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Cookie Policy

Clinical Services International (CSI) respects your privacy and is committed to protecting your personal data. Please read this Privacy and Cookie Policy (“Policy”) carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data and cookie data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities should you need to.

This Policy aims to provide you with information about how we collect and process your personal data through this website and otherwise through our dealings with you.

Who we are

This website is operated by Clinical Services International Limited (registered and incorporated in England and Wales, with company number 10438275, and registered office at 50 Sloane Avenue, London SW3 3DD, United Kingdom), together with CSI Clinical Services International GmbH (registered and incorporated in Germany, with company number HRB227536 Berlin, whose registered office is at Hannoversche Strasse 2, 10115 Berlin, Germany), and CSI Clinical Services International LLC (registered and incorporated in the United States of America, with company registration number 5889309, whose registered office is at Four Tower Bridge, 200 Barr Harbor Drive, Suite 400, West Conshohocken, PA 19428, United States) (referred to as “we”, “us” or “our” in this Policy). Together, we are the data controller responsible for your personal data.

 

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below (see How to contact us below).

Personal data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which the identity has been removed (anonymous data). A data subject is the individual who the personal data relates to.

 

We may collect and use the following kinds of personal data (some of which is subject to you choosing to provide us with it):

 

  • Identity data including your first name, last name, title

  • Contact data including your address, email address and telephone number

  • Technical data – including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website

  • Usage data – including information about how you use our website, products and services, click movements, browsing time and details

 

We collect and use this personal data to provide products and services to you. If you do not provide personal data that we ask for, it may delay or prevent us from providing such products and services to you.

 

This website is not intended for children and we do not knowingly collect data relating to children.

How your personal data is collected

We use different methods to collect data from and about you, including through:

 

  •  Direct interactions – We may collect your data through your filling in forms, submitting or uploading information to our website, or you corresponding with us through our website, social media, by phone, email or otherwise.

  •  Automated technologies or interactions – As you interact with our website, we may collect data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies. Please see the section on Cookies below for further details.

  • Third parties or publicly available sources – We may receive personal data about you from various third parties, such as an analytics provider, or through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems

How and why we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Where you have given consent

  • To comply with our legal and regulatory obligations

  • For the performance of a contract with you or to take steps at your request before entering into a contract

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

 

The table below explains what we use your personal data for and why:

What we use your personal data for

Our reasons

Special Category Personal Data

Special category person data includes personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data (when processed to uniquely identify an individual); and data concerning health, sex life or sexual orientation.

 

We do not anticipate that we will collect any such data. However, if we do process special category personal data, we will also ensure we are permitted to do so under data protection laws.

Marketing

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. You may also receive such marketing communications from us if you have consented to it.

 

You have the right to opt out of receiving marketing communications at any time. Please contact us if you wish to elect to unsubscribe directly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your personal data with

We may share personal data with:

 

  • Our affiliated companies mentioned at the start of this Policy, Clinical Services International Limited, CSI Clinical Services International GmbH and CSI Clinical Services International LLC

 

  •  Third parties we use to help deliver our services and website to you, e.g. cloud servers, website hosts

 

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

 

We may also need to:

 

  • Share personal data with external auditors to ensure compliance with legal and regulatory requirements

  • Disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations

  • Share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring – usually, information will be anonymised but this may not always be possible; however, the recipient of the information will be bound by confidentiality obligations

 

If you would like more information about who we share our data with and why, please contact us (see How to contact us below).

Keeping your data secure and confidential

All staff at Clinical Services International adhere to our confidentiality policy. It is their legal obligation to keep all information confidential unless there is a safety risk.

 

In addition, we only disclose personal information when we have your express permission to do so. The only time we can share details without your consent is if it is required by the law.

 

Every person has the right to withdraw consent for details to be shared at any point.

 

A carer or representative may be able to give consent if the individual is unable to do so themselves for whatever reason.

 

The law requires us to pass on certain personal details when a court order is issued.

Where your personal data is held and transfers abroad

Personal data may be shared with our affiliated companies, CSI Clinical Services International GmbH, located in Germany, and CSI Clinical Services International LLC, located in the United States of America (see above: Who we share your personal data with).

 

Under UK and European data protection laws, we can only transfer your personal data to a country or international organisation abroad in certain circumstances. We will ensure that where your personal data is transferred abroad, it does so in accordance with applicable laws. This may include an adequacy decision being in place in relation to the country that is in receipt of your personal data or we may have in place appropriate safeguards to protect your personal data, including the use of approved Standard Contractual Clauses and/or Data Transfer Agreements, where deemed safe. Alternatively, a specified transfer exception may apply.

How long your personal data will be kept

We will keep your personal data while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal data for as long as is necessary.

 

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device, store information about your preferences or past actions and improve the content of the website according to your usage.

 

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users and provide all the features of our website. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

 

We use the following cookies:

 

  •  Strictly necessary cookies – These are cookies that are required for the operation of our website. They include cookies that enable you to log in to secure areas of our website.

  • Analytical or performance cookies – These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences, for example, your choice of language or region.

Third-party cookies

Throughout our website, we may link to other websites owned and operated by certain trusted third parties to, for example, make additional products and services available to you. These third-party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these third-party websites, please consult their policies as appropriate.

Consent to use cookies and changing settings

We will ask for your permission to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested and/or the functioning of the website.

 

At any time, you can prevent cookies from being set on your browser. It may be necessary to refresh the page for the updated settings to take effect. For instructions on how to block, delete or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our website.

Our use of cookies

As well as our own cookies, we may engage third party providers such as Google Analytics to act on our behalf to ensure safe browsing, enrich user experience, track and analyse your usage of our website through the use of cookies, pixel tags / web beacons, and similar technologies. These third parties collect, and share with us, usage information about visits to our website, measure and research the effectiveness of our advertisements, track page usage, help us target our recommendations and advertising, and track use of our recommendations and advertisements.

 

For a list of the specific cookies we may collect, please contact us.

Your rights

You have the following rights in relation to your personal data, which you can exercise at any time:

Access

The right to be provided with a copy of your personal data

Rectification

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data – in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations

To object

The right to object:

  •  At any time to your personal data being processed for direct marketing (including profiling)

  •  In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of those rights, please:

 

  • Contact us – see below: How to contact us

  • Provide enough information to identify yourself

  • Let us know what right you want to exercise and the information to which your request relates

 

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have security procedures in place, as well as technical and physical restrictions to access to ensure your personal data is safeguarded at all times.

 

We have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

How to make a complaint

Please contact us if you have any query or concern about our use of your information (see below: How to contact us). We hope we will be able to resolve any issues you may have.

 

You also have the right to make a complaint at any time to your local supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a third party, so please contact us in the first instance.

Changes to this Policy

We may change this Policy from time to time. Please ensure that you regularly check this Policy for any changes that may affect you.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How to contact us

You can contact us by post, email or telephone if you have any questions about this Policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

 

Our contact details:

 

Clinical Services International

50 Sloane Avenue

London SW3 3DD

United Kingdom


CSI Clinical Services International GmbH

Hannoversche Strasse 2

10115 Berlin

Germany

 

info@csint.com

+44 (0)20 3954 0517

Customer Service

  • To effectively perform our contract with you

  •   For our legitimate interests, i.e. to make sure we can deliver the best service to you and respond to you when you need us

Preventing and detecting fraud against you or us

For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us

Activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

  •  To comply with our legal and regulatory obligations

  •  For our legitimate interests or those of a third party, i.e. to minimise fraud and to prevent consumers registering more than one membership in order to exploit our services

Gathering and providing information required by law or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • For our legitimate interests, i.e. to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

  • In certain circumstances where you have given your consent

Preventing unauthorised access and modifications to systems

  •  For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us

  •  To comply with our legal and regulatory obligations

Updating and enhancing customer records and our service provided to you

  •   To perform our contract with you or to take steps at your request before entering into a contract

  •  To comply with our legal and regulatory obligations

  •   For our legitimate interests or those of a third party, e.g. making sure we can keep in touch with our customers about existing orders and new products or services

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