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Privacy Policy

Latest update: 23 March 2023

Please note that this privacy statement is intended for website visitors based in the Netherlands and is a direct translation of our Dutch privacy statement.

Brain Research Center Holding B.V. (hereinafter “Brain Research Center” or “we“), as a medical research firm, processes data about individuals. Your privacy is of great importance to Brain Research Center. In this Privacy and Cookie Statement we therefore inform you about how we handle personal data, which rights you have with respect to personal data that we process, how you can exercise these rights and where you can ask questions. This Privacy and Cookie Statement applies to all processing of personal data by or on behalf of the Brain Research Center.

Since May 25, 2018, the same privacy legislation applies throughout the EU: the General Data Protection Regulation (GDPR).

In the context of the GDPR, we are considered a data controller. Our contact details including the e-mail address where our data protection officer can be reached for privacy-related questions or comments can be found below:

Brain Research Center Holding B.V.
Croneburg 2
1081 GN Amsterdam, The Netherlands
fg@brainresearchcenter.nl

From whom do we collect what personal data?

We collect personal data from (potential) participants and their supervisors in clinical studies. We also collect data from applicants, (contact persons of) suppliers and third parties, such as visitors to our website, social media pages or our office. We obtain this data directly from you, using cookies or similar technologies, or from public sources (such as LinkedIn or a hospital website).

From all parties, we may collect the following personal data if necessary for the purpose:

  • NAW data (name, first names, initials, gender, address, zip code, city);
  • other (contact) data (telephone number, e-mail address and similar data required for communication).

In addition to these name and address details and other (contact) data, we may collect the following personal data, as described below for each party.

From (potential) participants in clinical studies we may collect the following additional personal data:

  • bank account number and data related to travel expenses (commuting distance);
  • medical data;
  • race and education level;
  • time of arrival and departure from the Brain Research Center office.

If you do not or no longer want us to collect this personal data, it is unfortunately not possible for you to (continue to) participate in a clinical study.

From suppliers and other service providers, we may collect the following personal data:

  • data for the purpose of placing orders or purchasing services;
  • data for the purpose of calculating and recording fees and expenses and making payments, including bank account number;
  • other data whose collection and processing is required to comply with applicable laws or regulations.
  • Time of arrival and departure from Brain Research Center office in case an appointment has been made

From job applicants, we may collect the following additional personal data:

  • bank account number and travel expense data (commuting distance);
  • nationality, date of birth;
  • availability, CV, employment history, educational history (copies of diplomas, certificates, testimonials), motivation letter;
  • references, data regarding the position applied for, interview notes and written communication with applicant;
  • time of arrival and departure from Brain Research Center office.

From website visitors, including subscribers to the online newsletter or requesters of information through the website, we may collect the following additional personal data:

  • data related to a visit to the website https://www.brainresearchcenter.nl/, such as for example “Cookies“; Details about cookies can be read and set during your visit to the website, in order to analyze and optimize the use of the website
  • data relating to electronic messages originating from or intended for third parties;
  • data necessary to maintain contact with these third parties;

We may collect the following additional personal information from other third parties (such as Brain Research Center office visitors):

  • data relating to electronic messages originating from or intended for third parties;
  • data necessary to maintain contact with these third parties;
  • other data obtained from public sources;
  • time of arrival and departure from Brain Research Center office.

For what purposes do we use your personal data?

We may use the above personal data for the purposes listed below:

  • So that we can investigate the possibility of your participation in a clinical study ((potential) clinical study participants);
  • So that we can conduct clinical studies in which you are participating (clinical study participants);
  • so that we can fulfill our obligations arising from a contract concluded with you, or to take action at your request prior to the conclusion of the contract (clinical trial participants, employees, suppliers);
  • For our administration (all parties);
  • to maintain contact with you and to communicate with you; also including communication for marketing and related activities such as sending newsletters or sending requested information (all parties);
  • for handling your job application (job applicants);
  • for ordering or purchasing services (suppliers);
  • for auditing and other internal control purposes (all parties);
  • to provide you with access to our website, to analyze and optimize your use of the website, and for the security of our website (website visitors);
  • to be able to take and automate the appropriate follow-up steps based on the information provided by you, such as sending you information by e-mail or contacting you by telephone for further questions
  • for the implementation or application of laws or regulations, including for cooperation in investigations by regulators (all parties);
  • for security purposes, including visitor registration (all involved);
  • to survey your experience with our website or services, for statistical purposes and to improve our website and services ((potential) clinical trial participants, website visitors);
  • to protect or enforce our rights and interests (all parties).

If we will further process your personal data for purposes other than those mentioned above, we will inform you in advance.

On what bases are your personal data processed?

We process your personal data on the basis of one or more of the following legal bases:

  • the performance of a contract concluded with you, or to take measures at your request prior to the conclusion of the contract;
  • When necessary to comply with a legal obligation;
  • a legitimate interest of us or a third party, such as our interest to analyze and optimize our services and the use of our website, and to protect our rights and interests;
  • your explicit consent.

When we process personal data based on your consent, we will ask you separately. You may withdraw consent at any time. The withdrawal of your consent does not mean that the processing of your personal data prior to the withdrawal of your consent is unlawful.

How long do we keep your personal data?

We do not retain your personal data for longer than is necessary to achieve the purposes stated in this Privacy and Cookie Statement in conjunction with the bases mentioned above.

The personal data you provide to Brain Research Center as a potential clinical trial participant in the pre-screening process, if you do not proceed to the screening process, will be kept for one year after this process in connection with its administrative processing . If you do not proceed directly to the screening process, but are placed on a waiting list with your consent, we will retain your data for up to 5 years. If you, as a potential participant, proceed from the pre-screening process to the screening process, your personal data will be kept for a maximum of 25 years, regardless of whether you ultimately participate in a clinical trial or not.

The personal data you provide to Brain Research Center as part of your application will be kept for the duration of the application process. At the end of the procedure, this personal data will be destroyed, if you are not hired or the assignment is not given to you . We may agree with you to keep your information longer with your consent for possible future job openings.

To the extent we retain your information to comply with legal retention obligations, such as the 7-year tax data retention requirement, we will retain it in accordance with the legal retention requirements.

Please feel free to contact us for further information on the retention periods we use.

With whom do we share your personal data?

Brain Research Center does not provide your data to third parties (“recipients” within the meaning of privacy legislation), unless necessary for the proper performance of the purposes and bases described in this Privacy and Cookie Statement for which the personal data have been processed. The third parties to whom the personal data are made available are obliged to treat your personal data confidentially. If these parties are designated as ‘processors’ within the meaning of privacy legislation, Brain Research Center will ensure that a processing agreement is concluded with these parties.

We may, with your consent, share personal data of (potential) clinical trial participants with:

  • the sponsors (these are the sponsors of the clinical study). In this case, your medical data will be shared without providing your other data such as name, date of birth, and contact information.
  • Your treating physician (if required, we may share study results with them upon request).
  • other parties (for example, an MRI center, PET center, or a pharmacy; in this case, we share only the necessary name and address data to request and schedule research).

We may also share personal data of job applicants with:

  • Suppliers, including IT service providers. These are mostly parties that process personal data on our behalf as processors within the meaning of the GDPR in order to provide a service to us (e.g. HomeRun)

We may also share third-party personal data with:

  • Suppliers, including IT service providers. These are mostly parties that process personal data on our behalf as a processor within the meaning of the GDPR in order to provide a service to us (e.g. Google Inc., Meta, Hotjar, Mailchimp, Active Campaign )

It may be necessary for us to transfer your personal data to a recipient in a country outside the European Economic Area that provides a lower level of protection of personal data than the European legislation. In such a case, Brain Research Center will ensure that this transfer of data complies with the applicable laws and regulations, for example, by concluding a model contract drawn up and approved for that purpose by the European Commission.

Security measures

We consider it very important that your personal data is properly secured. We therefore ensure that appropriate technical and organizational measures are taken to protect your personal data as much as reasonably possible against unauthorized use. Our employees have access to your data only on the basis of functional necessity, are bound by confidentiality and are bound by instructions aimed at the adequate protection of your personal data.

Unfortunately, sending information over the Internet is never completely secure. Despite our best efforts to protect and keep your personal data safe, we cannot guarantee that the submission of personal data by you to us is completely secure. Any submission of your personal information to us is therefore at your own risk.

We use secure connections to transfer data from us to you and third parties over the Internet. If you have further questions about the security of your personal data or suspect that there are indications of abuse, please send an e-mail to fg@brainresearchcenter.nl.

We will reply to your message as soon as possible and, if necessary, take appropriate measures.

Cookies

Our website uses cookies and similar technologies. Cookies are small text files that are placed on your computer, tablet or cell phone through our website and are read when you use our website. When you visit our website you will see a so-called cookie statement, which allows you to see what types of cookies we use; you can also set which types of cookies you do and do not want to allow.

We have also done the following to ensure your privacy:

  • concluded a processor agreement with Google
  • masked the last part of the IP address;
  • turned off ‘data sharing’;
  • not using other Google services in conjunction with the Google Analytics cookies.

Deleting cookies

Information on deleting cookies can also be found at the Consumers’ Association.

Links to social media and third party websites

Our website contains links to social media and third-party websites. We are not responsible for how personal data is collected and processed by these platforms for their own purposes and refer to the relevant privacy statements of the relevant social media for more information on their use of your personal data.

Your privacy rights

You have the following rights with respect to Brain Research Center’s processing of your personal data:

  • the right to request whether we are processing personal data about you and, if so, to access your personal data;
  • the right to rectification of your personal data if they are inaccurate or incomplete;
  • the right to have your personal data erased (‘right to be forgotten’);
  • the right to object to the processing of your personal data, including for marketing purposes, or to restrict the processing of your personal data;
  • the right to withdraw consent to processing of your personal data, if the processing is based on your consent;
  • the right to receive or transfer your personal data to a third party designated by you in a structured, common and machine-readable form (right to data portability);
  • the right to file a complaint with the competent supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens. If you live or work in another country of the European Economic Area, you can file a complaint with the supervisor in that country.

Requests to exercise your rights can be submitted by post or e-mail using the contact details provided at the top of this Privacy and Cookie Statement. We will inform you within one month of receiving your request whether Brain Research Center can fulfill your request. Under privacy laws, Brain Research Center may deny your request under certain circumstances. If this is the case, we will explain to you why we are refusing your request. You can read more information about your privacy rights on the website of the Personal Data Authority.

If you are considering filing a complaint with the Personal Data Authority, please do not hesitate to contact us first as we would like to resolve any complaints you may have with you.

Version information

Please note that this privacy statement is intended for website visitors based in the Netherlands and is a direct translation of our Dutch privacy statement.

This Privacy and Cookie Statement was last updated on March 23, 2023. We reserve the right to change this Privacy and Cookie Statement unilaterally and will always post the most recent version of this Privacy and Cookie Statement on our website, indicating the effective date of the changes. If there are substantial changes that may significantly affect one or more data subjects, we will endeavor to inform those data subjects immediately. We recommend that you regularly consult this Privacy and Cookie Statement.