Privacy Policy

Effective as of May 16, 2024 Published on May 16, 2024

AlphaLife Sciences, LLC has always recognized data protection as an important issue for its stakeholders and understands the responsibility that comes with the processing of personal data. This Privacy Policy describes the privacy practices of AlphaLife Sciences, LLC and its affiliates (together “AlphaLife” or “we”) related to personal data collected, used, stored, and otherwise processed in connection with the services and products provided to our customers (the “Services”) and the portals, websites, apps where this Privacy Policy is referenced (the “Sites”). It explains the rights and choices available to individuals with respect to their personal data.

Please be aware that some supplemental country terms may be applicable as detailed at the end of this Privacy Policy.

Applicable Scope of this Privacy Policy

This Privacy Policy applies to the personal data AlphaLife processes as a data controller, i.e., as the party that determines what personal data to collect online or offline and to what end.

This Privacy Policy does not apply to (i) personal data about AlphaLife employees and candidates; and (ii) personal data that AlphaLife processes on behalf of its customers or other third parties as specified in the applicable agreement. Notwithstanding the above exclusion, this Policy may contain certain information for scenario (ii) for your right-to-know and to facilitate your communication with the data controller in this scenario.

Regarding personal data we process on behalf of our customers, AlphaLife provides an online platform and applications for our customers to operate aspects of their businesses, including the collection, processing, and storage of clinical and operational data for the planning, conducting and optimization of clinical trials. AlphaLife’s customers decide what data to upload to our platform or applications, which may include information about their authorized users, employees, and clinical trial patients. AlphaLife only processes this data as instructed by our customers and does not control or own the personal data uploaded, processed by the customers. Those instructions may include processing or using personal data for purposes of providing or developing the AlphaLife platform, applications and services, preventing or addressing service or technical problems, responding to support issues, responding to our customer’s instructions, or as may be required by law.

For your convenience, hyperlinks may be posted on the Services or Sites that link to other websites, services or apps that AlphaLife does not own or control. This Privacy Policy is not applicable to them and AlphaLife has no liability for the content of third-party websites, services or apps nor the personal data they collect. AlphaLife encourages you to read the privacy policies of the other websites you visit and services or apps you use.

Contents of this Privacy Policy

This Privacy Policy provides information about:

• The types of personal data AlphaLife may collect about you;
• How the personal data is collected;
• The purposes and legal basis of processing your personal data (e.g. to comply with the law, for marketing purposes with your consent);
• Your rights and choices about your personal data: depending on your jurisdiction, you may have legal rights associated with AlphaLife’s processing of your personal data, including rights to access, correct, delete, transfer, or object to the processing of your personal data. Regardless of where you live, AlphaLife will honor your request to opt-out of being contacted for marketing reasons;
• How to contact us.

What Personal Data Is Collected and Processed by AlphaLife

Personal data means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the natural person.

In any event, the personal data processed by AlphaLife is limited to data necessary for the purposes described in this Privacy Policy.

Depending on the purposes detailed below, personal data processed by AlphaLife includes:

• Personal and business contact information such as first and last names, email address, telephone number(s), cellphone number(s) and job title;
• Profile information such as user ID, login and password; type of organization (sponsor, CRO, hospital, research institution etc.), organization name, department, employment status, job responsibilities, roles in the projects;
• Usage information and device information such as IP and Mac addresses, logs, on how you use AlphaLife Services, including data from cookies as described below.

Such personal data may be collected by AlphaLife through the following means:

• Directly from you through the Services or otherwise communicated;
• Automatically;
• From third-parties, such as:
  • Your employer, or other organization you work for, and
  • Third parties you directed to share your personal data with AlphaLife.

The provision of personal data identified as mandatory is on a voluntary basis but is necessary to provide you with Services.

Please be aware that Services are not designed for children who are considered as minors under applicable data protection laws. If you are a minor, you are not allowed to use Services. If AlphaLife learns that it has collected personal data from a child, it will delete that information as quickly as possible.

Why Your Personal Data is Processed by AlphaLife

AlphaLife only uses your personal data as permitted by law. The legal bases and purposes of AlphaLife processing of your personal data are described below:

With your consent.

• to communicate with you, including when you request information related to Services, register on Sites, or interact with us through the Services, and more generally to manage AlphaLife communication and marketing activities;
• to ascertain your requirements and interests and provide you with the most suitable Services;
• to provide you with a personalized, interactive use of Services or Sites and allow you to access all their features.

To enter into an agreement with you and provide you with Services.

• To create an end-user account to have access to Services;
• To enable AlphaLife to manage its business relationships with you, (in conjunction with subscriptions, orders, support, including essential information for users of Services and security of Services);
• To operate, maintain, administer and improve the Services and Sites.

To pursue the following legitimate interests.

AlphaLife processes your personal data for purposes based on the following legitimate interests:

• To improve your experience better understand your needs and interests, and personalize your experience with the Services, including remembering your settings;
• To provide you with information related to marketing activities for similar goods and products if you are already using Services;
• To enable AlphaLife to manage its business relationships when you are acting on behalf of a AlphaLife customer;
• To protect the proprietary information of AlphaLife;
• To create anonymous data for analytics;
• To protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity as well as for security and safety prevention.

AlphaLife takes into consideration and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for purposes based on legitimate interests. Unless AlphaLife has your consent or is otherwise required or permitted to do so by law, AlphaLife will not use your personal data in circumstances where the impact on you outweighs its legitimate interests in processing your personal data.

To comply with law

• To manage AlphaLife legal obligations related to compliance laws, including but not limited to anti-corruption laws, applicable export laws, trade sanctions, and embargoes issued, by EU, UK, the U.S. and other countries, if any. This may include (i) conducting automated checks of any user registration data identified in this Privacy Policy and other information you provide about your identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when you update your information; (iii) blocking of access to Services in case of a potential match; and (iv) contacting you to confirm your identity in case of a potential match;

• To comply with lawful requests and legal process such as to respond to subpoenas or requests from government authorities as detailed hereinafter.

How Long Your Personal Data is Retained

AlphaLife does not store your personal data for more time than necessary and only as long as required to fulfill the purposes set out above. Retention periods may vary depending on the data categories and the processing activities. To determine the appropriate retention period for personal data, AlphaLife (or AlphaLife’s customer as the controller, as applicable) considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which AlphaLife processes your personal data and whether AlphaLife can achieve those purposes through other means, and the applicable legal requirements:

• where you gave your consent, until you withdraw it;
• where AlphaLife has entered into an agreement with you or your employer, as long as the agreement is into force plus the applicable local statutes of limitations;
• where AlphaLife has a legitimate interest in using your personal data, for a limited period of time appropriate to ensure a fair processing of your personal data or until you object to AlphaLife’s use of your personal data, subject to AlphaLife’ compelling legitimate grounds for continued processing which override your interest in objecting or for the establishment, exercise or defense of legal claims;
• where AlphaLife is required to comply with a legal obligation, the retention period will be determined according to the applicable law;
• Where your personal data is required to assert or defend against legal claims, AlphaLife will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.

At the end of the retention period, your personal data will be deleted or anonymized using processes and methods in accordance with applicable data protection standards.

With Whom AlphaLife May Share Your Personal Data

AlphaLife does not rent or sell information but may share your necessary personal data for certain business purposes with the following categories of organizations:

• Within AlphaLife Sciences Group: AlphaLife Sciences Group is a multinational business, located in Asia, America, and Europe to provide you with responsive and proactive services. In that globalized context, AlphaLife may need to share your personal data for purposes consistent with this Privacy Policy (e.g., to provide you with customer supports).

• With organizations in the specific projects that you are working for by using our Services. Those organizations usually include the sponsors, contract research organizations (CRO), clinical trial institutions, drug regulatory authorities or corresponding registration and approval agencies. AlphaLife may share your personal data with those organizations for purposes providing our Services to you and your employer.

• With AlphaLife trusted partners

  • AlphaLife business partners

AlphaLife may share your personal data with AlphaLife business partners such as resellers assigned to you to provide you or your employer with appropriate offers or Services.

• Third parties acting on AlphaLife behalf: AlphaLife may engage third-party companies and individuals where necessary and share your personal data with them in the course of the services that they render to AlphaLife, to administer and provide the Services on AlphaLife’ behalf (such as customer support, hosting, email delivery and database management services). These third parties will use your personal data only as directed by AlphaLife and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your personal data for any other purpose.

• With third parties to comply with applicable laws: AlphaLife may, depending on the applicable law, disclose some of your personal data to government or law enforcement officials or private parties, (a) if AlphaLife believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order), (b) enforce the terms and conditions that govern Services, (c) protect the rights, property, or safety of AlphaLife, AlphaLife’s customers, or the public and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. AlphaLife will review the requests to make sure they satisfy applicable laws. If a request asks for too much information, AlphaLife will try to narrow it, and if possible, will object to producing any information at all.

• With third parties to serve or protect AlphaLife legal and business interests: AlphaLife may sell, transfer or otherwise share some or all of its business or assets, including your personal data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, or a change of control or a total or partial liquidation of AlphaLife, in which case AlphaLife will make appropriate efforts to require the recipient to honor this Privacy Policy.

International Data Transfers

When you access the Services where AlphaLife acts as the data controller, if you are located in a different country than the country (the U.S.) where the datacenter hosting our Services are deployed, by continuing to use the Services, you consent to the transfer of your personal data to a country outside of your own where local privacy laws may not afford an equivalent protection as those in your jurisdiction. Depending on the jurisdiction of your residence, we may employ contractual tools (such as the Standard Contractual Clauses as formulated by the European Commission or UK’s International Data Transfer Agreement) or certify to the relevant governmental authority (such as via the EU-U.S. Data Protection Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF) to ensure an essentially equivalent level of personal data protection as your resident jurisdiction. You enjoy the right to know whether, and how your data is internationally transferred. You may contact us for details via the means provided in Section “ How You Can Contact Us” below, and we will promptly process your requests.

When you access the Services where AlphaLife acts as the data processor on behalf of our customers (the data controller), you enjoy the right to know whether, and how your data is internationally transferred. You may contact us for details via the means provided in Section “ How You Can Contact Us” below, and we will promptly relay your request to the data controller.

What Are Your Rights with Respect to Your Personal Data

Depending on the applicable data protection laws, you may have some or all of the following rights with regard to your personal data:

• access your personal data;
• obtain a copy of your personal data stored by AlphaLife;
• request the rectification, completion, update or erasure of your personal data;
• restrict processing;
• object to specific processing of your personal data if that processing is based on legitimate interests;
• data portability; and
• If the processing of your personal data is based on your consent, you have a right to withdraw that consent at any time (e.g. opt-out or unsubscribe from marketing communications).

If you have an end-user account, you can exercise some of your rights by logging on to your account. Otherwise, you may exercise your rights by submitting your request here: https://go.alphalifesci.com/privacy-complaint

Depending on the scope of the request, and if permitted under applicable law, AlphaLife may charge a reasonable fee to cover costs incurred in connection with such request. AlphaLife may deny access to your personal data in limited circumstances in accordance with applicable laws and regulations.

AlphaLife may request specific information from you to confirm your identity or process your request. Applicable laws may require or permit AlphaLife to decline your request but in all cases, AlphaLife will provide you with an explanation of its position, subject to legal restrictions.

How We Protect Your Personal Data

AlphaLife maintains appropriate technical and organizational measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction during transmission and once in its possession.

AlphaLife manages and regulates the storage and use of personal data by establishing a data classification system, data security management specifications, and data security development specifications. We use confidentiality agreements, monitoring, and auditing mechanisms to control and safeguard data security.

AlphaLife only allows employees and other authorized personnel who need to know your personal data to access relevant information. AlphaLife also requires all personnel who may have access to your personal data to comply with their corresponding confidentiality obligations.

However, while AlphaLife strives to protect your personal data, in light of the inevitable risks linked to the Internet, AlphaLife cannot guarantee full protection against any leak.

It is important for you to exercise caution to prevent unauthorized access to your personal data. You are responsible for the confidentiality of your password and information appearing on your account. Consequently, you must ensure that you log out of your session in the event of shared use of a computer.

In the event of a data security incident, we will promptly notify you in accordance with the applicable data protection laws, the notification may contain the basic information and possible impact of the security incident, the disposal measures we have taken or will take, and the risk mitigation suggestions, etc. We will notify you of the security incident by email, letter, telephone, push notification, etc. When it is difficult to notify every end-user one by one, we will adopt a reasonable and effective way to publish an announcement.

Cookies and Similar Technologies

Cookies used by AlphaLife

In order to improve your browsing experience on our Services or Sites, AlphaLife uses cookies or other similar technologies that may process your personal data.

Depending on the Services, AlphaLife uses different types of cookies:

• Strictly necessary cookies are always used; as they are essential for you to properly use the Services and cannot be switched off. For example, they allow you to save your personalization settings (choice of language, presentation of a service).

• Functional cookies are used in order to improve the performance of the Services, to provide you with optimized features and a more personal experience by collecting information when you use Services. Functional cookies also include analytics and performance cookies that are used to collect information about the traffic to our Sites and how users use our Services. The information gathered may include the number of visitors to our Sites, the websites that referred you to our Sites, the pages you visited on Sites, what time of day and duration you visited you Sites, whether you have visited our Sites before, and other similar information. AlphaLife uses this information to help operate Sites more efficiently, to gather broad demographic information and to monitor the level of activity on Sites or Services.

Disabling Cookies

You can remove or reject functional and advertising cookies at any time through the cookies banner. However, if you do not accept certain cookies, some functionalities and features of the Services may not function properly, and you may experience some inconvenience in their use. For example, AlphaLife may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites or access to our Services.

How You Can Contact Us

AlphaLife is committed to ensuring the privacy of personal data: You can contact the AlphaLife here: https://go.alphalifesci.com/privacy-complaint if:

• you have any questions about this Privacy Policy;
• you encounter any issue when having access to your personal data or related to your rights as described above;
• you believe that AlphaLife is not complying with the applicable local data protection laws;
• you have a reason to believe that the security of your personal data has been compromised or misused.

When you want to report a claim by lodging a complaint to the AlphaLife, in addition to the means above, you may also send a letter to the address mentioned at the end of this Policy, we may request additional information as reasonable to prevent identity fraud.

If your usual place of residence is in the UK, you have a right to file a complaint with ICO. If your usual place of residence is in the European Economic Area, you have a right to file a complaint with your local data protection authority.

Changes to Privacy Policy

AlphaLife reserves the right to modify and update this Privacy Policy at any time in accordance with AlphaLife requirements and circumstances, or where required by applicable laws and regulations. AlphaLife encourages you to periodically review this page for the latest information on its privacy practices. If major changes occur to this Privacy Policy, AlphaLife may inform you via email or another manner that AlphaLife believes reasonably likely to reach you. This may include posting a specific announcement on our Sites or sending notices through our Services.

Any modifications to this Privacy Policy will be effective upon AlphaLife posting of the new terms and/or upon implementation of the new changes in the Services.

Additional Country or Regional Terms

Depending on where you are living, some additional terms as detailed below may be applicable to you. Where the Privacy Policy refers to “personal data”, it shall be interpreted, as applicable, to mean “personal information” as defined by the applicable data protection law.