Greenlight Guru Clinical Product Privacy Policy

Version 3 - published on September 19, 2023

At Greenlight Guru (”Greenlight Guru Clinical”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy sets out the guidelines for our processing of your personal data in the Greenlight Guru Clinical Product and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to Greenlight Guru.

Data Controller

The data controller for your personal data is:

SMART-TRIAL ApS (d.b.a. Greenlight Guru)
K. Christensens Vej 2L
9200 Aalborg SV
CVR no. 35 13 97 10

1. If you visit our applications

This section sets out the policy of Greenlight Guru’s processing of personal data regarding users of Greenlight Guru Clinical’s applications.

1.1 If you create a user account

Types of personal data

When you create a user account on our websites, Greenlight Guru collects, processes and stores the following personal data about you:

  • Name, email address and phone number
  • Address and Country
  • Whether you have accepted to receive our newsletter
  • Occupation, employer
  • Staff ID
  • IP address and geolocation
  • Information about your internet connection, and the equipment you use to access our services

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Administration of user account
  • Product security measures
  • Statistics and analysis
  • Product and service development
  • Customer service and support

Legal basis
Greenlight Guru will mainly process your personal data based on one or more of the following legal bases:

Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, as well as improving and developing our products and services (Article 6 (1) (f) of the General Data Protection Regulation).

Contractual obligation: We process your personal data with the purpose of complying with our agreement to deliver a user account to you (Article 6 (1) (b) of the General Data Protection Regulation).

Retention period
Your personal data related to a user account which is not associated with a clinical trial or a Greenlight Guru customer will be retained for 2 years from your last user account activity. If your user account is associated with a clinical trial or a Greenlight Guru customer, we refer to the privacy policy of the entity responsible for the clinical trial in question or the Greenlight Guru customer, respectively.

Anonymized personal data may, however, be kept for a longer period of time.

2. Contact persons at customers, suppliers and other business partners

This section sets out the policy for Greenlight Guru’s processing of personal data in the Greenlight Guru Clinical product collected from owners of sole proprietorships or contact persons at customers, suppliers and other business partners who collaborate with Greenlight Guru.

Collection of personal data
Greenlight Guru may collect, process and store personal data about you in the following instances:

  • When your company or the company you are employed with enters into an agreement with Greenlight Guru
  • When you collaborate and communicate with Greenlight Guru

Types of personal data
Greenlight Guru may collect, process and store the following personal data:

  • Name, email address, telephone number and similar identification data
  • Individual data, such as preferred language and home country
  • Organizational data, such as company name, company address, job position, business area, primary work location and country
  • Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and Greenlight Guru, that may include e.g. your contact information
  • Any feedback you provide if you participate in surveys
  • Financial data, such as payment terms and bank account details

Such information may be provided directly by you (primarily via emails and other correspondence) or by a third party such as your employer.

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Generally, to plan, perform and manage the business relationship, including any contracts
  • Administration, such as processing payments, evaluation of credit ratings, performing accounting, auditing, billing, as well as providing support services
  • Completion of requests received from you
  • General communication
  • Product and service development
  • Statistics and analytics
  • Market research
  • Compliance and regulatory purposes, such as fulfilling our legal and compliance-related obligations to prevent illegal activity
  • Dispute handling
  • Legal basis
  • Greenlight Guru will mainly process your personal data based on the following legal bases:

Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6 (1) (b) of the General Data Protection Regulation).

Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. statistics, analysis, providing support as well as improving and developing our products and services. The processing may also be necessary for our legitimate interests in preventing fraud or establish, exercise, or defend legal claims (Article 6 (1) (f) of the General Data Protection Regulation).

Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6 (1) (c) of the General Data Protection Regulation).

Retention period
Your personal data will be retained for 3 years as from termination of the cooperation between Greenlight Guru and your company or the company you are employed with.

Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted. The storage period has been determined on the basis of the storage requirements laid down in s. 10 of the Consolidated Bookkeeping Act and, consequently, with a view to complying with applicable law.

Anonymized personal data may be kept for a longer period of time.

4. Disclosure to other data controllers and transfer to data processors

To fulfill the purposes described above we may provide access to your personal data for third parties who, on the basis of a contractual relationship with Greenlight Guru, provide relevant services, e.g. IT-providers or email providers. Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.

In connection with Greenlight Guru’s development, the company structure may change, e.g. through a full or partial sale of Greenlight Guru. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, Article 6(1)(f) of the GDPR, as Greenlight Guru has a legitimate interest in handing over part of its assets as well as making commercial changes.

Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to

  • Police
  • Lawyers
  • Auditors
  • Courts
  • Public authorities
  • Prospective buyers
  • Affiliated companies
  • If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will be based on the EU Commission’s standard contracts or binding corporate rules.

5. Your rights

  • You have the right to access the personal data we process about you
  • You have the right to object to our collection and further processing of your personal data
  • You have the right to have your personal data rectified and deleted, with certain statutory exceptions, including the Bookkeeping ActYou have the right to request us to restrict the processing of your personal data
  • Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
  • You may, at all times, withdraw any consent you may have given. We will then delete your personal data, unless we can continue the processing on another basis. Our newsletter can be unsubscribed by clicking the link at the bottom of the newsletter

6. Questions or complaints

If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:

SMART-TRIAL ApS
K. Christensens Vej 2L
9200 Aalborg SV
Denmark
Email: clinical.info@greenlight.guru

If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country. A list of European supervisory authorities is available here.

7. Changes to the privacy policy

We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly. The, at all times, applicable privacy policy will be available at our websites.



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