How your personal information is used by Clinical Outcomes Solutions (COS)
Your privacy is important to us. This Privacy Policy explains our online information practices regarding collection, use, and disclosure of information that you may provide via Clinical Outcomes Solutions or that we may otherwise collect about you, including personally identifiable information (“PII”). For purposes of this Policy, PII about you means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. This notice explains how we do this and tells you about your privacy rights and how the law protects you. Please read this entire Privacy Notice before using or submitting information to us.
Our privacy promise to you:
To keep your data safe and private.
Not to sell your data.
To give you ways to manage and review your marketing choices at any time.
Your consent and policy updates
By using this site, you are accepting the terms of this Privacy Policy (as well as COS’s Terms of Use). Whenever you submit information via this Site, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy, so please read this entire Privacy Policy before using, or submitting information to Us.
COS may, from time to time in its sole discretion, change or modify this Privacy Policy. Any changes or modifications will be effective upon posting of the revised Policy on the Site. Your access and use of the Site and provision of information is governed by the Privacy Policy then in effect. Therefore, your continued use of the Site following COS’s posting of any changes or modifications will constitute Your acceptance of such changes or modifications.
If you have any questions or want more details about how we use your personal information, you can ask us by writing to COS at:
Personal Data Enquiries
Clinical Outcomes Solutions
Privacy Office
8 Motis Centre
Cheriton High Steet
Folkestone, Kent, UK
CT19 4QJ
E-Mail: dpoffice@clinoutsolutions.com
EU Representative
OBSECOM GmbH
Königstr. 40
70173 Stuttgart Germany
Telephone: +49 711 / 4605025-40
Telefax: +49 711 / 4605025-49
E-Mail: clinicalus@obsecom.eu
Website: https://www.obsecom.eu
How does the law protect you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside our organization.
The law says we must have one or more of these reasons:
To fulfill a contract we have with you, or
When it is our legal duty, or
When it is in our legitimate interest, or
When you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of all the ways that we may use your personal information and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
Privacy Notice
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To manage our relationship with you or your business
To develop and carry out marketing activities
To provide advice or guidance about our products and services
To respond to complaints and seek to resolve them
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Your consent
Our legitimate interests
Our legal duty
Our legitimate interests
Our legal duty
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Keeping our records up to date, working out which of our products and services may interest you and telling you about them
Seeking your consent when we need it to contact you
Being efficient about how we fulfill our legal duties
Complying with regulations that apply to us
Being efficient about how we fulfill our legal and contractual duties when we need it to contact you
We must be efficient in fulfilling our legal duties.
Groups of Personal Information
We use many different kinds of personal information, and group them together like this.
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Contact
Where you work and how to contact you
[Name, company, reorganization, work and/or personal address/es and postal address]Contractual
Details about the services we provide to youLocational
Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internetTechnical
Details on the devices and technology you useCommunications
What we learn about you from letters, emails, and conversations between usOpen Data and Public Records
Information about you that is openly available on the internetUsage Data
Other data about how you use our products and servicesConsents
Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you
Where we collect personal information from
We may collect personal information about you (or your business) and from these sources:
Data you give to us:
When you talk to us on the phone
When you use our website
When you contact us or a representative of our firm, via LinkedIn
In emails, letters, contracts or work orders
Who we share your personal information with
We do not share your data with any third-party companies or agencies for marketing purposes. We may share your personal information with other organizations or third-party providers to provide you with the service you have chosen or to fulfil our contractual obligations.
We may share your personal information if the make-up of COS changes in the future:
We may choose to sell, transfer, or merge parts of our business, or our assets
Or we may seek to acquire other businesses or merge with them
During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
If the change to our Company happens, then other parties may use your data in the same way as set out in this notice.
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from providing a service.
Marketing
We may use your personal information to tell you about relevant services. This is what we mean when we talk about “marketing”.
The personal information we have for you is made up of what you tell us, and data we collect when you engage with us either directly or via LinkedIn, or from third parties we work with.
We can only use your personal information to send you marketing messages if we have either your consent or a “legitimate interest”. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
We will ask you to confirm or update your choices if there are changes in the law, regulation, or the structure of our business. If you change your mind, you can update your choices at any time by contacting us.
Job applications
If you use our form to apply for a job, you will be asked to provide your name, contact details and further application documents so that we can review your application and contact you. Data processing for the purpose of processing your application is carried out on the basis of your voluntary consent. Taking into account the limitation periods of Anti Discriminations Laws, application documents will be retained for a period of 6 months following the completion of the application process and will then be deleted unless retention is required for the documentation of other operations (for example, subsequent recruitment). If we reject your application but would like to keep your application documents in our pool of candidates for a longer period of up to one year in order to consider you for future vacancies, we will contact you in advance and ask for your consent. Data will then only be stored with your prior express consent.
How long will we keep your personal information
After you stop requiring our services, we will keep your personal information for no longer than 7 years. to maintain records according to rules that apply to us. We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory or technical reasons.
We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
Personal Data Enquiries
Clinical Outcomes Solutions
Suite 8 Motis Business Centre
Cheriton High Street
Folkestone, Kent, CT19 4QJ, UK
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the “right to object” and “right to erasure”, or the “right to be forgotten”.
There may be legal or other official reasons why we need to keep or use your data, but please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
It is not accurate.
It has been used unlawfully but you don’t want us to delete it.
It not relevant any more, but you want us to keep it for use in legal claims.
You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data or ask us to delete it or restrict how we use it or please contact us by writing to:
Personal Data Enquiries
Clinical Outcomes Solutions
Suite 8
Motis Business Centre
Cheriton High Street
Folkestone, Kent, UK
CT19 4QJ
How to withdraw your consent or make a complaint
You can withdraw your consent at any time. Please contact us if you want to do so. Please let us know if you are unhappy with how we have used your personal information. You can contact us at the address above.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.
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California Consumer Privacy Act (“CCPA”) Privacy Policy Addendum
As a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.
Right to Know
If you are a California resident, you have the right to know what PII we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the PII during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of PII we have collected (a “Categories Request”) or a request for access to the specific pieces of PII we have collected (a “Specific Pieces Request.”)
If you make a Categories Request, you will need to provide us with at least two data elements specific to you, such as your cell phone number or driver’s license number (depending on the data elements we already maintain about you), so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:
The categories of PII we collected about you
The categories of sources for the PII we collected about you (e.g., social media websites, government records available to the public, etc.)
Our business or commercial purpose for collecting that PII
The categories of third parties other than service providers (if any) with whom we shared the PII
If you make a Specific Pieces Request, we need to be sure we have verified your identity with great certainty to safeguard the privacy of the PII we have collected. Therefore, in making such a request, you will need to provide to us at least three data elements specific to you, together with a signed declaration under penalty of perjury that you are the individual to whom the PII you are requesting pertains. After we confirm that your request is a verifiable consumer request, ww will, consistent with the CCPA, disclose to you the specific pieces of PII we collected about you that you requested.
Right to Request Deletion
You have the right to request that we delete any of your PII that we maintain. However, we are not obligated to comply with your request if we have a legal basis to retain the PII. We will not delete any PII pursuant to your request unless we are able to verify that you are the individual to whom that PII pertains.
If you make a request for us to delete PII, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable consumer request (see below on “How to Submit a Request”), we will inform you whether we have deleted (and have directed our service providers to delete) your PII from our records, or whether we are declining to grant your request to delete due to a legal basis for us to retain the PII.
Exceptions to CCPA Rights
The CCPA has certain exceptions to the rights it grants to residents of California. Under one such exception, information that is “medical information” under the California Confidentiality of Medical Information Act (“CMIA”) is protected in accordance with that Act, and the CCPA rights do not extend to such information in light of that protection.
How to Submit a Request
To request access to or deletion of your PII as described above, please submit a verifiable consumer request to us at the address below:
Clinical Outcomes Solutions
1820 E River Rd., Suite 220
Tucson, Arizona 85718
Attn: Personal Data InquiriesYou may make a request on your own behalf, and if you are the parent or guardian of a minor child, you also may make a request related to your child’s PII. If you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual’s full name, address, email address, and phone number. That way we will be sure you have fully authorized us to act in accordance with the requests of that individual.
As indicated above, in order to protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, we require identification verification before granting any request to provide copies of, know more about, or delete your PII. We take special precautions to help ensure this. We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm that the PII relates to you. We will only use PII collected in connection with a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.