Privacy Policy

Please read this privacy policy (“Privacy Policy”) carefully because it outlines our practices for collection, use, and disclosure of your information that you provide to us and when you use our Websites. This privacy policy also describes your choices regarding the use access, and correction of your personal information.

Clinithink Limited (the “Company,” “we,” or “us”) will be what’s known as the ‘Controller’ of the personal data you provide to us. We understand the importance of maintaining the confidentiality and security of your information and seek to secure your privacy during your visit to our websites that include, but are not limited to, https://clinithink.com, https://exchange.clinithink.com,   https://training.clinithink.com, https://clinithink.assist.com/portal, https://ftp.clinithink.com:9443 and https://clixnotes.clinithink.com and any other sites, owned or operated by us, that post a link to this Privacy Policy (collectively, our “Websites”).

We process the information you provide to us on the basis of the usage set out in this policy and agreed to by you. By clicking “I Agree” you agree to the procedures and practices discussed in this Privacy Policy. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices

Collection of Your Personal Data

Throughout this Privacy Policy, we use several specialized terms. When we use the term “Personal Data” in this Privacy Policy, we mean information relating to an identified or identifiable natural personal, like your name, postal address, e-mail address, IP address or telephone number. We use the term “aggregate” when we combine information from various persons or users.

We collect your information to give you convenient access to our Websites’ features, to verify your identity in our interactions with you, to personalize your experience on the Websites, and for customer service purposes. Your information also helps us keep you posted on status updates and service reminders.  If you contacted us through https://clinithink.com or registered for access to https://clixnotes.clinithink.com we may also contact you about offers that may interest you.

Access

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by sending a detailed email to privacy@clinithink.com. We will respond to your request within a reasonable timeframe.

If you use the Websites to transform clinical narrative (“NL Medical Data” see definition here) then we may use, copy and/or modify any NL Medical Data to support product improvement and utilization analysis.

The use of information collected through our service shall be limited to the purpose of providing the service for which the customer or partner has engaged Clinithink.
Clinithink predominantly collects information under the direction of its customers and partners and therefore has limited direct relationship with the individuals whose personal data it processes. If you are a customer of one of our customers or partners and would no longer like to be contacted by one of our customers or partners that use our service, please contact that customer or partner that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers and partners.

Clinithink acknowledges that you have the right to access your personal information. An individual who seeks access to correct, amend, or delete inaccurate data should initially direct their query to Clinithink’s customer or partner (the data controller).  If you have engaged Clinithink personally through our Websites then we will support your access to correct, amend, or delete inaccurate data.  Please contact us using the details at the end of this policy.  If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Clinithink will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Passive Collection

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, web browser type, internet service provider (ISP), referring or exit pages, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, and date and time stamps, and/or clickstream data to analyse trends in the aggregate and administer the site.

We automatically and store it in our logs.  We will hold this data in line with our data retention policy for 7 years.   After this time we will use reasonable efforts to delete this data.

Tracking Technologies

Clinithink and its partners use cookies or similar technologies to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

We use cookies and technical information:

  • to provide you with a more customized experience on our Websites and provide you greater convenience each time you interact with us,
  • to help us understand which parts of our Websites are the most popular and how much time our users spend in each,
  • to measure the effectiveness of our customer communications and the searches performed on our Websites,
  • to administer our Websites,
  • to study traffic patterns and trends on our Websites, and
  • to study aggregate demographic information about our users as a whole.

We use cookies  so that CLiX ENRICH and Clinithink Exchange can operate efficiently without the need for you to re-enter your access credentials with every interaction. These cookies are used only during the individual session and are not stored permanently.  This cookie is a session cookie used to store authentication state within Clinithink Exchange. An active Clinithink Exchange session needs to be running when any instance of CLiX ENRICH is running, so this cookie will be present when using Clinithink Exchange or CLiX ENRICH. This cookie will be cleared when the session is closed or when the user logs out.

Our Use, Disclosure and Retention of Your Information

Unless we say otherwise when collecting such information, we will use any Personal Data that you provide to us in accordance with the terms of this Privacy Policy. We will collect, process, use, and store your Personal Data only for the purposes we describe to you in this Privacy Policy or elsewhere on our Websites. We may disclose Personal Data that you provide to the following categories of recipients, as described in greater detail below: parties you authorize to receive it; service providers, agents & marketing partners working on behalf of Clinithink; law enforcement; attorneys; regulators; auditors and advisors to Clinithink, affiliates of Clinithink or other entities as required and permitted by law.

Except as set forth in this Privacy Policy, we will not use, disclose, or transfer your information unless (1) you expressly authorize us to do so; (2) it is necessary to allow our service providers or agents to provide services for us, (3) it is necessary in order to provide our products or services to you (and contacting you when necessary), (4) we are sending you other Clinithink relevant information that may be useful to you and that you have agreed to, (5) subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (6) it is necessary to protect the confidentiality or security of your records, (7) subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of the Company or the merger of the Company into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which the Company is not the survivor, (8) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer preferences and trends and dispute resolution, (9) it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity; (10) it is necessary for us to provide it to our attorneys, regulators, auditors or other advisors; or (11) it is otherwise necessary for us to disclose it as required or permitted by law.

We may combine information we collect about you from our Websites with information we obtain about you from other sources, including aggregate data from third parties. We may also aggregate personal and other information about you or NL Medical Data that you submit to our Websites with information about and NL Medical Data from our other customers or partners. We may also employ third party service providers to place and administer such cookies and web beacons on our Websites. Such third parties may also collect your information and perform website analytics as described in this Privacy Policy. We may reproduce work product created by such third parties based upon web analytics data or other similar data collected from visitors to our Websites in order to facilitate the serving of data or content in connection with providing you with more relevant content. You agree to such use and agree that we will retain complete ownership and control over any aggregated data that we compile or acquire.

Sometimes we hire other companies to provide products and services to you on our behalf, such as processing transactions, hosting websites, conducting customer surveys, and providing customer service. We may share some of your Personal Data with companies we hire to provide products and services to you on our behalf in order to enable them to perform such work. These companies are prohibited from using your Personal Data for any other purpose and are required to maintain its confidentiality.

We will retain Personal Data for the duration of a contract and for up to 7 years from the date you last used our Websites in line with our data retention policy.  Following this time reasonable efforts will be employed to delete this Personal Data.

Your Choices

Opting out of Relevant Advertising 

We partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.

Accessing and Updating Your Information

If you agree to this Privacy Policy, then you have voluntarily agreed to our practices and procedures regarding your information as described in this Privacy Policy, our Websites’ Terms of Use, and other written documentation that may be provided to you regarding our products, services, or Websites. If you do not want us to use your information as described herein, or would either like to modify your information, or remove your information from our databases for marketing purposes, please send and opt-out request and provide us with your contact information . Without the use of your information, however, we may not be able to provide you the products, services, or information you request. We will promptly comply with your information revision requests, but may retain copies of such information as necessary for us to comply with governmental orders, resolve disputes, troubleshoot problems, enforce any agreement you have entered into with us, and as otherwise reasonably necessary for our business purposes.

Promotional E-mails

We may send you e-mails with promotional offers only if you opt-in to receiving such e-mails. If you would no longer like to receive e-mailed special event information, sales notifications or other messages from us, please provide us with your contact information or follow the “Unsubscribe” instructions on such e-mails. Your e-mail address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

Your Rights

You may have additional rights depending on the territory in which you are resident.  These rights under applicable law, may include the following:

  • A right to withdraw consent for future processing at any time, where relevant;
  • A right to request from Company, access to and rectification or erasure of, your Personal Data;
  • A right to restrict Company from processing personal data concerning you or to object to the processing of your personal data;
  • A right to data portability; and
  • A right to lodge a complaint with a data protection authority.

Please use the contact link at the end of this policy to contact us to exercise these rights.  Please include your full name, email address, country of residence and company information as part of a detailed email so that we can verify your identity prior to considering your request and undertaking any relevant further action.

Security

We employ and maintain technology and security measures designed to protect your information. When you submit sensitive information on our Websites, that information is subject to a variety of protections, including firewalls and password-protected features for certain website options. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us or receive from us.

Third Party Websites

You may have the option to enter third party websites through our Websites, or you may have the option to enter our Websites from another third party website. Since we cannot be assured that such third party websites follow our privacy policies, we encourage you to ask questions and review the privacy policies of these third parties. We have no responsibility or liability for the actions or policies of these independent sites, do not endorse any product or service that may be mentioned or offered in such websites, and are not responsible for the content or privacy practices of such websites.

Visiting our Websites from Outside of the United States

If you are visiting our Websites from outside of the United States, please be aware that your information will be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy including enrolment in Privacy Shield as set out below. By using any portion of our Websites, you understand and agree to the transfer of your Personal Data to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

The Company’s US subsidiary, Clinithink LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from the European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield list https://www.privacyshield.gov/.

Clinithink LLC is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Clinithink LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Clinithink LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolutions procedures have been exhausted.

“Do Not Track” Signals

California and Delaware laws require that we indicate whether we honour “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we shall treat your Personal Data in accordance with this Privacy Policy, whatever your Do Not Track setting chosen during your use of our Websites and do not monitor or honour any Do Not Track browser requests.

Contact Us

If you have any questions regarding this Privacy Policy, then you may contact us at: privacy@clinithink.com.

Clinithink Ltd

4 Derwen Road, Bridgend, CF31 1LH, United Kingdom

This Privacy Policy was last updated on May 23, 2018.