Last Revised: 20 September 2022
If you are a UK/EEA candidate applying for a job at Lightship, please visit our Employee Recruitment Privacy Notice.
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Table of Contents
Types Of Information We Collect & For What Purposes
We collect two basic types of information from you: personal information and non-personal information.
Personal information includes all information that relates to you, or which are opinions about you personally and either identifies or may be used to identify you personally (collectively, “personal information”). Wherever you are, here are examples of the type of personal information that we may collect from and about you and how we may use that information.
Clinical trial recruitment
- Types of Data. If you choose to take part in a clinical trial, we will collect your name, contact details, date of birth and other screening information, which may include but is not limited to, health and medical/ medication history, ethnicity, height, weight, family history and any other information necessary to determine your suitability for a given trial. We may also ask for your opinion on our service through the provision of an optional satisfaction survey.
- Primary Purpose for Collection and Use of Data. We obtain your consent to process this information to assess your eligibility for a given trial and for safety reasons should you go on to participate in the trial.If you have provided your consent, then we may also add your details to our database so that we can inform you about suitable clinical trials in the future. Where necessary, we may also request a copy of your medical history from your treating physician following your authorization.
- Types of Data. On some occasions, we offer screening and testing services for certain diseases in communities. We collect your name, contact details and necessary medical information.
- Primary Purpose for Collection and Use of Data. Once the test has been performed, the data/result will be shared with you. If you provide your consent, your information will be added to our database to ensure we can contact you about current and future trials or related initiatives relevant to your health condition(s).
Market research / Surveys
- Types of Data. You may take part in our market research and surveys without volunteering any of your personal information. However, you also have the option of providing identifying information, including your contact details, which may be linked back to your feedback/opinions collected as part of the research or survey.
- Primary Purpose for Collection and Use of Data. Market research and surveys provide us with valuable insights. You can take part without being identified, or where you choose to provide your personal information, we will seek your consent to process this information.We may then contact you about current and future trials or related initiatives relevant to your health condition (if you have disclosed this information to us). Please note that we may share personal information with service providers as necessary to help facilitate the research and/or survey.
Client relationship management
- Types of Data. We collect the name, contact details, and other professional information about our clients and their employees, or any third parties employed or engaged by them, with whom we may interact.
- Primary Purpose for Collection and Use of Data. Where relevant to our client contracts, we will contact them concerning normal business administration, such as projects, services, business-to-business marketing, satisfaction surveys, and billing.
Investigator / Healthcare professional engagement
- Types of Data. We collect personal information, such as your name, contact details, age, gender, ethnicity, licensure coverage, bank account information or other professional information. If you are acting as an investigator on a trial, we may also be required to conduct a background check.
- Primary Purpose for Collection and Use of Data. We obtain your consent when processing your personal information to understand your qualifications and training necessary to conduct a trial, for diversity and inclusion monitoring, to identify native languages which can be matched to the needs of our clients and study participants, and for the purposes of performing our contract with you, as it relates to normal business administration, satisfaction surveys, and billing, where relevant.
Participants mobile application
- Types of Data. Study participants who have enrolled in a trial will be offered Lightship’s secure Patient App. The App will collect account credentials such as name, email address, scheduling information for study visits and responses to health questionnaires and satisfaction surveys.
- Primary Purpose for Collection and Use of Data. Study participants will consent to the use of Lightship’s Patient App to manage account access, scheduling of study visits and engagement with Lightship’s study team throughout the course of a trial. This is designed to provide participants with a safe and convenient way to manage and share information. Should a participant not consent to use of the App, our study team can discuss alternative approaches for engagement.
- Types of Data. If you provide feedback or contact us for support, we will collect your name and email address, as well as any other information that you wish to send to us in order for us to respond.
- Primary Purpose for Collection and Use of Data. By submitting a request to us, you consent to us processing your personal information to act upon your query, feedback, or issue.
- Types of Data. If you apply for a job posting, or become an employee or contractor, we collect information necessary to process your application or to hire and/or retain you as an employee or contractor. This may include your contact details, professional qualifications, employment history and government issued identification. If necessary for a given role, we may conduct background checks, including criminal history and professional disbarment where the local law permits.
- Primary Purpose for Collection and Use of Data. We use information about current employees or contractors to manage your employment or engagement, or in anticipation of a contract with you. In some contexts, we are also required by law to collect certain information about our employees or contractors. We also have a legitimate interest in using your information to have efficient staffing and work force operations.
- Types of Data. If you receive an email from us, we use certain tools to capture data related to when you open our message or click on any links or banners it contains.
- Primary Purpose for Collection and Use of Data. We obtain your consent prior to enabling this functionality to understand how you interact with our communications so that we may make them more relevant to you.
First party cookies
- Primary Purpose for Collection and Use of Data. We have a legitimate interest in collecting personal information from strictly necessary cookies for our website to function. Where we place cookies to improve the performance of our website based on how you interact with it or to personalize your experience based on your preferences and interests, we will always seek your consent. We apply the same approach to cookies when you access our website via your mobile device. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.
Third party cookies
- Types of Data. We work with third parties to help us identify potential participants for our clients’ trials and for other purposes. These third parties may use technology, such as cookies, to track whether you have completed a questionnaire on our site.
- Types of Data. When completing one of our online questionnaires (e.g., study online screener or market research survey), we collect your Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used).
- Primary Purpose for Collection and Use of Data. We have a legitimate interest in monitoring our networks and the visitors to our websites to cut down on fraudulent activity or bogus screeners completed by a robot.
Where permitted by applicable law, we may process your personal information for a compatible purpose secondary to the primary reason for collection, such as obligations under law or scientific research in the public interest. We may combine your personal information collected through various sources, including information collected through our Services, and develop a profile that will be used for the purposes above. We may also process your information to establish or exercise our rights, to defend against a legal claim, to respond to legally binding requests, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, equality and diversity monitoring, or a violation of our policies.
We strive to uphold data minimization principles and only seek to collect personal information from you for the purposes described in this Privacy Notice. We are required to disclose the categories of personal information we collect under California law – see California Privacy Law Appendix for details.
Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). When we combine non- personal information with personal information, we treat the combined information as personal information. We may use personal information to create non-personal information. We use non- personal information for any legitimate business purpose.
Offline Interactions and Other Sources
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources, or from our offline interactions with you. Where legally required, if we believe a person does not already know that we hold personal information about them (e.g., we do not have an existing active relationship with them), we will inform them that we are now holding their data, the reasons why, and inform them of their rights and choices.
We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our website. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.
Social Media Integration
Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, including the information listed in the Types of Information We Collect section above. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.
Your Privacy Rights & Choices Regarding Your Personal Information
The following rights and choices are available to you, but some exceptions may apply based on our reason for processing your personal information and the local privacy laws in your jurisdiction. Depending on the above, you may have the right to:
- Access Your Personal Information. You may request that we send you or another organization or person a copy of your personal information held by us.
- Change/Correct Your Personal Information. We rely on you to ensure that the personal information we hold is up to date. You may request us to correct or modify your personal information where it is inaccurate or incomplete at any time. Note that we may keep historical information in our backup files as permitted by law.
- Delete Your Personal Information. Typically, we retain your personal information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information or request that we delete your personal information. Note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our legitimate business purposes, which could include honoring your wish not to be re-contacted.
- Object to Certain Processing. You may under certain circumstances object to our use or disclosure of your personal information.
- Withdraw Your Consent. You may withdraw consent at any time or for any reason where such processing is based upon consent (for example, when signing up to hear about Lightship’s studies). If you withdraw your consent for the processing of personal information, then we may no longer be able to provide you the services specifically related to the consent you have withdrawn.
- Restrict Certain Processing / Limit Use of Sensitive Personal Information. You may, under certain circumstances, request that we restrict processing of your personal information or limit the use of sensitive personal information.
- Text Messages. If you receive an automated text message from us, you can opt-out of receiving future text messages by replying “STOP.”
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
You also have the right not to be subject to discriminatory treatment for exercising the above privacy rights.
To submit requests or questions, or designate an authorized agent to make a request, please contact us via our online web form or send an email to email@example.com or call or write to our US or UK team using the contact information below.
Please note that, as required by law and for your protection, we will need to verify your identity before we are able to fulfil your information rights request. Depending on your request, we will ask you to validate existing information that we already have on file for you to ensure we are confident about your identity. We may also use two factor authentication techniques to do this. Following successful verification, we will fulfill your request to the extent necessary under applicable law and within applicable legal timelines.
In some circumstances, you may designate an authorized agent or representative to submit requests to exercise your privacy rights on your behalf. We will require the authorized agent or representative to verify that they have been authorized to make this request on your behalf by presenting a copy of the signed permission. This should be submitted at the time of issuing the request to us. Without this information, the request may be denied.
In accordance with California law, we are providing notice that we do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To submit a request, please contact us using the contact information below.
How We Protect Personal Information
We use a number of physical, technical, and organizational security measures in an attempt to safeguard data against any unauthorized access, disclosure, or loss and evaluate these measures on an ongoing basis. However, no method of transmission over the internet or use of electronic storage is fully secure; therefore, we do not guarantee that your data will be 100% secure from theft, loss, or unauthorized access.
In the event that we are required by law to inform you of a security incident, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether such access or use has been authorized by you. If you have reason to believe that your interaction with us is no longer secure (for example, if your account password has been compromised), please notify us immediately using the contact information below.
The following additional information relates to our privacy practices:
- Retention Of Your Personal Information. Typically, we retain your personal information for an appropriate period given the nature of our interaction with you and in line with our records retention policy, unless a longer retention period is required or permitted by law.
- Children’s Privacy. We seek to collect the information necessary to provide our Services solely from parents or legal guardians to the extent required by law. We do not knowingly collect personal information directly from children or other persons who are under 16 years of age. Individuals who are children or those under the age of 16 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 16 without a parent or legal guardian’s permission, please contact us immediately.
If you have any questions, comments, or complaints concerning our privacy practices, please contact us at the appropriate address below. We will respond to your requests and provide you with any necessary additional privacy-related information.
222 Pacific Coast Highway 10th Floor
El Segundo, CA 90245
Lightship Clinical Research Limited
11th Floor, Whitefriars Lewins Mead
England, BS1 2NT
If you are in the UK and are not satisfied with our response, you have a right to lodge a complaint with the Information Commissioner’s Office.
California Privacy Law Appendix
In accordance with California law, please see the chart below to learn more about the categories of personal information we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it. For further information on the specific context in which we use each category of data, please see the ‘Types of Personal Information We Collect & For What Purposes’ section above.