1. Introduction

Centre d’Études Cliniques Ltée (“us”, “we”, or “our”) is concerned about the protection of your personal data. This Privacy Policy applies to the following interested parties but not limited to: potential customers, customers and volunteers. We are committed to protect all your personal information and this is our foremost priority. We undertake, in this respect, to treat all data, in accordance with:

  • Section 21, Data Protection Act 2017 (for which an annual fee is allocated for the same), on the protection of individuals with regard to the processing of their personal data and on the free movement of such data,
  • “GDPR” General Data Protection Regulation ((EU) 2016/679) (together hereinafter referred to as “Regulation”).

Procedures have also been set up to review and monitor the use of personal information so as ensure that data processing practices conform to the local data protection, The Data Protection Act 2017 (Mauritius).

http://dataprotection.govmu.org/English/Legislation/Pages/Data-Protection-Act-2017-.aspx

  1. Aim of the Privacy Policy

The overall aim of this  policy is to guide you on how we collect and process your personal information that comprises of data which you provide through the website or by other means. We may process your personal data for our main legitimate business interest that is clinical trials.

We respect your right to privacy and the following statement sets out how we collect and treat your personal information. The policy applies to www.centredetudescliniques.com and Centre d’Etudes Cliniques Ltée (CEC).

By using the CEC website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in the Privacy Policy, terms used in this Privacy Policy have the same meaning as in our Terms and Conditions and Cookie Policy, accessible on www.centredetudescliniques.com

  1. Site for Safeguarding Personal Data

Your personal data are collected by the CEC, registered with the Registrar of Company under Business Registration Number, C17149694, whose head office is located at 6, Lancaster Court, Lavoquer Street, Port Louis 11328, Mauritius.

CEC has initiated the appropriate safety measures to avoid your personal information from being unintentionally lost, used, altered, disclosed and/or accessed in any illegal manner. On the same line, the access to your personal data is limited to only those persons who have signed a confidential agreement for non-disclosure of personal data.

  1. Delegated Person for Communication

CEC has nominated a staff member as correspondent in the name of Mr. Ravi PEENITH. In case of any queries or clarification, or request to exercise your legal rights, you may contact the delegated person, available at any time on the following email address: ravi.peenith@centredetudescliniques.com

If you have any complaint regarding this Privacy Policy or if you feel your rights have been violated, please contact us and we shall take the necessary actions at soonest. Nonetheless, nothing restricts you from contacting the supervisory authority responsible for Data Protection in Mauritius which is the Data Protection Office (Level 5, SICOM Tower, Wall Street, Ebène Cyber City, Republic of Mauritius).

  1. Personal Information We Collect

a. Personal Data

Personal data or personal information is information about an individual from which the latter can be identified. (https://ico.org.uk/media/fororganisations/documents/1554/determining-what-is-personal-data.pdf)

We may require personal information from you as part of the services managed by CEC as an Independent Contract-Research-Organisation (CRO). This may include the following but not limited to, your first and last name, phone number, address, state, province, ZIP/Postal code, city, email address and the like. Data about study volunteers is treated with strict discretion and is provided in a de-identified format (format where a person’s identification cannot be reasonably identified) so as to preserve volunteer’s rights to privacy.

Your personal data is of utmost importance to us and failure to provide us with the right and appropriate requested personal data, will consider being unethical and such information would be wrongfully processed. Therefore, any misleading information will result in cancellation/ rejection of the registrations in the good faith of our operations/ doings.

Hence, it is utterly your duty to inform us as soon as possible about any changes regarding your personal data.

b. Use of Personal Data

Your personal data is collected by the CEC in line with its operation and the data is processed as per the requirements of the clients and as part of our services offered which are, but not limited to; selection and inclusion of volunteers, collection of medical data, statistical analysis, results and amongst others.

c. Recipients of your Personal Data

Your personal data that is revealed to us is strictly confidential and intended exclusively for CEC’s operations. The data is not in any case transferred or rented to unauthorized third parties unless the approval from CEC Management has been sought. The data is limited to delegated CEC staff and shall, under no circumstances, be used for commercial or non-clinical purposes.

d. Shelf Life of your Personal Data

CEC is accountable to preserve your personal data for only a period strictly necessary for the purpose of its operations, which includes the aim of satisfying legal requirements, accounting or reporting procedures.

In the light to determine the necessary retention time of your personal information, the nature, amount and sensitivity of your personal information, risk of possible harm from illegal manipulation or divulgation of your personal information, are basically taken into consideration and are in line with CEC established procedures.

Basic information on our customers, suppliers/partners, employees (including contact details, identity, and transaction information) is kept for a minimum of 10 years after they discontinue being in contract with us for tax and legal purposes. Regarding, volunteers’ personal data, the latter is kept for at least 5 years if they have not participated in any study, or 10 years from the Closing date of the last participation.

Under certain conditions, you can exercise your rights under the Data Protection Act 2017 (Part VII) and the GDPR (Art. 12-23) pertaining to your personal data.

e. Inquiry on your Personal Data

In case, you request access to your personal data (or the need to exercise other rights), you may do so, free of charge. However, a reasonable fee may be charged or we may refuse to undertake your requested actions if your request is deemed as baseless, repetitive or excessive. If your identity is considered to be doubtful, we may request you to provide us with further information to confirm your identity before providing you access to your personal data. Nonetheless, in case we refuse to comply with your request, we will inform you the reason of the refusal, in writing. We shall attempt to respond to all reasonable requests within one month. However, it may be possible to exceed a month to respond to your request, depending on the complexity and number of requests made.  (Section 37) Data Protection Act 2017).

f. Rights on your Personal Data

In line with the Data Protection Act 2017 and the GDPR, you have certain rights that you may exercise related to your personal data.

  • Right of access

You have the right to request an access to your personal data. This allows you to have a copy of your personal information we hold and information on the purpose of the processing of the data. You may also request the correction and erasure of your personal data or to object for such processing. You also have the right to lodge a complaint with a supervisory authority, pertaining to unauthorized processing.

  • Right to rectification

You have the right to rectify any incomplete or inaccurate information related to your personal data in our database. However, certain procedures will be enforced to ensure that the new data provided is accurate.

  • Right to erasure

You are allowed to request the erasure of your personal information if the data become obsolete for processing or if you withdraw on the processing of your personal information. You may also exercise this right if you object for the processing of the data or if the data has been unlawfully processed. However, in certain cases, we may not adhere to your request of erasure due to specific legal reasons which will be communicated to you, when applicable.

  • Right to restriction of processing

You have the right to ask us to restrict the processing of your personal data if,

  1. You contest the accuracy of your personal information,
  2. You want us to delete your personal data in case of unlawful processing,
  3. You want us to hold your personal data, even when it is not required to us, for your need of establishing, exercising or defending legal claims,
  4. We are in the obligation to verify if we have prevailing legal grounds to use it, even if you object to our use.
  • Right to object

You may object, for legitimate reasons, to the processing of your personal information. You are also allowed to object to the processing of your personal data if we are processing it for direct marketing purposes. We shall no longer process your personal data unless, we exhibit legal purposes which revoke your interests, rights and freedom.

  • Right to Data Portability

You have the right to request the transfer of your personal data to you or to another data controller (third-party) in a commonly used machine-readable format. However, this request will be entertained in a lawful manner and only automated information that was initially provided in consent to our usage or to bind contract with you, shall be concerned.

You can exercise your rights by contacting our delegated data controller by email at the following address: ravi.peenith@centredetudescliniques.com

g. Transfer of your Personal Data

Your information, including Personal Data, may be transferred to and maintained on systems located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are a foreign resident and choose to provide information to us, please note that we transfer the data, including Personal Data, to Mauritius and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We have taken all the necessary and reasonably steps, in the light to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will be effected to an organization or a country unless we are convinced that there are adequate controls in those places including the security of your data and other personal information.

h. Disclosure of your Personal Data

Some of your personal data may be shared to third parties, mainly to our customers, in line with our legitimate business interest. However, your shared personal information will be in a de-identified format, thus your shared personal data will remain anonymous.

CEC may also disclose your Personal Information in the good faith that such action is necessary:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of CEC.
  • To prevent or investigate possible wrong doing in connection with the Service.
  • To protect the personal safety of users of the Service or the public.
  • To protect against legal liability.
  1. Adjustment of purpose

Your personal data will be used for the sole purpose of its legal business framework, unless, for any other justified reason which is consistent to its original aims, we may logically consider using it in another way. In case you need further explanation regarding this new adjustment and its data processing, you may contact our data controller.

In case we require to use your personal information for any unrelated purpose, we will notify and explain to you the legal framework that permits us to do so.

  1. Automated Interactions Technologies

We may collect information such as the usage and activities on our website using cookies and other similar tracking technologies. Please review our Cookies Policy for more information.

  1. Children’s Privacy

Our Service does not address anyone under the age of 16 (“Children”) according to the Data Protection Act 2017 (Section 30.), without consent of the respective parent or guardian. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our system.

  1. Service Providers

We may outsource a third party (companies and/or individuals) to perform ‘in part’ or ‘in full’ our core operations (“Service Providers”). Therefore, the third parties contracted will have access to your personal data only to perform the specified tasks on our behalf and are obliged not to disclose or use it for any purpose as per our legally binding confidentiality agreement.

  1. Amendment to the Data Protection Policy

We may update our Privacy Policy from time to time and any changes effected, will be communicated to you by posting the new Privacy Policy on this page. We will let you know via email and/ or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  1. Contact Us

CEC welcomes your questions and comments regarding clarification or explanation about this Privacy Policy. We remain at your disposal:

  • By email: info@centredetudescliniques.com
  • By mail : Centre d’Etudes Cliniques,
    6 Lancaster Court, Lavoquer Street,
    Port Louis 11328  Mauritius
  • By phone number: (230) 214 14 05