Anova Enterprises, Inc.  (“we“, “us”, “our” or “Anova”) are committed to protecting and respecting your privacy. This policy (together with our Website Terms and Conditions) and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This will include data collected when you visit www.anovaevidence.com and/or input your data into our platform www.anovaos.com, our associated mobile applications and other services (“Services”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

WHO WE ARE

We are Anova Enterprises, Inc. of Woodfield Preserve, 10 N. Martingale Road, Suite 400, Schaumburg, Illinois, 60173.

Our representative in the European Union is : Adam Brogden who can be contacted at 69 Esker Woods Drive, Lucan, Co. Dublin, Ireland, by telephone +353 15 549700, or by email at contact@gdprlocal.com

We are the Controller of the personal data referred to in this policy for the purposes of the applicable data protection legislation.

THE BASIS ON WHICH YOUR DATA IS PROCESSED

We have entered into contractual arrangements with research sites and sponsors for the purposes of facilitating participation in and conducting sponsor studies. As part of providing the Services you may provide your personal data via our Services as an authorised user of a research site or a sponsor. You may also provide your personal data direct to us via our website.

You instruct Anova to process your personal data in accordance with this policy on the following basis:

• on the basis that we need to comply with a legal obligation;
• on the basis that processing is necessary for the performance of a contract, being our agreement to provide the Anova platform to you; or
• on the basis of our legitimate interests (and we have assessed that these interests do not override your rights and freedoms).

The legitimate interests are as follow:

• providing services to you and our other users (such as research sites and sponsors supporting the conduct of clinical trials and related pathways);
• activities associated with the running of our business such as finance and administration and information security and back-up procedures;
• improving and developing our services;
• marketing and promoting our business and services.

Where we process special category data, the basis for this is set out in our special category data supplement that can be accessed here.

WHY WE COLLECT INFORMATION ABOUT YOU

We collect data about you for the following purposes:

• to provide the Anova Site and platform to you and give you the best possible experience of using our services.
• to enable sponsors (a biopharmaceutical company, medical device manufacturer or a physician or academic centre) to connect with research sites (a clinical organisation conducting trials) registered on the Anova platform.
• to enable patients to connect with research sites (a clinical organisation conducting trials) registered on the Anova platform, to identify a matched research opportunity and/or register interest in participating in research and/or enrol and/or manage their participation in a clinical trial conducted by a sponsor and the research site;
• to provide anonymised, aggregated, non-identifiable analysis of the user activities being conducted over the Anova platform.
• to provide and/or conduct research using anonymised (or pseudonymised if part of a clinical trial), aggregated, analysis of the patient and their data with the intent of contributing to generalisable knowledge, for example:
  • Assessing natural history, including estimating the magnitude of a problem; determining the underlying incidence or prevalence rate of a condition; examining trends of disease over time; assessing service delivery and identifying groups at high risk; and describing and estimating survival;
  • Determining clinical effectiveness, cost effectiveness, or comparative effectiveness of a test or a treatment;
  • Measuring and monitoring safety and harm associated with the use of specific products and treatments, including conducting comparative evaluation of safety and effectiveness;
  • Measuring or improving quality of care, including conducting programs to measure and/or improve the practice of medicine and/or public health.
• anticipating and resolving problems with your use of the Anova platform or the Site or related services.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information you give us

Registration: To register on the Anova platform, as an administrative user you must provide us with your name, email address, and a password. You may provide additional information during the registration process, for example, your address, job title, academic qualifications (degrees and medical licenses), research experiences, financial disclosure(s) information, conflict of interest history and employment history to help build your profile. You understand that, by creating an account, we and other users may be able to identify you by your public profile.

Research sites: If you are a representative of a research site, you may also provide us the details of your organisation, including information about your organisation, patient population profile, contact(s) for a number of roles, research site facilities, investigational product storage and preparation details, sample storage and prep, reagent storage, medical waste management, IT, IRB, laboratory, cardiology, imaging, surgery and ophthalmology details. You may also provide us patient details, including demographics, clinical, and administrative data to identify a matched research opportunity and/or register interest in on behalf of the patient in participating in research and/or enrol and/or manage the patient’s participation in a clinical trial.

Sponsor: If you are a representative of a sponsor, you may also provide us details about your organisation, contact information and study(s) protocols.

Patient: If you are a patient (or a patient representative) you may also provide us demographics, clinical, and administrative data to identify a matched research opportunity and/or register interest in participating in research and/or enrol and/or support participation in a clinical trial.

Not all of the above information is personal data.

Interacting with us and other users: You may give us information about you by corresponding with us by e-mail, through using the Anova platform or otherwise, for example where you contact our customer services department or where you contact another user through the Anova platform.

Information we collect about you.

With regard to each of your visits to the Anova platform we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Anova platform (including date and time); people you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
• Content that you upload. We will have access to the content which you provide on the Anova platform, including your profile data, and private and group messages, which we may exercise on an ad hoc basis.

Special Category Data

In some circumstances we collect and process Special Category Data.  The Special Category Data that we collect and/or process is set out in special category data supplement that can be accessed here.

COOKIES

Our website uses cookies to distinguish you from other users of the Anova platform. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Anova platform.

Our cookies policy can be found here.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

Information you give to us

We may use this information:

• to match users with research study sponsors and clinical research sites.
• to inform and refine the Anova platform and the Site;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to identify a matched research opportunity and/or register interest in participating in research and/or enrol in a clinical trial and/or support/manage patient participation in a clinical trial;
• to notify you about changes to the Anova platform and the Site
• to ensure that content from the Anova platform and the Site is presented in the most effective manner for you and for your computer or device;
• to monitor the use of the Anova platform and the Site from time to time to eliminate infringing, defamatory, immoral, illegal, abusive and/or inappropriate use;
• to conduct research using anonymised (or pseudonymised if part of a clinical trial), aggregated, analysis of the patient and their data with the intent of contributing to generalisable knowledge.

Information we collect about you

We will use this information:

• to best match you with other users; to administer the Anova platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the Anova platform to ensure that content is presented in the most effective manner for you and for your computer or device;
• to allow you to participate in interactive features of the Anova platform;
• as part of our efforts to keep the Anova platform safe and secure;
• to best match you and/or your organization to research opportunities and/or register interest in participating in research and/or enrol in a clinical trial and/or support/manage patient participation in a clinical trial;
• to conduct research.

DISCLOSURE OF YOUR INFORMATION

Your information will be available to other users via our matching process, which will enable research sites to contact sponsors and vice versa, and enable patient to contact research sites and vice versa.

We will not pass to any other third parties any personal information that would identify you as an individual or be directly linked to you as an individual (including your contact information) except in the limited circumstances explained in this section.

We may need to share your information with our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.

We may also share non-identifiable personal information with selected third parties for the following purposes:

• Analytics and search engine providers that assist us in the improvement and optimisation of the Anova platform.
• In the event that we sell or buy any business or assets;
• Research, with the purpose of contributing to generalisable knowledge;
• In the event that you provide additional explicit consent in participating in a clinical trial;

We may disclose your personal information to third parties:

• If Anova or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers may be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Anova, our customers, or others.

STORAGE AND SECURITY

Anova is a company located in the United States (US) and if you are located in the European Economic Area (EEA) or in another country outside the US and EEA your data will be transferred into the US. The data that we collect from you will be processed in the US and we have implemented adequate safeguards for this transfer. By submitting your personal data, you agree to this transfer, storage or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Anova platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have implemented appropriate security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on the Anova platform is password-protected and we use appropriate authentication and encryption. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please note that emails, instant messaging, and similar means of communication with other users are not encrypted, and we strongly advise you not to communicate any confidential or financial information through these means.

Data retention

We retain the personal information you provide no longer than is necessary for the purposes for which it was collected.  Our right to retain your personal information is subject to the exercise of your rights to request erasure in accordance with applicable data protection legislation.

We may retain your personal information for a longer period where a legal or regulatory requirements exists (including, International Conference on Harmonization (ICH) Guidelines for Good Clinical Practice, FDA or EMA rules and other professional norms).  We may be required to ensure maintenance of, and therefore access to essential documents for a minimum period of 2 years after the latter of two occurrences: (i)  the date when a clinical investigation conducted using information on the Anova platform is terminated or completed, or (ii) the date that the records are no longer needed to support a premarket approval (PMA) or new drug application (NDA) by a sponsor.

THIRD PARTY SITES

The Anova platform may, from time to time, contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

YOUR RIGHTS

You have the following rights:

• The right to request access to the personal data that we hold about you;
• The right to request rectification of the personal data that we hold about you;
• The right to request erasure of the personal data that we hold about you (although please note that this right is limited by certain circumstances, for example: where the information is still required for the purposes set out in this privacy policy, there are overriding legitimate grounds for the processing);
• The right to request restriction of processing about you;
• The right to object to processing; and
• The right to data portability.

If you wish to invoke any of the above rights, please notify us using the contact details set out in the contact section below.

You may also opt-out of receiving marketing communications from Anova by contacting us at info.us@anoveevidence.com  If Anova receives a valid opt-out request from you, Anova will (i) not contact you with marketing communications about Anova’s products or services; and (ii) will not use your personal information obtained from your use of the Site to contact you with marketing communications.

You have the right to lodge a complaint with a competent supervisory authority.

In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACTS

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Data Protection Officer, Anova, 3400 West Stonegate Boulevard, Suite 101, Arlington Heights, IL 60005 or emailed to info.us@anovaevidence.com.

Data Protection Officer

Our Data Protection Officer is Ravi Natarajan, Anova, 3400 West Stonegate Boulevard, Suite 101, Arlington Heights, IL 60005.  Email ravi@anovaevidence.com

UK Representative

Our UK Representative is: Martin Walsh, Anova, Inc. 20 Eastbourne Terrace, London W2 6LG.  Email martin@anovaevidence.com

EU Representative

Our representative in the European Union is : Adam Brogden who can be contacted at 69 Esker Woods Drive, Lucan, Co. Dublin, Ireland, by telephone +353 15 549700, or by email at contact@gdprlocal.com