Privacy Policy

Trifecta Multimedia, LLC DBA Trifecta Clinical® (Trifecta) provides online training and communication tools to physicians conducting clinical trials on behalf of pharmaceutical companies. As part of our business, Trifecta is provided by its Client minimal business information from these physicians and their support staff (Name, Address, Employment Title, Division or Place of Employment, and Employment Email Address) to enter in Trifecta system and provide access for training and communication tool. At Trifecta, we understand that privacy is an important concern of our customers. The nature of our business requires that our Client may need to provide nonpublic information about you. This is information that we are provided when we provide our Client with products and services. We do not sell your information to anyone. Trifecta is subject to the investigatory and enforcement policies of the Federal Trade Commission. This US-EU Privacy Shield Privacy Policy (the “Policy”) sets forth the privacy principles Trifecta follows with respect to transfers of personal information (provided by Trifecta Client) from the EEA to the United States. Note: It must be emphasized that at no time is Trifecta provided any sensitive personal information other than Name, Employment Title, Division or Place of Employment, and Employment Email Address; or Patient information as part of our services for this platform for the pharmaceutical client.

Definitions

For purposes of this Policy, the following definitions shall apply:

Client

Any customer of Trifecta (Pharmaceutical Industry Sponsor / CRO), located in the EEA that has purchased our training and communication tool as a service.

Trifecta

Trifecta Multimedia LLC DBA Trifecta Clinical®, its predecessors, successors, and subsidiaries in the United States.

Personal information

Any information or set of information that is required by Trifecta (Name, Employment Title, Division or Place of Employment, and Employment Email Address) for the purpose of entering Client in Trifecta system and provide access for the Trifecta on line training and communication tool. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

Agent

Any third party that uses personal information under the instructions of, and solely for, Trifecta.

Affirmative Commitment to Privacy Shield Framework

Trifecta complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the use, and retention of personal information (provided by Trifecta Client) transferred from the European Union to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Use of Personally Identifiable Information

Trifecta is provided by its Client minimal employment related personally identifiable information in order to provide provision you in the Trifecta system and provide you access to the system. The personally identifiable information includes your Name, Employment Title, Division or Place of Employment, and Employment Email Address.

Accountability for Onward Transfer

Trifecta does not transfer data to third parties outside of its agents. Trifecta will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Trifecta has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Trifecta will take reasonable steps to prevent or stop the use or disclosure. Trifecta is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles. Note: Trifecta may be required to disclose an individual’s personal information at Trifecta possession in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Integrity & Purpose Limitations

Trifecta is provided by its Client minimal business information including and limited to Physicians conducting Clinical Trials and their support staff Name, Employment Title, Division or Place of Employment, and Employment Email Address). Upon approval and direction of our Clients to process such information, Trifecta will use the above stated provided information only for the purpose of provisioning in Trifecta system and providing access to the Trifecta system as authorized by Trifecta Client.

Confidentiality & Security Procedures

Trifecta exercises different level of access restriction to nonpublic personal information about you to our employees in order to provide services to Client. Additionally, Trifecta maintains procedural, physical, and electronic safeguards that comply with the Federal regulations to guard your nonpublic information. The privacy policies described herein will be adhered to in the event you become an inactive as informed by Client. Trifecta is committed to protecting the confidentiality of Client provided personal information.

Log Files

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, referring/exit pages, internet service provider (ISP), operating system, user conducted tasks and the associated date/time stamp. We house this information as part of the system audit trail to support Trifecta Client during their Regulatory inspections for applicable audit trail requests. At no time does Trifecta utilize this information to analyze trends, user behavior, or to gather demographic information about our user base.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use session cookies for security. A session ID cookie expires when you close your browser. We set a session cookie at login to allow you to navigate through the many areas of our site while maintaining session data. No tracking is done using this cookie, nor is any personally identifiable information contained within the cookie.

If you reject cookies, you may not be able to use our site.

If you have questions or concerns regarding this statement, you should contact Trifecta Technical Support at 877.747.8638.

Access to Personally Identifiable Information

If your personally identifiable information changes or you want to limit the use and disclosure of your personal data, correct, or update it, you can contact Trifecta by emailing our Technical Support department at help@investig­atorspace.com / help@eprese­ntonline.com or by contacting us via telephone or postal mail at the contact information listed below.

Trifecta Multimedia, LLC DBA Trifecta Clinical®
725 South Figueroa Street
Suite 4050
Los Angeles, CA 90017

1·310·385·8642

Dispute Resolution Complaints Handling System

In compliance with the Privacy Shield Principles, Trifecta commits to resolve complaints about our use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Trifecta at privacyshield@tri­fectaclinical.com Trifecta has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Changes to the www.trifectaclinical.com Privacy Policy

If we (Trifecta) decide to change our privacy policy, we will post those changes to this privacy statement and other places we deem appropriate so that you are aware of what information we get provided, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here.