study, including the sponsor of the study, investigative sites, and third-party services providers and suppliers. 

  • Human Resources Personal Data:  Personal Data may be collected from job applicants, actual or past employees, consultants, or independent contractors, in order to fulfill our Human Resources (HR) functions and administer potential, past, or current employment with NLCR.   Such Personal Data may be disclosed to Worldwide’s agents providing recruitment or employment services on our behalf. 

  • Business Contact Personal Data:  Personal Data may be collected from clients, service providers, suppliers, and business partners in order to discuss prospective business opportunities, Worldwide’s service offerings, or provide customer support. 

  • Prospective Study Participant Personal Data:  Personal Data may be collected from prospective study participants, including patients or healthy volunteers, in order to determine interest or eligibility to participate in a clinical research study.  Such Personal Data may be disclosed to other entities participating in prospective studies, including the sponsor of the study, investigative sites, and third-party services providers and suppliers. 

  • Web Visitor Personal Data:  NLCR collects Personal Data from website visitors and mobile app users in accordance with, and for the purposes described in our Online Privacy Statement. 

Sensitive Personal Data: 

NLCR may collect and use sensitive Personal Data including government-issued ID numbers (including social security, driver's license, and passport numbers) financial account information, reports of individual background information, and information relating to a criminal offense.  Worldwide may also process Personal Data pertaining to race, ethnic origin, political opinions, sexual orientation, sex life, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, or that concerns medical or health conditions or sex life.  Worldwide shall only collect and use sensitive Personal Data where permitted, and subject to heightened restrictions, under applicable law (and only after obtaining your explicit consent or authorization where so required) and where we have provided you with specific notice of such processing.  For more information on privacy notices see “Notice” and “Effect of Other Notices”.

Privacy Principles

The following sets forth the privacy principles that Worldwide follows with respect to Personal Data we globally collect use and disclose. 

  • Notice: NLCR informs individuals in accordance with applicable law, regulation or policy, about the purposes for which we collect and uses Personal Data about them, the people or types of people who will have access to it, including the types of non-agent third parties to which Worldwide discloses that information, and the choices and means, if any, NLCR offers individuals for limiting the use and disclosure of Personal Data.  Where NLCR is processing Personal Data as a data processor (for example, as a CRO on behalf of client or sponsor), we will only use your Personal Data according to the privacy notices and instructions issued by those entities.  For more information on privacy notices see “Effect of Other Notices”. 

  • Choice: NLCR secures, when required by applicable law, regulation or policy, the consent of the individual to the collection, use, or disclosure of their Personal Data. NLCR endeavors to offer individuals the opportunity to choose whether Personal Data about them is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, or (c) to continue to be used for certain types of ongoing processing, such as ongoing commercial e-mail, facsimile, telemarketing, or direct mail communications.  Where NLCR is processing Personal Data on behalf of a data controller (for example, as a CRO on behalf of client or sponsor), NLCR will act according to the instructions of and contractual terms in place with the controller to support the data controller’s obligations under the Choice principle. 

  • Accountability for Onward transfer:

    • Agents/Service Providers:  NLCR may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf.  We take reasonable and appropriate steps, including the execution of written contracts, to require third-party agents and service providers to process Personal Data in accordance with applicable law and the principles contained in this Global Privacy Statement and to stop and remediate any unauthorized processing. 

    • Third-Party Controllers:  In some cases, we may transfer Personal Data to unaffiliated third-party data controllers, including clients sponsors of clinical trials for commercial and research purposes. These third parties do not act as agents or service providers and are not performing functions on our behalf.  We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide adequate levels of data protection in accordance with applicable law.

In addition, NLCR may share Personal Data with third parties if:  

    1. NLCR sells or buys any business or assets, in which case NLCR may disclose a limited amount of Personal Data to the prospective seller or buyer of such business or assets;  

    2. if NLCR or substantially all of Worldwide’s assets are acquired by a third party, in which case Personal Data NLCR holds may be one of the transferred assets; or  

    3. if NLCR is under a duty to disclose or share Personal Data to comply with any legal obligation as required by law or in response to a request from a regulatory or enforcement authority, to enforce any contract with individuals to which the Personal Data relates, or to protect NLCR’s rights, property, or safety of NLCR’s employees, clients, or others.

NLCR shall only carry out international transfers of Personal Data within or outside of NLCR or its group of affiliated companies and agents where we have implemented reasonable, adequate protection for such information in compliance with applicable laws.  For additional information on transfers made subject to the EU-US  Privacy Shield please refer to  Privacy Shield Policy.

  • Security: NLCR implements appropriate administrative, physical, and technical safeguards to protect Personal Data in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. NLCR evaluates any potential security incident/personal data breach and reports any unauthorized disclosure of Personal Data as required by and in accordance with applicable laws.  

  • Data Use, Integrity & Retention: NLCR uses Personal Data only in ways that are compatible with the legitimate business purposes for which it was collected or subsequently authorized by the individual. Worldwide ensures that Personal Data is accurate, complete, and relevant to its intended use. Worldwide checks the accuracy of any Personal Data at the point of collection and at regular intervals afterward. Worldwide takes all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.  Where NLCR is processing Personal Data on behalf of a data controller (for example, as a CRO on behalf of client or sponsor), Worldwide will act according to the instructions of and contractual terms in place with the data controller to support the data controller’s obligations under the Data Use, Integrity & Retention principle. 

  • Purpose Limitation: NLCR collects, uses, and discloses Personal Data only in such manner as is necessary for its business purposes, and for no other purposes, and retains the information in identifiable form only as long as necessary and / or in accordance with retention periods identified in specific privacy notices. NLCR uses best efforts to procure that clinical sites send any Personal Data relating to patients to NLCR in a de-identified form wherever possible, and were not possible, to procure that the clinical sites obtain the explicit consent of the relevant patients to send their Personal Data to NLCR in identifiable form. Where NLCR is processing Personal Data on behalf of a data controller (for example, as a CRO on behalf of client or sponsor), NLCR will act according to the instructions of and contractual terms in place with the data controller to support the data controller’s obligations under the Purpose Limitation principle. 

  • Access: NLCR processes all Personal Data in line with individuals’ rights, such as, in accordance with applicable laws, by granting individuals reasonable access to Personal Data that NLCR holds about them, and enabling them to question, correct, amend or delete their Personal Data. Where permissible by law, NLCR may charge a fee for access or apply exemptions to withhold information if it deems appropriate. Where NLCR is processing Personal Data on behalf of a data controller (for example, as a CRO on behalf of client or sponsor), NLCR will act on the instructions of the data controller and assist the data controller in responding to any access requests.  Employees and any other individuals should submit any questions or comments regarding this Global Privacy Statement or any Personal Data that NLCR holds about them to:

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New Life Clinical Research 

Attention: Global Data Protection Officer

5901 NW 151TH ST #122, MIAMI LAKES, FL 33014, USA


It is our policy to post any changes we make to our Global Privacy Statement on this page.  The date the Global Privacy Statement was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes. 

 

Effective Date: 07April2020 

Last modified: 17May2022

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