Effective May 8, 2018

Your Privacy Matters!

Our privacy policy has been updated according to General Data Protection Regulations effective on 25th May 2018 released by EU.
This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy and Settings.

Table of Contents:

• Introduction
• Data We Collect
• How We Use Your Data
• How We Share Information
• Your Choices & Obligations
• Other Important Information

Introduction

Our registered users (“Members”) use Services to manage clinical trials, collect electronic data, get information, etc. Content and data on some of our Services is viewable to non-members (“Visitors”).

Services

This Privacy Policy, including our Cookie Policy applies to your use of our Services.
This Privacy Policy applies to Shanhu.com, Shanhu-branded apps, Slideshare, Shanhu Learning and other Shanhu-related sites, apps, communications and services (“Services”).

Data Controllers and Contracting Parties

Shanhu will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services; you are entering into the User Agreement with Shanhu.
As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”
Shanhu (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close or inactivate your account according to local regulations.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, email address and/or mobile number, organization, role and a password.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data).
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to manage clinical trials over our Services.

1.2 Data From Others

Others may post or write about you (e.g. PM may request accounts to CRA and site staff). Customers and partners may provide data to us.

We receive personal data about you when you use the services of our customers and partners, such as sponsors, CROs and other organization request accounts for you.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.
As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We don’t allow others to use our cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, you leave message in our wechat public account.

1.7 Other

We are improving our Services, which means we get new data and create new ways to use data.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, our Services (including ads) so that they can be more relevant and useful to you and others, e.g. we provide specific functionality based on your role.

2.1 Services

Our Services help you manage clinical trials, collect data, get information etc., so that be more productive.
We use your data to authorize access to our Services.

Stay Connected

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts in clinical trials.

Stay Informed

Our Services allow you to stay informed about study or site status you are authorized to. Our Services also allow you to improve your professional skills, or learn new ones in managing clinical trials. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content to help you know your study status on our Services.

Productivity

Our Services allow you to collaborate with colleagues, and other users in same clinical trial, e.g. supplies manager, site staff, project manager, CRAs, etc.

2.2 Communications

We contact you and update your study information. We offer settings to control messages you receive in email sent by system.

2.3 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience.

Other Research

We make clinical trials smart and help users be more productive and successful in clinical trial management. We use available data to research clinical trial management, key points, to provide relevant reports on our Services. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish clinical trial insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.

2.4 Customer Support

We use data to help you and fix problems.
We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

2.5 Aggregate Insights

We use data to generate aggregate insights.
We use your data to produce and share aggregated insights that do not identify you.

2.6 Security and Investigations

We use data for security, fraud prevention and investigations.
We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

3.1 Our Services

Some data (e.g. name, email, phone number) that you include on your profile and relevant content you post on our Services will be seen by others, e.g. notice, notifications.

Profile

Partial data of your profile is visible to the Members in the same clinical trial on our Services so that clinical trial can be managed efficiently.

3.2 Communication Archival

All clinical trial relevant information will be archived accordingly to clinical trial regulations, including your login trail, operation history and notifications sent by system.

3.3 Related Services

We share your data across our different Services and Shanhu-affiliated entities.
We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we are able to identify you across different Services using cookies or similar technologies to ensure consistency across our different Services.

3.5 Service Providers

We may use others to help us with our Services.
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.6 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Shanhu, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.7 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your clinical trial is active and during archived period required by clinical trial regulations.
We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you temporarily or forever quit from your clinical trial, we will retain your information according to clinical trial regulations.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and communication controls. We offer you settings to control and manage the personal data we have about you.
For personal data that we have about you:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Visitors may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

4.3 Account Closure

We keep some of your data even after you close your account.
If you choose to close your Shanhu account, we generally delete closed account information according to clinical trial regulations, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
Information you have shared with others (e.g., through notifications, notice) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., in archived clinical trial relevant information) until it meets all clinical trial regulation requirements.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please visit our Wechat public account for additional information about safely using our Services.

5.2. Cross-Border Data Transfers

We store and use your data outside your country.
We process data both inside and outside of the People’s Republic of China and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.
At any time, you can withdraw consent you have provided by going to settings.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Shanhu Services you have requested)) and “legitimate interests”.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Mail dataprotection@irtone.com.

5.4. Contact Information

You can contact us or use other options to resolve any complaints.
If you have questions or complaints regarding this Policy, please first contact dataprotection@irtone.com or leave message on our Wechat public account online. You can also reach us by physical mail.