This privacy notice is addressed to: Clinical investigators (principal investigators, sub-investigators or co-investigators); Other site staff such as nurses, pharmacists or technicians, whose Personal Data may be processed in the course of the clinical trials and studies sponsored or organized by Tropical. You are receiving this Privacy Notice because Tropical Clinical Trials (“Tropical”, “we” or “us”) will process information about you, which constitutes “Personal Data.” This privacy notice is provided to you to ensure transparency in relation to collection, use and disclosure of your Personal Data by Tropical for purposes related to the conduct of clinical trials and non-interventional studies (collectively “Clinical Studies”) sponsored or organized by Tropical (“Tropical Clinical Studies”) and/or its affiliates which are being carried at your Clinical Trial Site (the “Site”). For the purposes described in this Privacy Notice, Tropical is responsible for the processing of your Personal Data acting as a “Controller”. We invite you to read this Privacy Notice carefully, as it contains important information. What Personal Data do we collect and use? For the purposes described in this Privacy Notice, we may collect the following information about you, including: name, identification number, address and other contact details, financial information (e.g. bank account number, financial interests in any of the Tropical Group companies), qualifications, publications and information contained in the CV you provide to us where necessary, previous experience and other information regarding your participation in Clinical Studies within or outside of Tropical and the training you have received, technical data related to your use of Tropical IT systems. Why do we collect and use Personal Data? Your Personal Data may be used by us for the purposes and on legal bases specified below. Processing purpose Legal basis 1. To conduct Tropical Clinical Studies in accordance with good clinical practice and applicable laws. Our legitimate interest in conducting Clinical Studies to test potential treatments as well as compliance with legal and regulatory obligations; 2. To support applications for and to comply with the conditions of any marketing approval granted in respect of any medication studied under a Tropical Clinical Study (“Study Medication”). Compliance with legal and regulatory obligations. 3. To support applications to vary the terms of any marketing approval granted in respect of a Study Medication. Our legitimate interest in conducting Clinical Studies to test potential treatments. 4. To carry out research related to the development of pharmaceutical products, diagnostics or medical aids and improve Clinical Study practice. 5. To inform you, plan and/or conduct other Clinical Studies including to identify suitable investigators for our studies. 6. To share information with other companies or industry organizations in the context of planning and conducting Clinical Studies. 7. To assess the effectiveness of the sites participating in our studies. 8. To support recruitment of study subjects (for this purpose your name and contact information may be used for study advertisements in print and online media). 9. To comply with the US Financial Disclosure regulation, which is intended to ensure that financial interests and arrangements of clinical investigators that could affect the reliability of data submitted to the Federal Drug Administration of the U.S.A. (“FDA”) are identified and disclosed to the FDA¹ and other disclosure obligations as required by applicable laws and regulations. Our legitimate interest in this purpose as well as compliance with legal and regulatory obligations. 10. To ensure traceability and follow-up of drug safety notification. Compliance with legal and regulatory obligations. Please note that in some countries, consent is the basis on which Personal Data is processed.
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