Alethium's Privacy Policy

Effective Date: 6/15/23

Version: 1

Introduction

The Alethium Technologies, Inc. (Alethium) is a eClinical software provider.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Alethium’s policies and practices regarding its collection and use of your personal data on our website, and sets forth your privacy rights. Our website means any of the Alethium web-pages.

By using the website or services, you agree that your information will be handled as described in this Privacy Notice, to the extent applicable. Your use of the website or cookies, and any dispute over privacy, is subject to this Privacy Notice and the possible Agreement we have with you, including its applicable limitations on damages and the resolution of disputes.

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Alethium is headquartered in West Hollywood, CA, in the United States. Alethium has appointed an internal data protection officer for you to contact if you have any questions or concerns about Alethium’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Alethium’s data protection officer. Alethium’s data protection officer’s name and contact information are as follows:

Joseph Farrell
Alethium Technologies, Inc.
1250 North Harper Ave
Suite 410
West Hollywood, CA 90046
jfarrell@alethium.health
(213) 616-7699

How we collect your personal information

Alethium collects personal information about its website visitors and customers (collectively, the “users”) directly from you, automatically through your use of the website or services and through third parties. We use this information to provide the users prospects and customers with our services.

With a few exceptions, this information is generally limited to:

name
job title
employer name
work address
work email
work phone number
internet protocol (IP) addresses, the region or general location of electronic devices accessing the internet
browser type, operating system and other usage information about the use of Alethium’s website, including a history of the pages users view.

Information We Collect Directly From You

We collect information from you when you request information from us or otherwise interact with our website. The type of information that we collect from you depends on your particular interaction with our website and may include, without limitation, your name, address, and email address, and any other information that you choose to provide to us.

Information We Collect Automatically

We and our third party service providers automatically collect, process and use information about you through the use of cookies and other tracking technologies (collectively, “cookies”), including:

Details of users visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, search activities as well as the page, content, software or resources that you access.

Your IP address, web addresses of the sites you arrive from and go to next and information about your connection, including your device’s browser, operating system, platform type and Internet connection speed. We use this information for operational and performance measurement purposes and to regionalize certain contents of the website.

Details of transactions and orders, your history of correspondence with us, quote requests or inquiries or when you contact customer service or technical support.

We use this information to help us design our website to better suit our users’ needs. We may also use the collected IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Information We Collect About You From Third Parties

From time to time, Alethium receives personal information about individuals from third parties to publish our advertisements or to analyze your interest in our website. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party parties such as Google Adwords, Google Analytics and LinkedIn.

How we use (process) your personal information

Information about our current and potential customers is an integral part of our business. Our primary goal in collecting personal information is to deliver a smooth, efficient and personalized experience when using our website and services. This allows us to provide you with the information, services and features that are most likely to meet your needs. We use your information, including your personal information, for the following purposes:

To provide login access, to facilitate the features on our website, to
communicate with you about your use of our website, to respond to your inquiries, to manage your account, to send you information that you have requested, and for other customer service purposes.
For marketing and advertising purposes. For example, as permitted by applicable law, we may occasionally contact you by e-mail, postal mail, or telephone to provide you with information about other services that might be of interest to you.
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the websites.
We automatically track certain information about you, based upon your behavior on our website. We use this information to conduct internal research on our user and visitor demographics, interests and behaviors, and to offer more personalized content. The information we collect from you and about you is used as follows:
- To ensure that content from our website is presented as optimally as possible for you, your computer and your web browser.
- To measure and improve the website’s performance and usability, its contents, services and features as well as to personalize your overall experience
- To send you information based on your relationship or transactions with us, notify you about changes to our products or services.

Alethium has a legitimate interest in understanding how members, customers and potential customers use its website. This assists Alethium with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs. We will only collect and process your information when we have a legal basis to do so. You also have choices about our use of your information as explained in this Privacy Notice.

Cookies and tracking technologies

Alethium makes available a comprehensive Cookie Policy that describes the cookies and tracking technologies used on Alethium website and provides information on how users can accept or reject them. To view the notice, just click here.

How do we disclose your information?

We do not sell personal information to anyone. We do not share your information with non-affiliated third parties for their own marketing purposes. We do share your information with third parties who are facilitating the delivery of our services; as follows:

To Our Affiliates. As permitted by applicable law and as contractually agreed between us, we may share your personal information with our affiliated entities. Those entities may market their products and services to you, but their use of your personal information will be governed by this Privacy Notice.
Service Providers. We may share your information with other third party service providers to assist us in providing our website to you and/or responding to your requests.

We also may share your information in the following circumstances:

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company. We also may transfer our rights under any client agreement we have with you.
In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the agreement between us or this Privacy Notice, or as evidence in litigation in which we are involved.
Aggregate and Anonymous Information. We may share aggregate or anonymous information about users with third parties for research or similar purposes.
Legal Purposes. To enforce our rights, as required by law or when we believe that disclosure is necessary to protect our rights.

The Alethium website connects with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Alethium website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our website to your personal data.

Sharing information with third parties

To facilitate the provision of our website or services, we may enlist the assistance of data processors who have access to specific information (referred to as “Subprocessors”).

To ensure adherence to relevant regulatory requirements, we carefully evaluate the legality, suitability, and proficiency of all Subprocessors involved in data processing activities. The following outline provides a brief overview of the approved Subprocessors that we may employ to handle users’ personal information . Please note that this list is subject to change at Alethium’s discretion.

Subscribe for subprocessor updates:

Processor	Purpose	Processing Location	Privacy Policy
Amazon Web Services	Infrastructure Hosting	US	https://aws.amazon.com/privacy/
Zendesk	Support Ticket Tool, In-application Support Chat	US
Loom	Support recordings (customer optional)	US	https://www.loom.com/privacy-policy
Google	Support Ticket Email Processing Document Retention	US	https://policies.google.com/privacy?hl=en-US
Twilio Communications Platform	Televisit instance messaging and connectivity management	US	https://www.twilio.com/en-us/privacy
Hubspot	Customer data retention		https://legal.hubspot.com/privacy-policy
Stefanini Group	Customer Support	BR	https://stefanini.com/en/privacy-policy
Cognito, LLC	Customer Support	US	https://www.cognitoforms.com/legal/privacy
Calendly	Appointment Scheduling	US	https://calendly.com/privacy

Transferring personal data to the U.S.

Alethium has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Alethium’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, Alethium is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, Alethium also collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Alethium in a manner that does not outweigh your rights and freedoms. Alethium endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Alethium and the practices described in this Privacy Statement. Alethium also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Alethium has received zero government requests for information.

For more information or if you have any questions, please contact us at privacy@alethium.health

Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

Right to be informed
Right of access
Right to rectification
Right to erasure
Right to restrict processing
Right of data portability
Right to object
Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data Alethium collects about you and how it is used.

If you wish to confirm that Alethium is processing your personal data, or to have access to the personal data Alethium may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Alethium might have received the data from Alethium ; what the source of the information was (if you didn’t provide it directly to Alethium ); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Alethium if it is inaccurate. You may request that Alethium erase that data or cease processing it, subject to certain exceptions. You may also request that Alethium cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Alethium processes your personal data. When technically feasible, Alethium will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Alethium will provide you with a date when the information will be provided. If for some reason access is denied, Alethium will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at privacy@alethium.health. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

Alethium and US State Laws

California Residents
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), California residents have rights which impact how their personal information is being processed.

As described in this Privacy Notice, we collect various types of personal data about you in order to fulfill specific business, legal and compliance purposes. We do not use personal data for commercial purposes.

Subject to the exceptions detailed in the CCPA, as a California resident, you have the right to request: (i) deletion of your personal information; (ii) correction of inaccurate personal information; (iii) to know / access the categories of personal information that we collect about you, including the specific pieces of personal information; and (iv) to know the categories of personal information disclosed for a business purpose.

Submitting a Request
You may ask us to disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your identify as a user of our services, we can disclose that information to you. You may also make a request to have that information erased or deleted.

You may make these requests by emailing us at privacy@alethium.health or you may complete this request form.

You can make a request for your information twice every 12 months. If you are making an erasure request, it will help us if you include details of the information you would like erased. We may need to ask you for additional information to fully identify you. If we are not able to identify you, we may not be able to erase your information.

Please note that if you request that we remove your information, we may retain some of the information for specific reasons, such as to resolve disputes, troubleshoot problems and as required by law.

Furthermore, some information is never completely removed from our databases due to technical constraints and the fact that we regularly back up our systems. Therefore, not all of your personal information will ever be completely removed from our database.

We will respond to you on these requests as quickly as we have received your note but it may take us up to 45 days. If we need more time than that, we will let you know.

You also have rights under each of the VA Act, CO Act, CT Act and UT Act
a) The Virginia Consumer Data Privacy Act and any regulations, amendments and/or updates thereto (the “VA Act”);
b) The Colorado Data Privacy Act and any regulations, amendments and/or updates thereto (the “CO Act”);
c) The Connecticut Act Concerning Personal Data Privacy and Online Monitoring and any regulations, amendments and/or updates thereto (the “CT Act”); and
d) The Utah Consumer Privacy Act and any regulations, amendments and/or updates thereto (the “UT Act”);

As a user of Alethium, you can request that we provide you with the following:

conduct and document data protection assessments about Alethium;
ask Alethium to demonstrate Alethium’s compliance with its obligations under each of the US State Laws mentioned above;
request that Alethium implements appropriate technical and organizational measures; and to assist you in the event of a data security and/or data breach notification.

Data storage and retention

Your personal data is stored by the Alethium on its servers, and on the servers of the cloud-based database management services the Alethium engages, located in the United States. The Alethium retains service data for the duration of the customer’s business relationship with the Alethium and for a period of time thereafter, to analyze the data for Alethium ’s own operations, and for historical and archiving purposes associated with Alethium ’s services. Alethium retains prospect data until such time as it no longer has business value and is purged from Alethium systems. All personal data that Alethium controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@alethium.health

Children’s data

We do not knowingly attempt to solicit or receive information from children.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
Alethium Technologies, Inc.
1250 North Harper Ave
Suite 410
West Hollywood, CA 90046
privacy@alethium.health
Subject Access Request Form
(213) 616-7699

Privacy Policy

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