SUVODA App PRODUCT PRIVACY POLICY AND TERMS OF USE

Suvoda LLC, a U.S. company with corporate domicile at 181 Washington Street, Suite 100, Conshohocken, PA 19428, USA, and its subsidiaries (hereinafter collectively referred to as "Suvoda", "We", "Our") provides clinical trial software products including, without limitation, Suvoda's interactive response technology (IRT), Drug Inventory Management System (DIMS), electronic informed consent (eConsent), electronic clinical outcomes assessment (eCOA), and electronic patient (ePatient) solution and related services (our "Services"). In the course of providing the Services We collect and process information about our clients, users of our Services and clinical trial data subjects and/or the caregivers of clinical trial data subjects. Some of such information is personal information, and could be related to an identified or identifiable natural person (the "Personal Information"). This privacy policy and terms of use (the "Terms") explains how and what We, as data controller, collect, use, share and protect such Personal Information about you as someone who uses the Services. It also explains the terms and conditions to which you agree if you access or use the Services as well as what choices you may have in connection with this collection, use and sharing of information. These Terms do not govern use of the www.suvoda.com website. Those terms may be found at http://www.suvoda.com/privacy-policy.

By using the Services you are hereby informed of the scope of these Terms. We encourage you to read them carefully.

By accessing or using the Services, you agree to be bound by these Terms. If you do not agree, please immediately discontinue accessing the Services.

User Conduct

In using the Services, you agree:

Not to attempt to access any part of the Services which you are not authorized to access or to circumvent any use restrictions put into place to prevent certain uses of the Services or Hardware;
Not to disrupt or interfere with the security of, or otherwise abuse, the Services, system resources, accounts, servers, or networks connected to or accessible through the Services;
Not to use or attempt to use or access another person's account or Personal Information, or create or use a false identity on the Services;
To keep your credentials confidential and not to allow any unauthorized user to access the Services using your credentials;
Not to upload, post, or otherwise transmit through or on the Services any viruses or other harmful, disruptive, or destructive files;
Not to decompile, reverse engineer, reverse assemble, decipher, or otherwise attempt to discover any programming code or any source code used in or with the Services or Hardware or otherwise distribute in any way any content on the Services or the Hardware;
Not to modify, store, copy, distribute, transmit, display, perform, reproduce, publish, license, transfer, post, translate or scrape any content without our prior written permission.
To observe and comply with all Applicable Laws, Codes of Practice and any instructions or conditions notified to you by Suvoda or the Sponsor. "Applicable Laws" means local, national and international legislation, enactment, subordinate legislation, rule, regulation, order, directive or other provision, or requirement of a regulatory authority (or persons authorized on their behalf) and any judicial or administrative interpretation or application thereof, which has, in each case, the force of law in the jurisdictions in which the Services are provided and/or utilized. "Codes of Practice" means all guidelines governing use or provision of mobile telecommunications and data services that are issued by any generally recognized bodies or that are adopted by Suvoda or its third-party providers from time to time.
Not to act or omit to act in any way in connection with your use of the Services which will or may place Suvoda or any other third party in breach of any provisions of Applicable Law or a Code of Practice, any other licenses, authorizations, and to cooperate fully with Suvoda and its third-party providers to enable them to comply with all of the same.
Not to use the Services for any improper or unlawful purpose.
Not act or omit to act in any way which will or may injure or damage any persons or the property of any persons or howsoever cause the quality of the Services to be impaired.
To contact Suvoda's support desk for support with the Services. The contact information for Suvoda's support desk can be found at: https://www.suvoda.com/contact.
Suvoda may restrict or remove your access to the Services at any time.

Information We Collect:

These Terms apply to Personal Information that We collect and process from you when you use the Services, including the following information:

Registration Information:

In order to use our Services, you will need to open an account. To do this you will need to choose login credentials. In connection with the services, you may also need to provide your email address or ohone number if you chose so. In some cases you will also need to provide your first and last name, fax number, business address, time zone, title and other business contact information, government identification number, and/or banking data.

Usage Information:

We collect and maintain information about your usage of the Services, including any actions you take in connection with the Studies to which you have access. For example:

Entering new data subjects and/or caregivers for the Study
Signing electronic informed consent documents
Completing eCOA assessments
Completing reimbursement requests
Scheduling appointments

Additionally, Suvoda may collect and provide information regarding the use of any Hardware to third parties as needed in order to provide the Services, including without limitation, software and settings of the Hardware, and information generated by the Hardware.

How We Use and Share the Information Collected:

We send the information, including Personal Information, you provide to us when you register to the Study, and, following approval by the Sponsor, when you access the Services. We may use the email address and/or phone number that you provided in order to supply you with information regarding our Services and communicate with you with respect to your use of the Services, including any maintenance issues and notifications with respect to our Terms, as well as to solicit feedback about our Services and to send you promotional materials about our Services. We may also use information about your use of the Services to improve the Services.

In addition, We may use the email address and phone number that you provide to send you notifications related to the Study you are accessing. These notifications are sent at the request of the Sponsor.

Purpose of the Use of Information:

In addition to the above, Suvoda may use the information it collects, including Personal Information, for the following purposes:

To provide the Services to clients, users of our Services and clinical trial data subjects and/or the caregivers of clinical trial data subjects, as applicable, to fulfill our contractual responsibilities, and to comply with regulatory requirements;
To contact clients, users of our Services and clinical trial data subjects and/or the caregivers of clinical trial data subjects by phone, mail, email, and other electronic means of communication, as applicable, regarding the Services;
To send business communications, including by electronic means such as emails, regarding other products and Services for which clients may have interest;
For the specific purpose for which the information was provided;
To provide client-related Services to clients and users of our Services (to diagnose a problem related to our Services or to help manage this site);
To help improve the Services;
To prevent or detect fraud;
To fulfill the Terms of Use (http://www.suvoda.com/terms-of-use) (including protecting the rights, assets, and safety of Suvoda, its users, and others as well as protecting the content of the Services protected by copyrights);
To comply with laws and regulations or to meet the requirements of government authorities;
To analyze use of the Services.

Audit Trail

Your activities in the Services will be labeled with your user identifier, and will be associated with you to track your activities in the Services (the "Audit Trail"). This information will be retained by us even after your account is deleted or the Study on which you worked has been completed (please see the "Changing or Deleting your Information" section below). This information may be shared, along with other information in connection with the Study, with the Sponsor and/or other third parties, including regulatory authorities, as may be instructed by the Sponsor, to fulfill our contractual obligations and/or pursuant to a regulatory requirement.

Other Sharing

In addition to the uses described above, We may also share your information, including Personal Information, with third parties for the following purposes:

When you consent to the disclosure of such information
In conjunction with an audit by the FDA or other regulatory agency
To a parent company, subsidiary, joint venture, or other company under common control with us for the provision of the Services
To a service provider/contractor to perform functions and process your data, consistent with these Terms, in order to help us provide the Services
In connection with a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if We undergo bankruptcy or liquidation
Where We are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of Applicable Law
If We believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, situations involving potential threats to the rights, property, or personal safety of any person or to address technical issues
In an emergency or to protect the safety of any person
If We believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the website infrastructure or the Services generally)
To enforce these Terms and any other terms that you have agreed to, including to protect the rights, property, or safety of Suvoda, its users, or any other person, or the Services

Please see our Cookies Policy at https://www.suvoda.com/cookie-policy for information about the technologies that We and third parties use to collect information and to learn about options in connection with cookies.

Suvoda will not sell or rent your Personal Information.

Security and Information Protection

We take reasonable precautions to protect all information, including your Personal Information, applying a variety of appropriate technical and organizational measures. For example, all information, including Personal Information, entered into the Services collected by us is transferred over https, and kept on a server in a secure environment within an ISO/IEC 27001 certified data center unless and until We need to share it with third parties as set forth above. We limit access to all information, including Personal Information, entered into the Services only to employees, our affiliates, partners and any contractors who need the information to perform a specific service. Please remember that the Internet is not a 100% secure medium for communication, and We cannot guarantee that your information , including Personal Information, will always remain private when you use the Services.

Changing or Deleting Your Information; Privacy Rights

If you want to exercise your privacy rights as a data subject including, without limitation, to access and/or request an update, correction or deletion of the Personal Information We may have collected from you, please write to us at privacy@suvoda.com. Please identify yourself in such communication and provide us with sufficient information so that We can properly verify your identity. If you make such a request, We will respond to you within a reasonable time and in any case within a period of one (1) month. In particular you may exercise the following rights:

Access your Personal Information together with information about how and on what basis it is processed (to the extent that information is not set out in this notice)
Rectify inaccurate Personal Information (including to have incomplete data completed)
Erase your Personal Information in those circumstances where it is no longer necessary in relation to the purposes for which it was collected and there is no legal basis for Suvoda to retain it
Restrict processing of your Personal Information
Object to processing which has "legitimate interests" as its legal basis
Object to "automated decision making"
Obtain a portable copy of your Personal Information

If you wish to delete your Personal Information in your account, please contact the Sponsor of the Study. Upon instruction from the Sponsor, and subject to the paragraph below, We will proceed to delete Personal Information you have provided. If We delete such Personal Information, you will no longer be able to access the Services.

We may retain your information, including Personal Information, in an identifiable manner for as long as necessary to provide the Services, for as long as required by Applicable Laws and/or for as long as We reasonably believe that retaining the information is necessary to protect our legal rights or legitimate business interests or those of the Sponsor. We will retain the Audit Trail as necessary to fulfill our legal, regulatory or contractual obligations. In those cases, the Personal Information will be segregated to limit data processing and the Personal Information will be stored and retained to comply with the corresponding applicable legal, regulatory or contractual obligations.

Even if you have requested that We delete your Personal Information, keep in mind that the deletion of Personal Information by our third party providers may be performed in accordance with their internal policies and practices.

For any privacy or data protection related questions, please write to privacy@suvoda.com.

California Privacy Rights

Under California laws, California residents have certain rights with respect to their Personal Information. They can request access to or deletion of their Personal Information by contacting the Sponsor. Suvoda will not discriminate against you for exercising your legal rights.

Cross Border Transfer

Suvoda transfers, processes, and stores information about you on servers located in a number of countries, including the United States, which countries do not offer an equivalent level of protection on privacy matters that is offered in other territories such as the European Union. We may also subcontract processing to, or share your information with, third parties located in countries other than your home country.

Transfers of Information from the EEA

Suvoda complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework ("Privacy Shield") regarding the processing of all Personal Information it receives from the European Economic Area (EEA) member countries but does not rely on Privacy Shield as the sole mechanism for such transfers. You can visit our Privacy Shield certificate https://www.privacyshield.gov/list. You can learn more about the Privacy Shield Framework, by visiting the Privacy Shield website https://www.privacyshield.gov/welcome.

When We receive Personal Information under the Privacy Shield and then transfer it to third party service providers, We are liable for any processing of Personal Information by such third parties that is inconsistent with the Privacy Shield Principles unless We are not responsible for the event giving rise to any alleged damage.

Under the Privacy Shield you are entitled to access, correct, amend, or delete Personal Information about you that We hold where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. You may access, amend, correct or delete your registration information by accessing your account on the Services. You may also exercise this right by contacting us at privacy@suvoda.com.

With respect to Personal Information received or transferred pursuant to Privacy Shield, Suvoda is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In certain situations, Suvoda may be required to disclose Personal Information in response to lawful requests by public authorities, including in order to meet national security or law enforcement requirements. For more information, please see the " How We Use and Share the Information Collected " section above.

If you have any concerns or complaints regarding the processing of your personal data, please contact us as described in the "Complaints, Questions or Comments" Section below. Suvoda has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

Under certain conditions, Privacy Shield provides the right to invoke binding arbitration when other dispute resolution procedures have not provided resolution. This is described in Annex I to the Privacy Shield [https://www.privacyshield.gov/article?id=ANNEX-I-introduction]

Other Cross Border Transfers

In connection with the cross-border transfer of your Personal Information, including to the United States, your Personal Information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in the United States and other countries may have certain rights to access your Personal Information. By using the Services you are consenting to this transfer of your Personal Information.

Changes to These Terms

These Terms are subject to revisions from time to time, in our sole discretion. When We make changes We deem material We will provide you with prominent notice as appropriate under the circumstances, and you will be notified of such changes on your next log in to the system. Your continued use of the Services or Hardware after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of these Terms, please cease using the Services.

Complaints, Questions or Comments

We welcome questions and comments about these Terms. Questions or comments should be directed to:

Suvoda LLC
181 Washington Street, Suite 100
Conshohocken, PA 19428
ATTN: Privacy Officer
Phone: 1-855-788-6321
Email: privacy@suvoda.com

Suvoda SRL
10 Bld I.C. Bratianu, Floor 3, District 3
Bucharest, Romania, 011413
ATTN: Privacy Officer
Phone: +40 (31) 2265529
Toll Free: 0800-896-362
Email: privacy@suvoda.com

Last updated: 03-Jan-2024