Effective date: February 21st, 2020
Saama provides Services and tools that allow Clients to analyze and report on clinical data pulled from multiple, disparate data sources through a single interface. These tools and Services are not a part of Our corporate website. Saama serves as a data processor for Our Clients who use these tools and Services. More specifically, Saama does not own the information that is submitted to Us through the Services and tools. The information that is submitted through Client Services relationships will be held subject to the lawful requirements specified by the Clients.
Processing of EU Data
Saama is committed to complying with GDPR with respect to all personal data received from natural persons from European Union (EU) member countries.
If You are one of such persons and wish to review, update or delete your Personal Information obtained through Your access to and use of the Saama Website, or take it with You, please email us at firstname.lastname@example.org.
If You wish to review, update or delete Your Personal Information obtained through Your access to and use of the Saama Services, please contact the Saama Client who authorized Your access and use of the Services. To learn more about the GDPR, visit the GDPR Home Page https://www.eugdpr.org/.
Saama is responsible for the processing of personal data it receives, under the GDPR, and may subsequently transfer such personal data to a third party acting as an agent on Saama’s behalf. Saama complies with GDPR for all onward transfers of personal data from the EU.
EU – U.S. Privacy Shield: Transfer of Personal Information
Saama participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Saama adheres to the Privacy Shield Principles. Saama is committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List: https://www.privacyshield.gov/list
Saama is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf in accordance with Saama’s contractual obligations with its customers. Saama complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Saama is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Saama may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact EU Data Protection Authorities (EU DPAs) – our independent recourse mechanism.
EU Persons may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework at https://www.privacyshield.gov.
Collection and Use of Personal Information through Saama Client Services and Website
You may visit the websites of Saama without revealing any Personal Information. However, in some instances, Saama may require certain Personal Information, such as business contact information, email address, or phone number, to respond to Your inquiries or provide You with requested information.
We also collect information provided by Our Clients to provide Our Services to those Clients. This information may include Personal Information about individuals, including health information collected as part of clinical trials. Saama will use this information as directed by Our Clients and for service-related purposes.
Saama collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If You are a customer of one of Our Clients and would no longer like to be contacted by one of Our Clients that use Our Service, please contact the Client that You interact with directly. We may transfer Personal Information to companies that help us provide Our Services. Transfers to subsequent third parties are covered by the commercial agreements with Our Clients.
If a Client adds a user to their business or enterprise account, We will ask the Client for the user’s name and email address. We will automatically send the Client’s user a one-time email inviting him or her to visit a designated site for the collection of business information. Saama does not store this information, except to the extent permitted by law, and will only use it for the specific reason for which it was provided. If a person believes that a Client has provided Us with Your personal information and You would like to request that it be removed from Our database, please contact us at email@example.com.
Because of the nature of the Services, Saama operates as a data processor for Our Clients. Saama’s Clients are the data controllers as to the personal data collected when Saama is performing the Services. Individuals involved in clinical studies may interact directly with Saama’s Clients rather than with Saama. Saama maintains only the Personal Information Our Clients have asked Saama to process. It is the Saama Clients’ responsibility to ensure that the data the Client collects can be legally collected in the country of origin. The Saama Client is responsible for giving its employees and customers the appropriate level of notification that Personal Information is being collected and maintained.
We may anonymize and aggregate Personal Information collected through the Websites, tools, and Services, and use it for any lawful purpose.
Saama may automatically receive and record certain non-Personal Information from website users and the users of its tools and Services. Saama may use this information to provide certain functionality, improve the tools and Services, and monitor the use of the tools and Services.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to access the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at firstname.lastname@example.org.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at email@example.com.
Information Sharing and Disclosure
Saama may disclose Personal Information to its agents and partners who assist Saama in providing services to Clients. We will share Personal Information for such purposes only with third parties whose privacy policies are consistent with Ours or who agree to abide by Our policies with respect to Personal Information. If You do not want us to share Your Personal Information with these companies, You may contact us at: firstname.lastname@example.org.
Saama may otherwise disclose Personal Information when:
- We have express consent to share the Personal Information for a specified purpose;
- We are required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security, subpoenas, court orders, law enforcement requests, or such other legal process;
- We need to protect the personal safety of the users of Our systems or defend the rights or property of Saama; or
- We are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of the Services to another provider.
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