Respecting Privacy Issues

 

Enclarity is committed to protecting your privacy. We respect your right to privacy and feel it is important for you to know how we handle the information we receive from you via the Internet. In general, you can visit www.enclarity.com without revealing any personal information about yourself. If you choose to provide Enclarity with personal information, it may be necessary in some cases for us to provide your information to our contractors or agents in order to respond to your inquiry.

 

Customer Information Practices Statement

 

Guiding Principles

 

Enclarity is an information and research company that provides products and services to help our customers improve health care treatment, delivery and financing as well as develop and bring to market new therapies. In our operations, we often possess personal information that identifies individuals and other proprietary information about our customers' operations. Preservation of, and respect for, our customers' trust is critical to our continued success. Therefore, we will always treat such information:

 

• Confidentially, according to applicable laws.
• Appropriately, according to the promises we make to our customers.
• Respectfully, according to our common concern for the sensitive nature of such information.

 

Policies

 

Information Security: We maintain appropriate physical, electronic and administrative security standards and procedures to safeguard our data and systems. Our employees are educated on the importance of our privacy and security policies and must comply with them. Employees are permitted to access and use only that personal and proprietary information they need to perform their job duties.

 

Information Processing: We try to use only the amount of personal and proprietary information necessary for research, analytical, or derivative product development purposes that are consistent with:

 

1. Our core business mission to provide high-quality products and services to our customers; 2. Our contractual and legal obligations to customers, data controllers and individuals from whom we receive such information and 3. Applicable law.

 

We have procedures to maintain the accuracy of information while in our care. We do not maintain personal information longer than necessary.

 

• When we receive personal information from customers or other data controllers as a business associate, we rely on their obligations to provide individuals with any required notice and consent for the intended purpose or we obtain additional consent/authorization as necessary. We process personal information obtained from clinical research trials in accordance with the individual's informed consent, national laws and international guidelines governing human subjects protection. Research using personal information is approved by an institutional review board, ethics committee or privacy board where and as required by law.
• When we collect personal information directly from individuals (such as those interested in participating in a clinical research trial or becoming clinical investigators) on behalf of a customer, we will provide such individuals with:

 

Notice about the intended use and disclosure of their information;
Choice before using or disclosing their information for any other purpose; and
The ability to access and correct their information where required by law.

 

De-Identified Data: We remove, encode or encrypt individual identifiers from personal information to the fullest extent possible consistent with its intended use. In some cases, we receive personal information from customers and data controllers for the purpose of de-identifying it on their behalf. We anonymize such data using statistical techniques to create aggregated norms or benchmarks, such as, but not limited to, hospital performance measures or prevailing insurance charges in an area.

 

Clinical Communications: We may partner with customers such as health plans and health care providers to help them inform patients about treatment options such as clinical trials. We also may partner with customers to help them provide information on health-related products and services of potential interest to their consumers. We will not use personal information for such purposes unless:

 

1. The activity is permitted by law; 2. The activity promotes health and well-being; and 3. Individuals are given the opportunity to "opt-out" of the program or to "opt-in" to the program where required by law or by the customer or data controller.

 

In addition:

 

• We will not distribute information or solicitations to consumers enrolled in government health care programs for purposes other than assisting a customer in carrying out treatment, payment or health care operations, unless approved in advance by the sponsoring government agency and requested by the individual without any solicitation on our part.
• We will not solicit or provide information to consumers based on their status with or at risk for mental health, substance abuse, or HIV/AIDS, unless we are acting on behalf of a customer who has obtained appropriate consent/authorization or is otherwise legally authorized to make such contact, or when approved by an institutional review board or privacy board for research purposes in accordance with applicable law.

 

Information Disclosure: We will not disclose personal or proprietary information, which we obtain in the course of providing products and services to our customers, to any third party except: (1) as required by law, or (2) consistent with applicable law and our obligations to the customer, data controller and/or individual from whom we received the information, as follows:

 

• We occasionally hire other companies to provide limited services on our behalf. Those companies will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.
• We will not share one customer's information with another customer, except at the customer's direction or as part of de-identified aggregated norms. At the direction of a customer, such as an employee benefit plan sponsor, we will disclose the customer's information to its other service providers, from its service providers back to the customer, or to other entities participating with the customer in an organized health care arrangement. The other entities may also be our customers.
• We disclose personal information about clinical investigators and encoded patient data from clinical research trials to the study sponsor in accordance with the individual's consent or contract. Personal or proprietary information may be included in assets transferred as part of a merger or sale of the company's assets.

 

International Data Transfers: Personal information collected on Enclarity sites and services may be stored and processed in the United States or any other country in which Enclarity or its affiliates, subsidiaries or agents maintain facilities, and by using an Enclarity site or service, you consent to any such transfer of information outside of your country in accordance with international data protection laws.

 

Web Site Privacy: We do not identify visitors to our World Wide Web site unless they choose to identify themselves, such as to obtain information about products or clinical trials.

 

• Our Web site uses "cookies" to enable visitors to personalize your online experience or track aggregate site visitation statistics. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access the full functionality of the Web site.
• We also may collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring Web site addresses. We do not use IP addresses to identify individuals.

 

Our Web site is not designed to attract children; we do not collect or maintain information from our Web site from individuals that we actually know are under the age of 13 years.

 

Changes to This Privacy Policy: We will occasionally update this privacy statement to reflect changes in our services and customer feedback. When we post changes to this Statement, we will revise the "last updated" date at the top of this statement. If there are material changes to this statement or in how Enclarity will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this statement to be informed of how Enclarity is protecting your information.

 

Enclarity, Inc.
65 Enterprise
Aliso Viejo CA 92656