Effective on: March 1, 2024
Last updated on: February 29, 2024

Introduction

Rho, Inc. and all affiliates listed below under “Entities Covered by This Privacy Notice” (collectively “Rho”, “we”, “us”, “our”) take the protection of personal data (“Personal Data”) very seriously. Please read this privacy notice (the “Notice”) to learn what we are doing with your Personal Data, how we protect it, and what privacy rights you may have under applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”).

What Is Covered by this Privacy Notice?

This Notice addresses data subjects (which includes both individuals and households) whose Personal Data we receive and process:

• on our website RhoWorld.com and its contact forms (the “Website”);
• on our official social media accounts, including, without limitation, LinkedIn, Twitter, Facebook, Instagram, and YouTube (the “Social Media Platforms”);
• in a variety of third-party commercial tools, including our customer relationship management application, HubSpot, for the purpose of marketing, advertising, and selling our services to potential customers (collectively, with the Website and the Social Media Platforms, the “Sales and Marketing Activities”); and
• based on their relationship with us and our affiliates and subsidiaries in connection with the conduct of clinical trials, such as Principal Investigators at a clinical trial site and other investigative clinical trial site staff (“Trial Personnel”).

What Is Not Covered by this Privacy Notice?

Personal Data Processed on Behalf of Our Customers

This Notice does not apply to the Personal Data we process on behalf of our customers when providing our Contract Research Organization (“CRO”) services (the “Services”).

Human Resources Personal Data

This Notice does not apply to the Personal Data of employees, job applicants, contractors, business owners, directors, officers, or medical staff of Rho.

Information Which Does Not Constitute Personal Data

If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered Personal Data and this Notice will not apply to our processing of that information.

What Can You Find in this Notice?

This Notice tells you, among other things:

• What Personal Data we collect about you and how we obtain it;
• The legal bases for processing your Personal Data;
• For what purposes we use that Personal Data;
• How long we keep your Personal Data;
• To whom we disclose your Personal Data;
• Your rights about the Personal Data we collect about you and how you can exercise those rights;
• How we protect your Personal Data; and
• How to contact us.

Our Role with Respect to Your Personal Data

Within the scope of this Notice, Rho acts as a data controller or “business” for the Personal Data we process. This means that we decide how and why Personal Data is collected and further processed.

Entities Covered by this Privacy Notice

This Notice covers Rho and the following affiliate entities (the “Affiliates”):

• Dokumeds SIA
• Dokumeds SIA German Branch
• Dokumeds EESTI FILIAAL
• Ribotos Atsakomybės Bendrovės “Dokumeds” Atstovybė
• Dokumeds SIA Branch in Poland (DOKUMEDS SABIEDRIBA AR IEROBEŽOTU ATBILDIBU SP Z O O ODDZIAŁ W POLSCE)
• Representative Office “Dokumeds Ltd (Latvia) (Представительство ООО «Докумедс» (Латвия))
• Representative office of DOKUMEDS SIA in Ukraine (ПРЕДСТАВИТЕЛЬСТВО СИА ДОКУМЕДС)

Lawful Basis for Processing

We must have a valid reason to use your Personal Data. This is called the “lawful basis for processing.”

As a data controller, we may process your Personal Data on the basis of:

• your consent;
• our legitimate interests, such as our business interest in marketing our Services to potential customers; or
• any other ground, as required or permitted by law.

When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis. To do so, please use the contact details provided here.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

What Personal Data We Process and How We Obtain It

The table below describes the categories of Personal Data we have collected about you in the last twelve months.

We will not collect additional categories of Personal Data without informing you.  We do not collect sensitive personal information (as that term is defined in the CCPA) within the context of this Notice.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, Website functionality, authentication (session management), usage analytics (web analytics), to remember your settings, and to generally improve our Website.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Website are first-party cookies which are placed directly by us. Other parties, such as Google and HubSpot, may also set their own (third-party) cookies through our Website. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all features of our Website. For more information, please visit https://www.aboutcookies.org/.

To opt-out of analysis by Google Analytics on our website and other websites, please visit http://tools.google.com/dlpage/gaoptout.

For more information about our use of cookies, please see our Cookie Notice.

For What Purposes Do We Use Your Personal Data?

 

We may process your Personal Data for the following purposes:

• Conducting our Sales and Marketing Activities;
• Responding to your requests or inquiries you send us through the contact forms available on our Website;
• Contacting you about the Services that Rho has to offer and which we think may interest you; and
• Maintaining the functionality and security of our Website.

How Long We Keep Your Personal Data

We will retain your Personal Data for as long as is necessary to fulfill the purpose for which we collected your Personal Data and any other permitted linked purpose and in compliance with our data retention policies. For example, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Generally, we retain usage data for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.

If your Personal Data is used for more than one purpose, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that period expires. Our retention periods are also based on our business needs and good practice.

Disclosing Personal Data to Third Parties

The following table describes, in the last twelve months, the categories of information we have disclosed to third parties for business purposes, and the categories of those third parties.

Some of these third parties may be located outside of the European Union or the European Economic Area (“EEA”). In some cases, the European Commission may have determined that in some countries, data protection laws provide a level of protection equivalent to European Union law. You can see here the list of countries that the European Commission has recognized as providing an adequate level of protection to personal data. We will only transfer your Personal Data to third parties in countries not recognized as providing an adequate level of protection to personal data when there are appropriate safeguards in place. These safeguards may include the Standard Contractual Clauses as approved by the European Commission under Article 46.2 of the GDPR.

Other Disclosures of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our Affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, sell, share, and disclose aggregated, anonymous data for any legal purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

What Privacy Rights Do You Have?

You have specific rights regarding your Personal Data that we collect and process. Please note that you can only exercise these rights with respect to Personal Data that we process about you when we act as a data controller under the GDPR or as a “business” under the CCPA. To exercise your rights with respect to information processed by us on behalf of one of our customers, please read the privacy notice of that customer.

In this section, we first describe those rights and then we explain how you can exercise those rights.

Right to Know What Happens to Your Personal Data

This is called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things.

We are informing you of how we process your Personal Data with this Notice.

We will always try to inform you about how we process your Personal Data. However, if we do not collect the Personal Data directly from you, the GDPR exempts us from the obligation to inform you (i) when providing the information is either impossible or unreasonably expensive; (ii) the gathering and/or transmission is required by law, or if (iii) the Personal Data must remain confidential due to professional secrecy or other statutory secrecy obligations.

Right to Know What Personal Data Rho Has About You

This is called the right of access. This right allows you to ask for full details of the Personal Data we hold about you.

You have the right to obtain from us, including confirmation of whether or not we process Personal Data concerning you, and, where that is the case, a copy of or access to the Personal Data and certain related information.

Once we receive and confirm that the request came from you or your authorized agent, we will disclose to you:

• The categories of your Personal Data that we process;
• The categories of sources for your Personal Data;
• Our purposes for processing your Personal Data;
• Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period;
• The categories of third parties to whom we disclose your Personal Data;
• If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
• The specific pieces of Personal Data we process about you in an easily-sharable format;
• If we disclosed your Personal Data for a business purpose, the categories of Personal Data and categories of recipients of that Personal Data for disclosure;
• If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests; and
• The appropriate safeguards used to transfer Personal Data from the EEA or the UK to a third country, if applicable.

Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.

The CCPA does not allow us to disclose Social Security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, account passwords, or security questions and answers. We can inform you that we have this information generally, but we may not provide the specific numbers, passwords, etc. to you for security and legal reasons.

Right to Change Your Personal Data

This is called the right to rectification. It gives you the right to ask us to correct without undue delay anything that you think is wrong with the Personal Data we have on file about you, and to complete any incomplete Personal Data.

Please contact us and we will do our best to change the Personal Data for you.

Right to Delete Your Personal Data

This is called the right to erasure, right to deletion, or the right to be forgotten. This right means you can ask for your Personal Data to be deleted.

If you would like to request that we delete your Personal Data in our possession, please submit a request as directed here.

Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.

Right to Ask Us to Limit How We Process Your Personal Data

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.

Right to Ask Us to Stop Using Your Personal Data

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party). You may also object at any time to the processing of your Personal Data for direct marketing purposes.

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

Right to Port or Move Your Personal Data

This is called the right to data portability. It is the right to ask for and receive a portable copy of your Personal Data that you have given us or that you have generated by using our Website, so that you can:

• Move it;
• Copy it;
• Keep it for yourself; or
• Transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you a copy in electronic format.

Right to Withdraw Your Consent

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.

If you have given consent for your details to be provided to a third party and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless the applicable data protection laws permit it, we will not:

• Deny you access to our Website;
• Charge you different prices or rates for our Website, including through granting discounts or other benefits or imposing penalties;
• Provide you a different level or quality of our Website; or
• Suggest that you may receive a different price or rate for our Website or a different level or quality of our Website.

How Can You Exercise Your Privacy Rights?

To exercise any of the rights described above, please submit a request by either:

1. Calling us at 919-408-8000

2. Contacting us by email at data_privacy@rhoworld.com

3. Writing to us at:
Rho, Inc.,
Attn: Rho Privacy Team
2635 East NC Hwy 54
Durham, NC 27713
USA; or

4. Filling out this online contact form.

Verification of Your Identity

In order to correctly respond to your privacy rights requests, we need to confirm that YOU made the request. Consequently, we may require additional information to confirm that you are who you say you are.

For requests sent by one of the means listed here, we will verify your identity by asking you about information that matches the information that we already have about you.

We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

Verification of Authority

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with Rho and confirm with us that they gave you permission to submit this request.

Response Timing and Format of Our Responses

We will confirm the receipt of your request within ten (10) business days and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to a month to reply to your requests (except requests to stop selling or sharing your Personal Data) from the day we received your request. If we need more time (up to 90 days in total), we will inform you of the reason why and the extension period in writing.

If we cannot satisfy a request, we will explain why in our response. For data portability requests, we will choose a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without difficulty.

We will not charge a fee for processing or responding to your requests. However, we may charge a fee if we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

Privacy of Children

The Website and the Sales and Marketing Activities are not directed at, or intended for use by, children under the age of 16.

Data Integrity & Security

We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction. Some of those measures include encryption, and we also have dedicated teams to look after information security and privacy. Your Personal Data is contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

Right to Lodge a Complaint with a Supervisory Authority

If the GDPR applies to our processing of your Personal Data, you have the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data.

Specifically, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or the alleged violation of the GDPR.

Changes to this Notice

If we make any material change to this Notice, we will post the revised Notice to this web page. We will also update the “Effective” date.

Contact Us

If you have any questions about this Notice or our processing of your Personal Data, or want to submit a verifiable consumer request, please write to the Rho Privacy Team by email at data_privacy@rhoworld.com or call at 919-408-8000 or by postal mail at:

Rho, Inc.
Attn: Rho Privacy Team
2635 East NC Hwy 54
Durham, NC 27713
USA

Please allow up to thirty (30) days  for us to reply.

European Union Representative

Our  representative in the EU for data protection matters is Dokumeds SIA, which can be contacted at:

Dokumeds SIA
Katrinas dambis 20
Riga, LV-1045 Latvia
privacy@dokumeds.com

United Kingdom Representative

Our representative in the UK for data protection matters is RhoWorld UK, LTD, which can be contacted at:

RhoWorld UK LTD
Squires House
205A High Street
West Wickham
BR4 0PH, Kent
United Kingdom
Data_Privacy@rhoworld.com

Icons Used in This Notice

This Notice uses DaPIS, the Data Protection Icon Set (DAPIS). DaPIS is licensed under the Creative Commons Attribution-ShareAlike 4.0 International License. Please refer to  http://gdprbydesign.cirsfid.unibo.it//to learn more about this project.