PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: January 1, 2020
This Notice does not apply to information Optimal collects, maintains, or discloses in our capacity as a “Service Provider” under CCPA on behalf of our clients, including clinical and medical information that we collect, host, and analyze as part of the clinical research and site management services that we perform under contract with our clients. If your information has been submitted to us by or on behalf an Optimal client as part of those services and you would like to learn more about the handling of that information, or exercise any rights you may have under the CCPA, please inquire with the client directly.
Additionally, as used in this Notice, the term “California Personal Information” does not include, and this Notice does not apply to:
- information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the United States Food and Drug Administration;
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA); and
- publicly available information lawfully made available from federal, state, or local government records; or
- other information excluded from the CCPA's scope.
California Personal Information We Collect
In the twelve (12) months prior to the “Last Reviewed” date of this Notice, we have collected the following categories of California Personal Information:
- Identifiers such as name, email address, telephone number, mailing address, Social Security number, driver’s license number, unique personal identifier, online identifier, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as signature, financial information, medical information, education and employment history, medical information, or health insurance information.
- Characteristics of protected classifications under California of federal law, such as age, race, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Internet or other electronic network activity information, such as information concerning individuals’ interactions with our websites, applications, or advertisements.
- Professional or employment-related information, such as current or past job history; professional specialities, affiliations, licenses, and certifications; financial compensation information, and performance evaluations.
- Inferences drawn from any of the above information to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sources of California Personal Information
We collect the categories of California Personal Information listed above from the following categories of sources:
- Directly from you, including when you provide information to us online, in-person at health screening events or over the phone;
- Indirectly from you, such as when we automatically collect technical and usage information when you use our websites;
- Third-party websites and other online services, such as online advertisements.
Purposes for which We Collect and Use California Personal Information
We may use the California Personal Information listed above for the following business and commercial purposes:
- To provide our clinical trial recruitment services to our clients, including maintaining and updating our patient database, identifying and notifying prospective patients of clinical trials in which they may be interested, evaluating prospective patients for qualification in clinical trials, and referring patients to clinical trial sites;
- To respond to your inquiries;
- To contact you regarding changes or updates to our service offerings;
- To conduct recruiting and candidate evaluation activities and to inform our employment decisions;
- To provide, support, personalize, and develop our websites, applications, and product or service offerings;
- To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including ads;
- To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcment of laws or agreements meant to prevent or punish such activity;
- To maintain the safety, security, and integrity of our websites, applications, other technology assets, and our business, including the detection of security incidents;
- To debug, identify, or repair errors or effectuate similar functional enhancements in connection with the our websites and other applications;
- To develop, improve, and deliver marketing and advertising;
- For internal operational uses such as research, analytics, development, audits, and security;
- For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding
- To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development; and
- For any other purpose described to you when collecting your California Personal Information before or at the time of collection.
Sharing of California Personal Information
We may share California Personal Information with the following categories of third parties:
- Our affiliated companies;
- Our service providers;
- Our clients;
- Other third parties to protect our legal rights or comply with legal requirements;
- Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- Other third parties involved in a merger, sale, joint venture or other transaction involving a transfer of our business or assets; and
- Other third parties with your prior consent.
In the twelve (12) months prior to the “Last Reviewed” date of this Notice, we have disclosed the following categories of California Personal Information, which are described in more detail above, for a business purpose:
- Personal information categories listed in the California Customer Records statute;
- Characteristics of protected classifications under California of federal law;
- Internet or other electronic network activity information;
- Professional or employment-related information; and
- Inferences drawn from any of the above information.
Sales of California Personal Information
In the twelve (12) months prior to the “Last Reviewed” date of this Notice, Optimal has not sold California Personal Information.
Optimal does not and will not sell California Personal Information.
Your Rights and Choices with Respect to California Personal Information
The CCPA provides California residents with specific rights regarding California Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your California Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the section below on Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of California Personal Information we collected about you.
- The categories of sources for the California Personal Information we collected about you
- Our business or commercial purpose for collecting or selling that California Personal Information.
- The categories of third parties with whom we share that California Personal Information
- The specific pieces of California Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your California Personal Information for a business purpose, two separate lists disclosing
- disclosures for a business purpose, identifying the California Personal Information categories disclosed; and
- sales, identifying the California Personal Information categories sold and that each category of recipient purchased.
Deletion Request Rights
You have the right to request that Optimal delete any of your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your California Personal Information from our records, unless an exception under CCPA applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 833-887-3694; or
- Emailing us at Contact@globalaes.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your California Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use California Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Any disclosures we provide in response to a request will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your California Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
You have a right to not receive discriminatory treatment for exercising your CCPA rights, and we will not discriminate against you for exercising any of your CCPA rights.
Changes to this Notice.
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice to our websites and update the notice's date.
Updated January 1, 2020.
15201 Shady Grove Road
Rockville, MD 20850