Date Last Updated: 05/21/2019
At Innovative Supply Solutions, LLC (“Innovative Supply Solutions”, “ISS”, “our”, “we” and/or “us”), we take your privacy seriously. Because we collect certain types of personal information about users of our Platform, a clinical trial and drug supply management tool which is accessed via https://issplatform.com, we believe that you should fully understand how we collect that information, how we use it, and with whom we share it.
By using the Platform, you acknowledge that you have read, understood and agree to the Policy. Your continued use of the Platform following the posting of any changes to the Policy constitutes acceptance of those changes.
What is Personal Information and How Do We Collect it?
When we use the term “Personal Information” we mean information that would allow someone to directly or indirectly identify or contact you, such as your name, mailing address, email address, computer Internet Protocol (“IP”) address, and/or phone number. We may collect your Personal Information when you use provide it to us, including when you create an account, log-in to the Platform, or request Help Desk support.
Maintaining the confidence of Platform users is a vital component of our business operations. As such, ISS is committed to ensuring that Personal Information of Platform users is: processed fairly and lawfully, used for limited purposes, used in a relevant manner, processed in line with one’s rights and kept secure.
We may also collect other information about you, such as your browser type, the time of your visit, clickstream data, and the referring location (e.g., the site page that offered a link to our page) (“Other Information”). This data does not, on its own, permit direct association with a specific individual. We may use, transfer, and disclose this Other Information for any purpose. For example, we may record this basic information about visits to the Platform in order to understand customer behavior and improve our products, services, and advertising. (Personal Information and Other Information, together, the “Information”).
How We Use Your Personal Information
We use your Personal Information to communicate with you about our Platform, services, and registration, as well as to respond to you when you contact us. To continually improve and enhance the Platform and our services, we may send you marketing communications related to our business, which may be of interest to you.
ISS does not sell personal information. ISS may retain your messages, email or communications so that ISS can process inquiries, respond to requests, or improve the quality of our services. We may use your email address and other Personal Information to respond and communicate with you. ISS limits access to Personal Information to its employees and contractors who have a legitimate need to use it, such as responding to requests for Help Desk support.
We will never sell your Personal Information to third parties.
At ISS, we take appropriate steps to ensure that your Personal Information is collected lawfully, fairly and in a transparent manner. Furthermore, all Personal Information is processed, secured, transferred and/or deleted according to applicable industry regulations.
Collection of Personal Data from Other Sources
The ISS Platform may contain links to websites that are not owned or controlled by ISS. If you submit your Personal Information to any of these third-party sites, your Personal Information is governed by their privacy policies. We recommend that you review such third-party privacy policies before sharing your Personal Information.
ISS may sometimes collect personal information from sources other than you. When necessary, we may commission other companies or individuals to perform certain tasks contributing to our services on our behalf within the framework of data processing agreements. All other sites/sources are governed by their own Privacy Policies, which you should read before using them.
The European Economic Area (EEA) provides certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and to complain). Zoho undertakes to provide the same rights no matter where you choose to live. If you are in the European Economic Area and you believe that someone has entrusted your information to us for processing (for instance, your employer or a company whose services you use), you can request certain actions regarding your data. To exercise those data rights, please contact ISS to work with Zoho on your request.
We may disclose your Information to law enforcement agencies, government/regulatory bodies, and content protection organizations to: (i) protect our legal rights, privacy or safety, and that of our subsidiaries, affiliates, employees, agents, contractors, or other individuals; (ii) protect the safety and security of visitors to our online services or other properties; (iii) protect against fraud or other illegal activity or for risk management purposes; (iv) respond to inquiries or requests from government, regulatory, law enforcement, or public authorities; (v) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain; or (vi) comply with the law including with subpoenas, search warrants, court orders, and other legal process.
We reserve the right to transfer your Information in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to offer you services. We will make commercially reasonable efforts to provide you with reasonable notice of such transfer, or as otherwise required by law. If you do not want your Personal Information to be processed following such a transfer, you should contact the subsequent owner of the business.
Any Personal Information that you provide to ISS belongs to you. ISS will not sell, distribute, or reveal users’ IP addresses, email addresses or other Personal Information without their consent.
Modification or Removal of Personal Information
We will delete your Information once it is no longer necessary to achieve the purpose for which it was originally collected. However, we may be required to store Personal Information in a secure location due to regulatory provisions. In such case, ISS will pseudonymize, anonymize or isolate Personal Information in such a way that the Personal Information can no longer be attributed to a specific data subject without the use of additional information .
You may request to delete your account and any Personal Information that ISS may have about you by sending a request to firstname.lastname@example.org. We will provide confirmation of removal upon request.
ISS takes information security seriously. We implement physical, electronic and administrative procedures to safeguard the information we collect from accidental or unlawful destruction, loss, alteration or unauthorized disclosure. Our policies and procedures are aligned with industry standards and are reviewed regularly and updated as necessary to meet and/or exceed regulatory requirements, changes in technology, or business needs. ISS limits access to Personal Information to its employees and contractors who have a legitimate need to use it, such as responding to requests for Help Desk support.
We may disclose your Personal Information to trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep the Personal Information confidential. We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others rights, property, or safety.
We will never sell your Personal Information to third parties.
WHILE WE STRIVE TO SELECT THIRD PARTY PARTNERS WHO HAVE OR SHARE THE SAME STANDARDS IN REGARDS TO PRIVACY POLICIES COMPARABLE TO OURS, YOU AGREE THAT WITH RESPECT TO THOSE THIRD PARTIES, INCLUDING WITHOUT LIMITATION THE SITES WE LINK TO, WE DO NOT MAKE ANY REPRESENTATION OR WARRANTY REGARDING THE SAME, NOR WILL WE BE RESPONSIBLE TO YOU OR ANYONE ELSE FOR ANY PRODUCTS, SERVICES OR OTHER MATERIAL THAT MAY BE SOLD, LICENSED, DISTRIBUTED OR PROMOTED BY SUCH THIRD PARTIES OR ON SUCH SITES, OR FOR ANY CONTENT ON SUCH SITES. WE ENCOURAGE VISITORS OF THESE SITES TO REVIEW THE PRIVACY POLICIES POSTED ON THESE SITES.
ISS may process your Information on servers in the United States of America or in other countries. By accessing or using the Platform or otherwise providing Personal Information to us, you consent to the processing, transfer, and storage of your Personal Information within the United States of America, the European Economic Area (EEA) and other countries where ISS operates. Where applicable, all data transfers will be made pursuant to an agreement consistent with the EU Commission’s Model Contractual Clauses.
This Platform is provided on an “as is” and “as available” basis without any representations or warranties, expressed or implied. ISS makes no representations or warranties in relation to the Website or the information and materials provided therein. Nor does ISS make any warranty that the Website will be available uninterrupted; timely and free of viruses or bugs; or represent the full functionality, accuracy and reliability of the Website.
The Platform is not intended for use by minors and minors are not permitted to use or post on the Platform. In compliance to the Children's Online Privacy Act (COPPA) and The Family Educational Rights and Privacy Act (FERPA), ISS will not require a minor to disclose Personal Information. Access to primary content and features is entirely possible with generic, non-specific user information. If we become aware that Personal Information from a minor was inadvertently collected, we will delete such information without undue delay.
If you are in the European Economic Area (EEA), you have the following rights with respect to Personal Information that ISS holds about you.
Right to access : You have the right to access (and obtain a copy of, if required) the categories of Personal Information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification : You have the right to update the Personal Information we hold about you or to rectify any inaccuracies.
Right to erasure : You have the right to request that we delete your Personal Information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing : You may also have the right to request to restrict the use of your Personal Information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding grounds to use it.
Right to data portability : You have the right to transfer your Personal Information to a third party in a structured, commonly used and machine-readable format.
Right to object : You have the right to object to the use of your Personal Information in certain circumstances, such as the use of your Personal Information for direct marketing.
Right to complain : You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your Personal Information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Limitation of Liability
UNDER NO CIRCUMSTANCES SHALL ISS, ITS AFFILIATES, OR ITS LICENSORS BE LIABLE FOR ANY CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT LIMITATION, INDIRECT, PUNITIVE, INCIDENTAL OR SPECIAL DAMAGES, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF ISS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES) INCLUDING, WITHOUT LIMITATION, ANY THAT RESULT FROM: (i) THE USE OF, OR INABILITY TO USE, THIS SITE/PLATFORM; (ii) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR TRANSACTIONS ENTERED INTO THROUGH OR FROM THE SITE; (iii) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (iv) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SITE; OR (v) ANY OTHER MATERIAL RELATING TO THE SITE. ISS, ITS AFFILIATES AND ITS LICENSORS SHALL ONLY BE LIABLE TO THE EXTENT OF ACTUAL DAMAGES INCURRED BY YOU, NOT TO EXCEED THE PURCHASE PRICE RECEIVED BY ISS FOR THE PRODUCT OR SERVICE GIVING RISE TO THE LIABILITY. THIS LIMITATION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF ISS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES ISS’S LIABILITY IN SUCH JURISDICTIONS SHALL BE LIMITED TO THE EXTENT PERMITTED BY LAW.
California Privacy Rights/Do Not Track Notice
This paragraph applies only to California residents. As a California resident, you have a legal right to request and receive in writing or by e-mail the names and addresses of all such third parties who received your Personal Information during the previous calendar year and a list of the types of Personal Information disclosed to such third parties. To request such information, please send an e-mail to email@example.com or write to:
Innovative Supply Solutions
928 Jaymor Road, Suite B-100
Southampton, PA 18966
We will not honor such a request more than twice per calendar year.
We do not track our customers over time and across third party websites to provide targeted advertising, and therefore do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are vising such site, you may set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.