This Personal Data Notice and Consent form describes how Citeline (“Citeline “we”, “our” or “us”) may collect, use, share and transfer your personal data (i.e., any data that identifies you, including sensitive personal data) in the following circumstances:
Such online membership communities are referred to herein collectively as the “Online Community”
This document also explains your rights as a data subject. Please carefully review the information below.
Citeline determines the purposes and means of using your personal data. You may contact contact Citeline by emailing our Privacy team at privacy@norstella.com.
The following personal data is collected as part of your participation in the Online Community:
The following personal data is collected as part of the Survey:
In addition to the personal data collected as described above, the following sensitive personal data is collected as part of the Survey:
If you wish to take part in the Survey, it is necessary for this sensitive personal data to be collected so that your eligibility to participate in certain Studies can be determined and Sites may contact you about enrolling in certain Studies.
In connection with the Online Community, Citeline will process your personal data. Citeline does not share your personal data with Sponsors in connection with the Online Community. Citeline does share non-identifiable aggregated data with Sponsors so that that they may send communications to Online Community members who have opted to receive such communications as outlined at the top of this notice. You may opt out of the Online Community marketing communications at any time by following the link in the footer of any marketing email you receive.
In connection with the Survey, if your responses to the Survey indicate you are a potential candidate for a Study and you would like to be considered for the Study, you will have the option to provide your contact information and share your Survey answers with Citeline and with various Sites. If you elect to share your personal data with a Site and are contacted directly by a Site, you will receive the name of the Sponsor of the Study for which you are being considered and the Sponsor’s contact details. Please note that the Sponsor is an organization which separately determines purposes and means of collecting, using and sharing your personal data; as such, the Sponsor may provide you with its own personal data notice, which may include information regarding its data protection officer and how to contact that person.
We also share your personal data:
If you decide that you would not like Citeline to share any of your personal data in connection with the Survey, simply exit the Survey without submitting it. We will retain certain responses, but this data is anonymous.
In connection with the Online Community, personal data is collected, used and shared for the following reasons:
In connection with the Survey, personal data is collected, used and shared for the following reasons:
In connection with the Online Community, your personal data will be kept by us for as long as you participate in the Online Community, unless we need to retain your personal data for a longer period to meet our legal requirements. In these cases, we will retain your personal data only for the period necessary for us to pursue the relevant purpose.
In connection with the Survey, your personal data (should you choose to provide it to us) will be kept by us for 12 months from collection of the personal data from you, unless we need to retain your personal data for a longer period to meet our legal requirements. In these cases, we will retain your personal data only for the period necessary for us to pursue the relevant purpose.
We collect, use and share your personal data based on the following grounds and as permitted by applicable laws and regulations:
Under China’s Personal Information Protection Law (“PIPL”), you may make the requests and exercise the rights listed below, and Citeline will review and respond to any of the following types of requests or exercise of rights as required by the PIPL:
If you would like to make any of the requests or exercise any of the rights noted above, please contact us (see “How can you contact us?” below). We will make reasonable efforts to honor your request whenever feasible and in all cases we will respond to your request as required by applicable laws and regulations. In your request, please make clear what personal data your request relates to.
You may also contact applicable regulatory authorities with any concerns about the collection, use, or handling of your personal data.
You are not obligated to provide Citeline with your personal data and the collection of your personal data by Citeline is not required by law, however, if you choose not to provide Citeline with your personal data this will mean that you cannot participate in the Online Community, receive information about Studies or be connected by Citeline to Sites for potential participation in Studies.
For purposes of the Online Community and the Survey, Citeline intends to transfer your personal data from China to the United States. Laws in the United States may differ from those in China and your personal data may therefore be subject to different legal protections once it is transferred to the United States. In any event, Citeline will use reasonable and appropriate measures to handle your personal data in accordance with the PIPL.
If you have any questions about this Personal Data Notice and Consent or about the way we use your personal data, or if you would like to submit a request to us, please contact us at privacy@norstella.com.
I acknowledge that I may withdraw my consent at any time by contacting Citeline’s Privacy team by contacting privacy@norstella.com.