Privacy Policy

Version
3
- published on
August 25, 2021

At SMART-TRIAL ApS (”SMART-TRIAL”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy sets out the guidelines for SMART-TRIAL’s processing of your personal data 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 SMART-TRIAL.

Data Controller

The data controller for your personal data is:

SMART-TRIAL ApS
K. Christensens Vej 2L
9200 Aalborg SV
CVR no. 35 13 97 10

1. If you visit our websites and applications

This section sets out the policy of SMART-TRIAL’s processing of personal data regarding users of SMART-TRIAL’s applications, websites www.smart-trial.com, www.smart-trial.co and any of our subdomains (e.g. x.smart-trial.com or x.smart-trial.co).

1.1 INFORMATION PROVIDED BY YOU

Types of personal data
SMART-TRIAL uses cookies on our websites and applications. SMART-TRIAL may collect, process and store the following personal data about you via cookies when you visit our website:

  • IP address
  • MAC address
  • Geolocation and ZIP code
  • Gender and age
  • Language settings
  • Hardware, software and internet browser used to access our websites or applications
  • Date and time of your access to our websites
  • Preferences and click behaviour
  • Browsing history

We use cookies to collect the personal data stated above. You can find more information regarding our use of cookies in our cookie policy, which is available here.

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

  • Promotional marketing in general
  • Product and service development
  • Statistics and analysis

Legal basis
SMART-TRIAL will mainly process your personal data based on the following legal basis:

Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), as well as improving and developing our products and services (Article 6 (1) (f) of the General Data Protection Regulation).

Retention period
Cookies are deleted pursuant to our cookie policy which is available here. Anonymised personal data collected via cookies may, however, be kept for a longer period of time.

1.2 If you use contact forms, schedule a demo, sign up for product webinars or otherwise contact or communicate with us

Types of personal data
When you use the contact forms on our websites, schedule a demo, sign up for product webinars or otherwise contact or communicate with us, SMART-TRIAL collects, processes and stores the following personal data about you:

  • Name, email address, phone number
  • Employer
  • What your inquiry or the communication concerns
  • Date and time of your inquiry
  • Other personal data you submit as part of your inquiry or communication with us. We recommend that you do not submit sensitive personal data, unless it is strictly necessary in relation to your inquiry. If you submit sensitive or otherwise confidential personal data by email, we recommend that you use encryption.
  • Whether you have accepted to receive our newsletter or other material and communication from SMART-TRIAL
  • Browsing history

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

  • Handling of your inquiry
  • General communication with you
  • Customer service and support
  • Statistics and analysis

Legal basis
SMART-TRIAL 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 and developing our products and services (Article 6 (1) (f) of the General Data Protection Regulation).

Contractual obligation: If your inquiry concerns conclusion of a (potential) contract with SMART-TRIAL, we process your personal data to make arrangements prior to the conclusion of the contract (Article 6 (1) (b) of the General Data Protection Regulation).

Retention period
Your personal data will be retained for up to three years from your last interaction with us. Anonymised personal data may, however, be kept for a longer period of time.
If you are a customer or employed with one of our customers, suppliers or other business partners, we refer to section 3 below.

1.3 If you create a user account

Types of personal data

When you create a user account on our websites, SMART-TRIAL 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
SMART-TRIAL 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 SMART-TRIAL 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 SMART-TRIAL customer, we refer to the privacy policy of the entity responsible for the clinical trial in question or the SMART-TRIAL customer, respectively.

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

2. If you subscribe to our newsletter and other marketing material

This section sets out the policy for SMART-TRIAL’s processing of personal data when you have subscribed to our newsletter or other marketing material.

Types of personal data
When you subscribe to our newsletter or other marketing material, SMART-TRIAL collects, processes and stores the following personal data about you:

  • Name and email address
  • Occupation and employer
  • Your consent
  • Your interests
  • Your click behaviour in relation to marketing material we have sent you

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

  • Promotional marketing
  • Statistics and analysis

Legal basis
SMART-TRIAL will process your personal data based on one or more of the following legal bases:

Consent: SMART-TRIAL will only use your personal data in order to send you product information, newsletters and other marketing material if you have provided your prior and explicit consent hereto (Article 6 (1) (a) of the General Data Protection Regulation).

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

Retention period
Your personal data will be retained for as long as your consent to receive newsletters is active.

You may revoke your consent by clicking the unsubscribe link in the bottom of each e-mail or by contacting us as described below. The revocation of your consent does not affect the legality of the processing prior to the withdrawal.

The documentation for your marketing consent will be kept for two years after revocation. This retention period is based on SMART-TRIAL’s legitimate interest in being able to document that direct marketing activities have been carried out in compliance with applicable legislation (Article 6 (1) (f) of the General Data Protection Regulation).  

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

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

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

Collection of personal data
SMART-TRIAL 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 SMART-TRIAL
  • When you have shown an interest in SMART-TRIAL’s products or services, e.g. by providing your business card to SMART-TRIAL
  • When you collaborate and communicate with SMART-TRIAL

Types of personal data
SMART-TRIAL 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 SMART-TRIAL, 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
  • Marketing
  • Market research
  • Compliance and regulatory purposes, such as fulfilling our legal and compliance-related obligations to prevent illegal activity
  • Dispute handling
  • Legal basis
  • SMART-TRIAL 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, marketing activities (where consent is not required), 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 SMART-TRIAL 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 fulfil the purposes described above we may provide access to your personal data for third parties who, on the basis of a contractual relationship with SMART-TRIAL, provide relevant services, e.g. IT-providers, email providers and marketing 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 SMART-TRIAL’s development, the company structure may change, e.g. through a full or partial sale of SMART-TRIAL. 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 SMART-TRIAL 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: info@smart-trial.com

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.