Siron Clinical Privacy Notice

General
Siron Clinical (also referred to as “we” or “our”),as a Data Controller, is committed to the protection of Personal Information in line with Dutch legislation and the Regulation (EU) 2016/679, the EU General Data Protection Regulation (“GDPR”), effective as per May 25, 2018.
This Privacy Notice describes how we collect, use, disclose, store, protect and otherwise control your information which you provide to Siron Clinical over our Website (https://sironclinical.com/), or which is gathered via the Website by other means. This Privacy Notice also informs you of your rights and how to get access to your personal information. This Privacy Notice does not cover other services that we may offer or provide.
Access to the Website implies your full and unreserved acceptance of this Privacy Notice, as well as its general terms of use and the Cookies Notice.

1. Definitions
Personal information: any information or set of information about an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) telephone number; (d) email address or online identifier associated with the individual; (e) Social Security number or other similar identifier; (f) employment, financial or health information; or (g) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person).
Non-personal information: any information that is not Personal Information as defined above.
Data processing: Any operation or set of operations which are performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. What personal information do we collect?
Primarily your personal data will be gathered directly from you through completion of the contact form when using our website. As a person completing the form you may belong to one of the following categories:
• Potential partner/client
• Vendor or Supplier
• Job applicant (a person who has applied for a (consultancy) position but has not yet been accepted
• Other

When completing the contact form, you are asked to enter personal information: full name, e-mail address, or other details.
Additional personal information may also be provided, including via our e-mail address referenced on our website, for example, through uploading your business information or curriculum vitae. This may possibly include the following information:
• (academic) title
• (business) postal address
• (business) telephone number
• information about education and past work experience
• information on the company you are associated with

When subscribing to our Newsletter, you are asked to enter personal information: full name and e-mail address.
When downloading the eBook, you are asked to enter personal information: full name and e-mail address.
The website may also collect information about you through cookies that are explained in Section 5 ‘Use of Cookies’.

3. How do we use your personal information?
The information we collect will be used for purposes consistent with the subject matter of your enquiry, for example:
• To enter into discussions on delivering any services requested
• To follow up with you concerning your job application or consultancy
• To manage your subscription to our newsletter, including to send latest news and blog articles
• To manage your eBook or RFI download request

4. On what basis do we use your personal information?
The legal basis for the processing initiated via the Contact Form is our Legitimate Interest in order to develop relationships with new clients, to identify and select potential staff or subcontractors and to main satisfactory communication with people interested in us and our work. The legal basis for processing cookies, except for the strictly necessary cookies (technical) and your data provided if you subscribe to our newsletter is your consent. Please, remember that you may unsubscribe from the newsletter at any time without any cost.

From our website, you may use third party social media widgets/tools/buttons. If you use that functionality, your use is subject to the third party’s privacy notices and terms. As with all links to non-Siron Clinical websites/content/services, we recommend that you read the privacy notices and terms associated with third party properties carefully.

5. Use of Cookies
European laws, including the GDPR and the e-Privacy Directive, create obligations for digital publishers such Siron Clinical to give you clear and mandatory information about the use of cookies.

Cookies are small files that are stored on your device which enable features and functionality related to our website. They can be used for just the time you visit our Website or be more persistent to allow us to recognise you if you visit again.

Cookies can be classified as follows, depending on the owner:
• First-party cookies: They are created, sent to your computer and stored by the website you are visiting directly. They allow us to collect customer analytics data, remember language settings, and carry out other useful functions that help provide a good user experience.
• Third-party cookies: They are created and placed by third parties other than the website you are visiting directly. They are not managed by us, but by the third party that processes data obtained from the cookies.
Cookies can also be classified depending on the purpose of their placement. Main categories are:
• Strictly necessary cookies (technical): The cookies that allow you to browse a website, platform or app, and use the various options or services on it (e.g., control traffic, identify data or session, access restricted access sections or content, etc.).
• Functional cookies: Functional cookies help us to make the website usable by providing you some basic features and remember your preferences and choices of using our website (e.g., language, the region from where the service is accessed, etc.). Not accepting cookies may cause slow website performance or poorly adapted recommendations.
• Statistics cookies: Statistics cookies allow us to provide a better understanding of how you interact with the website.
• Marketing cookies: Marketing cookies enable us to monitor you to the websites. The aim is to display advertisements that are meaningful and attractive to you and therefore more useful to third party publishers and advertisers, as well as to make promotional and specific information available to you on the website

We use the following cookies:

Unclassified:

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You are able to accept or decline cookies when you enter our website. Alternatively, you can manage your cookies preferences through your browser settings. However, in some cases, some functions of the website may not work.

To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or https://www.aboutcookies.org/. 
Find out how to manage cookies on those popular browsers:
• Google Chrome 
• Mozilla Firefox
• Internet Explorer
• Safari

To find information relating to other browsers, visit the browser developer’s website.
To opt out of being tracked by Google Analytics across all websites, visit – http://tools.google.com/dlpage/gaoptout. 

6. How long do we keep your data?
The data retention period varies according to the different purposes of processing. In general, we will keep your personal data for the duration of the legally obliged storage and limitation periods (fiscal and administrative). If such an obligation does not apply, we will keep your data no longer than necessary (e.g., to meet your request via the contact form, or until you unsubscribe or cancel your subscription to the newsletter). The period of retention of job applicant data will be no longer than two (2) years.

At all times you have the right to request removal of your personal data from our systems.

Should however any legal ground prevent Siron Clinical to remove your personal data from its systems you will be informed what personal data we are obliged to keep and the reasons for keeping it.

7. How do we protect your information?
We take appropriate security measures to prevent your personal data from being accidentally or unlawfully destroyed, lost, used, accessed, altered or disclosed. Your personal data is stored at a safe and secured location that is only accessible to the authorized Siron Clinical personnel. They only process your personal data under our documented instructions, and they are subject to a duty of confidentiality. In addition, all sensitive information that you supply via our website is encrypted via Secure Socket Layer (SSL) technology.

8. What are your rights regarding your personal data?
With regard to the processing of your personal data you have the following right under GDPR:
• Access: you have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, all necessary information to make the process transparent
• Rectification: you have the right to require rectification of inaccurate data about you
• Deletion of personal data: you have the right to request deletion of your personal data, but this right may be limited depending on the specific circumstances
• Object to processing: you have the right to object, on grounds relating to your particular situation, at any time to the processing of your data where we are relying on legitimate interest as legal basis
• Restriction to processing: you have the right to restrict processing of data under certain specified circumstances
• Data Portability: when you have given your consent for the processing of your data, you have the right to request to receive or transfer your personal data to another organization, in a machine-readable form,
• Withdraw consent to data processing: when you have given your consent for the processing of your data, you can withdraw you consent at any time, without justification

You can exercise your rights described above by contacting our DPO at the following address: sironclinical.dpo@mydata-trust.info
If you are unhappy with the response you receive then you have the right to complain to the Data Protection Authority in your own country (if you are resident in the European Economic Area) or the DPA of the Netherlands by consulting the information here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

9. Do we disclose information to third parties?
We may share information with Siron Clinical affiliated companies, including third party collaborators.
In the event we are required to transfer personal data to recipients outside of the European Economic Area (EEA), it will protect the data in accordance with Data Protection Laws. If the personal data are transferred to countries that have not been recognized by the European Commission as providing an adequate level of data protection, we will put in place contractual safeguards to protect the data (e.g., EU Standard Contractual Clauses “SCCs” to the extent it constitutes a valid mechanism of transfer under Chapter V of GDPR).

10. Amendment of the Privacy Notice
We reserve the right to change the Privacy Notice at any time. The changes will be posted on the website. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our website.

11. How to contact us?
If you have any questions about this Privacy Notice or if you would like to register a complaint, please contact us by sending an e-mail to sironclinical.dpo@mydata-trust.info