Proteus Digital Health, 2600 Bridge Parkway, Suite 101, Redwood

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Proteus Services Privacy Policy
Proteus Digital Health, Inc. and/or its subsidiaries and affiliates (“Proteus” or “we”) provides
the InForm Medication Adherence Insights Service (the “Service”) as described in the Proteus
Clinical Services Agreement. The Service is offered as a product to companies that sponsor
human clinical trials (the “Customer” or “you”). This Privacy Policy applies to the information
of Customer that is made available to Proteus in connection with the Services or third party
information that Customer permits Proteus to access or collect in connection with the Services
(collectively, “Information”), including medical information and data pertaining to clinical trial
subjects (“Subjects”). Proteus treats Information according to the terms of this Privacy Policy,
and treats Information as confidential in accordance with the terms of your order for Services.
This Privacy Policy provides you with details of Proteus’ privacy practices, including:
What Information is collected when you use the Service;
How Information will be used and disclosed; and
Your rights with respect to collection and use of Information.
Please read this Privacy Policy carefully. By using the Service you expressly consent to the
collection, use and disclosure of the Information in accordance with this Privacy Policy.
As described in the Proteus Clinical Services Agreement, you will be responsible for ensuring
that each Subject provides appropriate authorizations and/or waivers under HIPAA and/or other
applicable privacy laws.
1. What information will Proteus collect and how will that information be used?
In this Privacy Policy, ‘Your Information’ includes all of the following:
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the information Customer provides to us when Customer contracts for the InForm
Medication Adherence Insights service (e.g., specifics of the clinical trial design,
specifics about the study drug).
the information relating to Subjects engaged in Customer clinical studies that is generated
by the Service when it is used (e.g., information about when Subjects take study
medications, activity levels, rest patterns, other physiologic metrics, patch connection to
the body and the Service, patch battery status, etc.);
the information generated when you or Subjects contact the Support Line or us (for
example with a question about the Service) or if we contact you in connection with the
Service; and
We may monitor and record calls and messages from you, Subjects, or other clinical trial
participants, such as clinical trial sites or clinical research organizations, for training and quality
purposes.
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Proteus will use the Information to:
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provide you with the Service;
contact you about the Service with administrative/service related notices;
investigate, and assist you with, any questions or complaints that you may have about the
Service;
analyze your use of the Service;
analyze the performance of the Service;
enhance the Service and to develop new products and services;
contact you for feedback, opinions and suggestions related to the Service and via email,
website surveys, telephone calls and other similar means. Your participation in such
feedback activities is voluntary.
2. Disclosing Your Information
Proteus will not share the Information with third parties except as described in this Privacy
Policy. Proteus may disclose Your Information to:
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our services providers who are involved in providing the Service; these third parties are
required not to use the Information other than to provide the services requested by
Proteus;
where there is a change in the ownership of Proteus (e.g., another company acquires
Proteus’s business or assets, whether by merger, sale of assets, sale of stock, through
bankruptcy, or otherwise), to the new owners; the new owners will assume the rights and
obligations regarding the Information as described in this Privacy Policy;
in connection with any legal investigation or where Proteus (or our service providers) are
required to do so by law, regulation or legal proceedings or to respond to subpoenas or
warrants.
To protect or defend the rights or property of Proteus (our service providers) or other
users.
3. Anonymizing and aggregating Your Information
Proteus may anonymize or aggregate Your Information into a form that can no longer identify
you, and may use that non-identifiable information for any purpose, including to conduct and
publish statistical analysis and other research on usage of the Service, to enhance the Service
and, and to develop new products and services. Proteus may also pass that non-identifiable data
to third parties, such as business partners, in its sole discretion.
4. Cookies
A “cookie” is a text file placed on your computer or mobile device which identifies your
computer/mobile device whenever you visit that website. It is used to collect standard internet
log information and visitor behavior information. This information is used to track visitor use of
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the website and to compile statistical reports on website activity. For further information visit
www.aboutcookies.org or www.allaboutcookies.org.
In order to provide the Service, Proteus may need to place cookies on your and Subjects’
computers or mobile devices. If you or Subjects alter your browser settings to reject cookies on
your computer or mobile device, the Service will not function on that computer/mobile device.
We may also collect your browser type, operating system, Internet Protocol (IP) address (a
number that is automatically assigned to your computer when you use the Internet, which may
vary from session to session), domain name, and/or a date/time stamp for your visit. We may use
third party analytics service providers (as described below) to collect data on your usage of the
Service.
7. Where Proteus stores and processes the Information
Your Information may be processed in the country in which it was collected and in other
countries, including the United States, where laws regarding processing of the Information may
be less stringent than the laws in the country in which it was collected.
8. Retention of the Information
Proteus will keep the Information for as long as it is necessary to fulfill the purposes for which it
was collected, or to the extent permitted or required by law. If your access to the Service is
terminated, Information pertaining to your use of the Service will only be available to you for the
limited time period specified in the terms of your order for Services but may be retained by us
for up to 5 years thereafter.
9. Security
Proteus is committed to protecting the security of the Information. We use a variety of industrystandard security technologies and procedures to help protect the Information from unauthorized
access, use, or disclosure. No method of transmission over the Internet, or method of electronic
storage, is 100% secure, however. Therefore, while Proteus uses reasonable efforts to protect the
Information, Proteus cannot guarantee its absolute security.
10. Changes To This Privacy Policy.
This Privacy Policy is subject to occasional revision, and if we make any changes in the way we
use the Information that result in a material reduction in the level of protection provided to your
Information (a “Material Change”), we will notify you by sending you an e-mail to the last email address you provided to us. Any such Material Changes to this Privacy Policy will be
effective upon thirty (30) calendar days following our dispatch of an e-mail notice to you.
Material Changes will be effective immediately for new users. In any event, Material Changes
to this Privacy Policy may affect our use of the Information that you provided us prior to our
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notification to you of the Material Changes. If you do not wish to permit Material Changes in
our use of the Information, you must notify us prior to the effective date of the Material Changes
that you wish to cease using the Service. Continued use of the Service, following notice of such
Material Changes shall indicate your acknowledgement of such Material Changes and agreement
to be bound by the terms and conditions of such Material Changes. Changes to this Privacy
Policy that are not Material Changes will be effective immediately for all users.
11. Contacting us about Your Information
Please contact Proteus Customer Support if you have any questions about the information that
Proteus holds about you:
Proteus Contact Information:
Proteus Digital Health, 2600 Bridge Parkway, Suite 101, Redwood City, CA 94065
Customer Support:
U.S. Phone: +1 877 285 9803
English language support available 24 hours a day, seven days a week
U.K. Phone: +44 800 011 3991
English language support available 24 hours a day, seven days a week
All geographies, Helpdesk Email: helpdesk@proteus-support.com
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