Privacy Notice

Last Update: 24 March 2021

Janssen Research & Development, LLC cares about your privacy and wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we or our service providers collect through the website or application (hereinafter the “Service”) which is operated and controlled by our service provider Pharmaceutical Research Associates, Inc together with its affiliates (“PRA”) from which you are accessing this Privacy Policy. By providing personal information to us or by using the Service, you acknowledge that you have read and understand this Privacy Policy.

Please note that the clinical research study, which this website is related to, is managed by Janssen Research & Development, which is a global organisation that operates through different legal entities in various countries. Therefore, the legal entity acting as the sponsor for Janssen Research & Development studies may vary and may be different from the legal entity that is the owner of this website.

USE OF SITE BY MINORS

The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below in the Contacting us section.

INFORMATION COLLECTION

Some areas of the Site may ask questions related to your health to assist the study site staff in determining your eligibility for the study. In addition, the Site may ask you to submit personal information, such as your name, telephone number, and email address in order for you to be contacted by a member of the study site staff. You will be informed what information is required and what information is optional.

The personal information that you choose to provide through the Site is processed by Pharmaceutical Research Associates, In. (“PRA”) on behalf of Janssen Research & Development and then provided to your selected study site, should you pass the pre-qualification process. The clinical trial site will receive and retain your information to contact you regarding potential participation in the clinical trial. Pharmaceutical Research Associates, In. (“PRA”) will not provide any information that directly identifies you (e.g. your name or contact information) to Janssen.

If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SENSITIVE INFORMATION

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Service or otherwise to us.

AUTOMATIC INFORMATION COLLECTION AND USE

We and our service providers may collect certain information automatically as you navigate around the Service. Please read the Cookie Policy for detailed information about the cookies and other tracking technologies used on the Service. Except where allowed by applicable law, we place cookies after having received your consent through the cookie banner or preference centre. The Cookie Policy includes information on how you may disable these technologies.

We and our service providers may also automatically collect and use information in the following ways:

Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.

IP address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many online services. We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service. We may also derive your approximate location from your IP address.

Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

How We Use and Disclose Information

We use and disclose information you provide to us as described to you at the point of collection.
Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection. We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, due to our pharmacovigilance obligations), or for our legitimate business interests. Our legitimate business interests may include any or all of the following:

• to respond to your inquiries and fulfill your requests, such as to send you documents you request or e mail alerts;
• to send you important information regarding our relationship with you or regarding the Service, changes to our terms, conditions, and policies and/or other administrative information; and

for other business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying Service usage trends, better understanding your interests so that we can serve you better, personalizing your experience on the Service by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.

We also disclose information collected through the Site:

• to our affiliates for the purposes described in this Privacy Policy. The affiliate that is acting as the Sponsor in relation to your country is the party responsible for the management of the jointly-used Personal Information;
• to our third party partners with whom we offer a co-branded or co-marketed promotion;
• to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide services; and
• to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

In addition, we use and disclose information collected through the Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose information collected through the Site in other ways, with your consent.

We may use and disclose information we collect automatically as described above, under “Automatic Information Collection and Use.”
In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

CHOICES AND ACCESS

How you can access, change, or delete your personal information
If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us via email at embracestudy@prahs.com. We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

CROSS-BORDER TRANSFER

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.

Some non-European Economic Area (EEA) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have ensured that adequate measures are in place, including by ensuring that the recipient is bound by EU Standard Contractual Clauses, or an EU-approved code of conduct or certification, to protect your Personal Information. You may obtain a copy of these measures by contacting our data protection officer in accordance with the “Contacting Us” section below.

SECURITY

We seek to use reasonable organisational, technical, and administrative measures designed to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

RETENTION PERIOD

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
For example, if we collect your personal information for your participation in a Clinical Trial, we may need to store it for a period of lifetime of the investigational product that is in scope of the Clinical Trial + 20 years.
Please note, however, that this is not an exhaustive list of retention periods. Your personal information may be stored for a longer period using the criteria set forth in the first paragraph of this section, especially points (ii) and (iii).

THIRD PARTY SITES AND SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Service or to which this Service contains a link. The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates.

CONTACTING US

Janssen Research & Development, LLC, located at 920 Route 202, Raritan, NJ 08869, United States, is the company responsible for collection, use, and disclosure of personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us via e-mail at embracestudy@prahs.com or please write to the following addresses:

• Janssen Research & Development, LCC, located at 920 Route 202, Raritan, NJ 08869 United States
• Janssen Research & Development, LLC is represented in EU by Janssen Cilag International NV, Turnhoutseweg 30, B-2340, Beerse, Belgium
• PRA Health Sciences, located at 4130 Park Lake Avenue, Suite 400, Raleigh, NC 27612

You may also contact our data protection officer responsible for your country or region, if applicable, at emeaprivacy@its.jnj.com. In case contacting the data protection officer, please include information on the website, and the clinical trial that your question may relate to.

LODGING A COMPLAINT WITH A REGULATOR

You may lodge a complaint with a supervisory authority competent for your country or region. Please click here for contact information for such authorities.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Service. Your use of the Service following these changes means that you accept the revised Privacy Policy. We recommend that you regularly review the Privacy Policy when you visit the Service. This policy was last updated on 24 March 2021.