For purposes of this Policy, the following definitions shall apply:
Any customer of Trifecta (Pharmaceutical Industry Sponsor / CRO), located in the EEA that has purchased our training and communication tool as a service.
Trifecta Multimedia LLC DBA Trifecta Clinical®, its predecessors, successors, and subsidiaries in the United States.
Any information or set of information that is required by Trifecta (Name, Employment Title, Division or Place of Employment, and Employment Email Address) for the purpose of entering Client in Trifecta system and provide access for the Trifecta on line training and communication tool. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
Any third party that uses personal information under the instructions of, and solely for, Trifecta.
AFFIRMATIVE COMMITMENT TO PRIVACY SHIELD FRAMEWORK
USE OF PERSONALLY IDENTIFIABLE INFORMATION
Trifecta is provided by its Client minimal employment related personally identifiable information in order to provision you in the Trifecta system and provide you access to the system. The personally identifiable information includes your Name, Employment Title, Division or Place of Employment, and Employment Email Address.
ACCOUNTABILITY FOR ONWARD TRANSFER
Trifecta does not transfer data to third parties outside of its agents. Trifecta will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Trifecta has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Trifecta will take reasonable steps to prevent or stop the use or disclosure. Trifecta is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles. Note: Trifecta may be required to disclose an individual’s personal information at Trifecta possession in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
DATA INTEGRITY & PURPOSE LIMITATIONS
Trifecta is provided by its Client minimal business information including and limited to Physicians conducting Clinical Trials and their support staff Name, Employment Title, Division or Place of Employment, and Employment Email Address). Upon approval and direction of our Clients to process such information, Trifecta will use the above stated provided information only for the purpose of provisioning in Trifecta system and providing access to the Trifecta system as authorized by Trifecta Client.
CONFIDENTIALITY & SECURITY PROCEDURES
Trifecta exercises different level of access restriction to nonpublic personal information about you to our employees in order to provide services to Client. Additionally, Trifecta maintains procedural, physical, and electronic safeguards that comply with the Federal regulations to guard your nonpublic information. The privacy policies described herein will be adhered to in the event you become an inactive as informed by Client. Trifecta is committed to protecting the confidentiality of Client provided personal information.
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, referring/exit pages, internet service provider (ISP), operating system, user conducted tasks and the associated date/time stamp. We house this information as part of the system audit trail to support Trifecta Client during their Regulatory inspections for applicable audit trail requests. At no time does Trifecta utilize this information to analyze trends, user behavior, or to gather demographic information about our user base.
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use session cookies for security. A session ID cookie expires when you close your browser. We set a session cookie at login to allow you to navigate through the many areas of our site while maintaining session data. No tracking is done using this cookie, nor is any personally identifiable information contained within the cookie.
If you reject cookies, you may not be able to use our site.
If you have questions or concerns regarding this statement, you should contact Trifecta Technical Support at 877.747.8638.
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
If your personally identifiable information changes or you want to limit the use and disclosure of your personal data, correct, or update it, you can contact Trifecta by emailing our Technical Support department at email@example.com / firstname.lastname@example.org or by contacting us via telephone or postal mail at the contact information listed below.
Trifecta Multimedia, LLC DBA Trifecta Clinical®
725 South Figueroa Street
Los Angeles, CA 90017
DISPUTE RESOLUTION COMPLAINTS HANDLING SYSTEM
In compliance with the Privacy Shield Principles, Trifecta commits to resolve complaints about our use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Trifecta at email@example.com Trifecta has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.