The company complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. The company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the company’s certification, please visit http://www.export.gov/safeharbor/.
This Policy applies to all personal information solicited by Novum in any format, including electronic, paper, or verbal including our Web sites www.gonovum.com and www.novumprs.com.
Novum participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in Safe Harbor, we have agreed to participate in the dispute resolution procedures of the American Arbitration Association for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with Safe Harbor, you should first contact us (as provided below). If contacting us does not resolve your complaint, you may raise your complaint with the American Arbitration Association here, Novum is committed to respecting the privacy of individuals. Novum has enacted the following procedures to review and monitor the use of personal information and to ensure it is used responsibly and that we comply with recognized standards of privacy protection:
On our Web sites we collect, name, email, and phone number (gonovum) and name, business, email, phone, and other business information (novumprs) in order to contact you regarding upcoming clinical trial participation (gonovum) or to send you a promotional CD and other business related information (novumprs).
From time to time we post testimonials on our Web sites. We receive permission to post testimonials that include personal information. If you wish to update or delete your testimonial, you can contact us at email@example.com.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. We will respond to your requests for information as well.
Generally, you may not opt-out of these communications, which are not promotional in nature.
2) CHOICE: We will give individuals the opportunity to choose (opt out) if their personal information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. All promotional emails sent to users will have unsubscribe instructions included in each email. Affirmative or explicit (opt in) choice must be given if the information is to be disclosed to a third party or used for a purpose other than its original purpose or the purpose authorized by the individual. However, we do not currently collect Sensitive Personal Information from users of our Web site. We may however, in limited circumstances, share personal information with government authorities or others as required to protect the interests of the Novum or others, as necessary in connection with the sale or transfer of all or a portion of the business, or as required by applicable law, subpoena, or court order.
3) DATA INTEGRITY: Novum will use personal information in ways that are compatible with the purpose for which the data was collected. Novum will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.
4) TRANSFER TO AGENTS: Novum will obtain assurances from its agents (service providers) such as shipping agents to ship CDs that they will safeguard personal information consistent with this Policy and that they will not use your personal information for their own promotional purposes.
5) ACCESS AND CORRECTION: Novum will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where the rights of persons other than the individual would be violated. You may contact us at firstname.lastname@example.org to correct, amend, or delete information as described above. We will respond to any request for access within 30 days.
6) RETENTION: Novum will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7) SECURITY: Novum maintains a high level of security, particularly in relation to data. Computer equipment, networks, programs, data and documentation are maintained to a high standard, and precautions are in place to protect personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration, and/or destruction. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
8) ENFORCEMENT: Novum will ensure adherence to this Policy by ensuring (a) readily available and affordable independent recourse mechanisms exist so that each individual’s complaints and disputes can be investigated and resolved; (b) procedures for verifying that the commitments companies make to adhere to stated principles have been implemented; and (c) obligations to remedy problems arising out of a failure to comply with the principles exist. Sanctions must be sufficiently rigorous to ensure compliance by the organization.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Novum Participant Advocate. Novum will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles contained in this Policy. You may also contact us at email@example.com. In addition, see Privacy Principles above for disputes regarding the Safe Harbor Privacy Framework.
Novum has provided its employees with appropriate training to ensure that all individuals who process personal information are fully aware of their responsibility with respect to data protection.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Novum to this policy may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
INTERNET PRIVACY/LINKS TO THIRD PARTY WEB SITES
Novum sees the Internet and other advanced electronic technology as valuable tools for communicating and interacting with others. Novum recognizes the importance of maintaining the privacy of information collected online. Some of our Web pages may contain links to Web sites outside the Novum organization. Linked Web sites are not under the control of or endorsed by Novum. This Policy does not apply to linked Web sites outside the Novum organization.
Cookies are information that your web browser places on your computer when you visit a website. Novum is able to access only the cookies that it sets on your computer, and we are only able to determine things like the type of computer operating system and browser that you and other visitors are using. Novum collects this information in the aggregate in order to improve access to our content based on our visitors’ browsers and operating system types to make our content available to as many users as possible. You can, of course, disable cookies on your computer by indicating this in the preferences or option menu of your browser. Log data collected on web servers supplies us with aggregate information about the number of visits to different pages of our site and how you found our site, such as through search engines or other websites. We use this information only for improving our site.
As is true of most Web sites, Novum gathers certain information automatically, and stores it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
Novum uses this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal information.
Novum Pharmaceutical Research Services, Inc.
225 W. Station Square Drive
Pittsburgh, PA 15219
Last Updated: 9/8/15