1) Introduction
This website is provided and maintained by Replior AB (Replior). Replior operates the websites replior.se and trialonline.se. This privacy policy applies for both websites.
The purpose of this Privacy Policy is to set out the principles governing our use of the personal data which you submit to us, or we obtain about you, via the website. By using this website, or (where applicable) by submitting contact information or registering as a user of the on-line services which we provide, you agree to this use.
Please note however, that this Privacy Policy only contains general information about Replior’s collection and processing of personal data when you are browsing through Replior’s websites. If you submit your personal information to us for any reason, for example, if you have an account because you take part in a clinical study, you will be provided with further information through the clinical study informed consent or from the clinical study sponsor about the use of your personal information, including:
- what personal data will be collected, for what purpose and through which technical means
- who is responsible for your personal data
- to whom your personal data is disclosed
- how long your personal data will be retained.
We may change our Privacy Policy from time to time. Please check this Privacy Policy occasionally to ensure that you are aware of the most recent version. We will of course notify you of any changes where we are required to do so. The texts contained in this document should be regarded as a master for the texts published on Replior’s external website. Minor text updates may occur without updating this document.
2) Privacy
Replior AB is a privately held company registered in Sweden. We are committed to protecting and respecting your privacy in connection with your use of our website and other programs, applications and features (collectively referred to herein as the “Tool” or “Tools”.) This privacy policy (“Privacy Policy”) sets forth the basis on which any personal information we collect from you, or that you provide to us, in connection with the Tools will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how we will collect and use your personal information.
1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you:
Personal information including, for example, your name, e-mail address, telephone, your company name and company contact details, information about your usage of the Tools and information collected by tracking technologies as further described below that may identify you as an individual or allow online or offline contact with you as an individual.
THE LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Replior’s processing of your Personal Data is based on the legal grounds as follows.
✓Legitimate interests
The legal basis for processing Personal Data such as technical data when you browse the Replior website is that the processing is necessary for the purpose of the legitimate interests of Replior. The legitimate interest of Replior may also constitute the legal basis for processing in situations where you provide us with your contact information by contacting us or otherwise have expressed an interest in our products or services.
✓Consent
Replior’s processing of your Personal Data is based on your consent where you provide us with your Personal Data by registering an account with us or signing up to our newsletter on our website. You can at any time withdraw your consent to such processing either by clicking the unsubscribe link in our newsletter or by contacting us at info@replior.se
We will not disclose your personal data to any third parties or third countries without your specific consent.
2. CONFIDENTIALITY AND SECURITY
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at DPO@replior.se.
3. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
Occasionally we send out newsletters (approximately 10/year) and other information (such as promotional material and invitations to events) via email. Our aim is to only send you information that you may find of interest and that supports you in your work.
If you inform us that you wish to cancel email newsletters or promotional emails by selecting unsubscribe at the bottom of such communication, or by emailing us at info@replior.se, we will remove you from our mailing list.
If you provide your mobile phone number through the Tools we may send you an SMS message with important information (such as cancellation of an event, or changes to time/venue for an event that you have registered to attend).
4. TRACKING TECHNOLOGIES
We use technologies such as cookies, tags, and scripts, which enable us to recognise your device. We also use tracking scripts to let us know when users have visited the webpage by “clicking-through” from our newsletters or other electronic communications.
The web page uses Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Tools and the volumes of usage of the Tools. This is done to ensure that the Tools are available when you want them and are fast. For more information on how Google Analytics processes this information, visit www.google.com/analytics.
5. LOG FILES
As true of most websites, we gather certain information and automatically store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved.
These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting. They may also be used to provide you with information and offerings that we believe you may find of interest and that support you in your work.
6. WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us through the Tools is stored on secure servers located in Sweden. Information is available to authorised personnel only, and access is restricted as much as possible.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. ACCESS TO AND DELETION OF PERSONAL INFORMATION
Withdrawal of consent
You will always have the option of letting us know if you no longer agree to the collection, use and transfer of your Personal Data according to this Privacy Policy and any specific privacy notice governing our use of your Personal Information in a specific case.
Corrections, additions or erasure
You are always entitled to access your Personal Data for viewing, or for making corrections, additions or erase certain of your Personal Data.
Restriction of use and data portability
Under certain circumstances (expressed in applicable data protection legislation) you may request that Replior restricts the use of your Personal Data. If you have provided us with Personal Data, you also have the right to have your Personal Data resubmitted to you, in a structured and accessible format, for transfer to another user/processor.
Requests and Complaints
If you wish to exercise any of the above mentioned rights or if you have any questions regarding Personal Data held by us or this online privacy policy, please contact us at: dpo@replior.se Please state your name, username (if any), registration details (if any) and the name of this website clearly on all communications.
Should you be dissatisfied with our processing of your Personal Data, please let us know and we will do our best to address your complaints. Your integrity is very important to us, and we always strive to protect and secure your Personal Data in the best possible way. Should we nevertheless, in your opinion, fail in this ambition, please note that you are also entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or such other authority as may be determined in the future.
8. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content provided by the webpage is presented in the most effective manner for you and for your computer or other device.
- To provide you with information, products or services related to Replior that you request from us or which we feel may interest you, unless you have requested that we not provide this information.
- To provide you with customer service communications, including events or activities you have registered for.
- To carry out our obligations arising from any agreements entered into between you and us.
9. SURVEYS AND REGISTRATION TOOLS
We use a Software as a Service Tool for management of newsletters, surveys and events. The tool and the service provider fulfil GDPR requirements. Replior has a Personal Data Processor Agreement with the service provider ensuring that your personal data is protected.
10. SOCIAL MEDIA WIDGETS
Our Tools include social media features and widgets, such as the “Share” button. These features may collect your Internet protocol address, which page you are visiting on our Tools, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Tools. Your interactions with these features are governed by the privacy statement of the company providing it.
11. HOW LONG WE KEEP PERSONAL INFORMATION
We will not keep personal information in a form which permits identification of data subjects for longer than is necessary for the purposes for which the personal data is processed. We have a ‘Records of Processing Activities’ register which documents for how long personal data should be kept. This register is periodically reviewed according to defined procedures, and personal data is updated or removed as applicable.
12. CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.
13. CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to DPO@replior.se. As an alternative, you may contact Replior at +46 (0)8 – 601 13 30 and ask to speak to the Data Protection Officer.
This Privacy Policy is effective and was last updated on 2021-02-15
Replior’s head office address is Hammarby Kaj 18, SE-120 30 Stockholm, Sweden
14. REVISION HISTORY
Initial version, 2020-09-03, Revised 2021-02-15