Privacy Policy
PRIVACY STATEMENT
Plasmacure understands and respects the importance of your privacy. This privacy statement describes how Plasmacure collects, processes, stores, protects, transfers and deletes personal data. It also explains for which activities we process the data and on what legal basis we do so. The sharing of data with other parties is set out below, as well as the processing of personal data outside the EU. The security of personal data is explained, together with the retention terms. This policy also details your rights as a data subject and what you need to do if you wish to file a complaint.
Scope
This privacy statement applies to Plasmacure’s processing of personal data in the context of its establishment in the European Economic Area (the EEA). This privacy statement describes how we collect and use your personal data in connection with:
- Your registration of interest, through our website, in participating in one of our future clinical studies (Potential Participant);
- Your participation in one of our clinical studies (Participant);
- Your participation in the past in one of our clinical studies which has been finalised (Former Participant);
- Your use of our website (Online Visitor);
- Our employee recruitment processes (Applicant);
- Procurement and potential procurement matters (Vendor).
This Privacy Statement does not apply to personal information that we may collect in the context of your employment or other working relationship with Plasmacure.
The role of Plasmacure
This privacy statement is provided on behalf of Plasmacure as data controller. Depending on the clinical study, other entities may act as joint data controller in relation to your personal data. On that occasion we will provide you with the name of the joint data controller when we collect your personal information, and we will supply you with an adequate privacy notice.
Information we collect
We may collect your personal data. “Personal data” means any information relating to an identified or identifiable natural person. Depending on the nature of your contact with Plasmacure, personal data may include:
- Contact information, such as name, address, phone number of email address;
- Financial information, such as bank account number or billing address;
- Demographic information, such as postal code;
- Recruitment information, such as CV, employment history and qualifications;
- Online identifiers, such as IP address;
- Information to confirm your identity; such as a passport or identity card if we are obliged to do so by local law;
- Health data: if you participate in one of our clinical studies;
- Genetic data; if you participate in one of our clinical studies;
- Image information, if you participate in one of our clinical studies; or when you visit our premises where we use closed-circuit television (CCTV); and
- Any other information that you provide to us that can be used to identify you.
We collect personal data via:
- Your direct interaction with us, when you volunteer to participate in one of our clinical studies;
- Cookies and automated technologies, such as when you visit our websites;
- Security systems, such as when you visit our premises we may obtain CCTV footage; and
- Social media, such as our use of Facebook, LinkedIn, Twitter and other social media to market our services/products. Generally, we will not use your personal data for such purposes, but if we do so, we will only share names, email addresses and in some cases mobile phone numbers with such parties (audience targeting).
How we collect and use your personal data
| Use of your Personal data when you are: | Purpose | Categories of Personal data we may process | Source of the Personal data | Legal basis |
|---|---|---|---|---|
| Potential Participant |
|
|
You, and/or the information we receive during your participation in the study | Consent |
| Participant |
|
|
You, and/or the information we receive during your participation in the study |
|
| Former Participant |
|
|
You,and/or the information we receive during your participation in the study | Consent |
| Online Visitor |
|
|
First party cookies |
|
| Applicant |
|
|
|
|
| Vendor |
|
|
You |
|
Any other purposes for which we wish to use your personal data that are not listed above, or any changes we propose to make to the existing purposes, will be notified by amending this privacy statement in accordance with the section titled ‘Changes to this Privacy Statement’.
Sharing information
Plasmacure will not share your personal data with other third parties than carefully selected third parties that we may engage to perform services on our behalf, provided those parties agree to keep your personal data confidential and to process your personal data only on our behalf. We may also release your information when we are obliged to do so or when we in any way believe such release is appropriate to comply with the law. Plasmacure may share your personal data with any group member and with any affiliate and/or subsidiary. Plasmacure may also transfer your personal data to a purchasing company, as part of a transfer of ownership of one or more parts of its business. Please be aware that these companies may communicate with you about our products or special offers you may find useful. Please be aware that your personal data may be transferred outside the European Union. When your personal data is transferred to countries that do not ensure an adequate level of protection Plasmacure will ensure it is done in a secure and compliant manner.
We do, however, make use of various social media channels and other tools to direct you to our social media channels or website to allow you to interact with our content. These social media channels include Facebook, LinkedIn, Twitter and other tools, such as QR codes. In the event that you click on a link or scan a QR code of any of these, such social media partner or QR code provider may collect personal data about you and may link this information to your existing profile on their social media channels. Please consult our Cookie Policy for more information.
We are not responsible for the use of your personal data by a social media partner or other tool. In such case, the social media partner or tool provider will act as the controller of your personal data. In the event that you have any questions, you are welcome to contact the social media partner or tool owner directly.
Safeguarding information
We recognize our responsibility to protect the data you entrust to us. Plasmacure uses a variety of secure techniques and organizational measures to protect your data. Our employees are required to respect your privacy at all times. When we engage third parties to perform services on our behalf, we protect the confidentiality of your personal data through contractual arrangements.
Retention of personal data
We will retain your personal data for as long as is necessary in order to fulfil the purposes for which we collected it, including any legal requirements. To determine the retention period, we take the following into account:
- Whether we are subject to any legal obligation, such as the regulation on Clinical Trials and the Dutch Medical Treatment Act (CCMO);
- Whether retention is required considering our legal position (such as for statutes of limitations, litigation or regulatory investigations); and
- The length of time that we have an ongoing relationship with you, and provide our services to you (for example, for as long as you are subscribed to one of our newsletters).
If we have not had any meaningful contact with you during a period of 5 years, we shall delete your data, unless the law or relevant regulators require us to retain it for a longer period of time.
If you are a website visitor, the retention period at user level and for events associated with cookies, user IDs and advertising IDs can be found in our cookie statement.
At the end of the retention period, we will delete your personal data in a manner designed to ensure that it cannot be reconstructed.
How to exercise your privacy rights
You have the following rights with regard to your Personal Data:
- Right to access information about how we process your personal data, including the categories of personal data we process, recipients of your Personal Data, and purposes for our processing.
- Right to rectification of inaccurate Personal Data concerning you, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Data completed.
- Right to erasure (deletion) of Personal Data concerning you where: (a) the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw your consent and there are no other legal grounds for the processing; (c) you exercise your right to object (see below) and there are no compelling legitimate grounds for the processing; (d) the Personal Information has been unlawfully processed; or (e) the Personal Data have to be erased for compliance with a legal obligation applicable to us. Please note that the obligations of clinical trials legislation may impede the exercise of certain rights in order, for example, to maintain the integrity of clinical trial data.
- Right to restriction of processing (i.e., data will be blocked from normal processing but not erased) where: (a) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy; (b) the processing is unlawful and you oppose the erasure of the Personal Data and requests the restriction of their use instead; (c) we no longer need the Personal Data for the purposes of the processing but they are required by you for the establishment, exercise or defence of legal claims; (d) you exercise your right to object (see below) pending the verification of whether our legitimate grounds override yours.
- Where processing is based on your consent, the right to withdraw consent at any time, without affecting the lawfulness of the processing prior to such withdrawal. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your Personal Data in some limited circumstances. Please note that the obligations of clinical trials legislation may impede the exercise of certain rights, for example, in order to maintain the integrity of clinical trial data. If you are or have been a participant in a clinical trial, you have been provided with additional, study-specific information by Plasmacure.
- Where processing is based on your consent, or on a contract, the right to data portability, i.e. the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from us.
- Right to object to the processing of Personal Data based on our legitimate interests, provided that there are no compelling legitimate grounds for the processing that would override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
After your written request you will have the possibility to look into your personal information. Please note that we may ask you to verify your identity before responding to such requests. We will send you a summary of your personal information. If this summary contains any inaccuracies, you can request in writing to alter or remove your personal information. This written request can be sent to the following address:
Plasmacure
Transistorweg 5
6534 AT Nijmegen
The Netherlands
privacy@plasmacure.nl
Once you have provided personal data to Plasmacure, you have a right to reasonable access, so that you can verify, update and/or modify your personal data. You may also request us to delete your personal data or to restrict the processing of your information. You also have the right to object to the processing of your information, to withdraw your consent or to export your information to another service. You can send your personal data access request to privacy@plasmacure.nl. We encourage you to keep your personal data up-to-date.
Monitoring of Data Protection Compliance
The Data Protection Officer (DPO) advises and informs Plasmacure on data protection, and monitors data protection compliance at Plasmacure. The DPO can be reached via: privacy@plasmacure.nl.
If you believe that Plasmacure does not comply with the above rules or does not do so adequately, or if you want to submit a complaint, please contact the DPO.
Alternatively, you can submit a complaint to the Autoriteit Persoonsgegevens (AP). This is the Dutch independent supervisory body that monitors compliance with the statutory rules for the protection of personal data. You can contact the AP at:
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag
Tel.: +31 (0)88 1805 250
The Netherlands
Changes to this Privacy Statement
We explicitly reserve the right to change or alter this Privacy Statement. Any changes will be published on this website. This Privacy Statement was last updated in December 2023.
