Privacy policy

At Reify Health, privacy is a priority. 

This Privacy Policy describes how Reify Health, Inc. and its affiliates (collectively “we,” “us,” “our,” or “Reify”) collect, use, share, and secure personal data through Reify Health’s website located at https://www.reifyhealth.com (“Website”) or the StudyTeam platform and any related services provided by Reify (together, the “Services”). 

The Services are designed primarily for use by organizations such as clinical trial sponsors and sites, including their authorized representatives (“Customers”). In the event of a conflict between this Privacy Policy and the terms of any written agreement(s) between Reify and a Customer, the terms of those agreement(s) will control to the extent of the conflict.

1. Reify's Role

Reify’s role with respect to personal data depends on several factors, including Reify’s Customer agreements. The following table identifies Reify’s data processing role in the various scenarios in which Reify interacts with our customers’ or patients’ personal data.

Description of Personal Data

Reify’s Role

Data provided to the Services by a Customer.

Data Processor

User access credentials, user analytics (including data collected through cookies).

Data Controller

Data submitted to Reify or the Services directly by the data subject or their representative.

Data Controller

2. Personal Data Collected by Reify

Reify as Data Controller. When Reify is the Data Controller, we collect personal data through our Website, the StudyTeam application and through our interactions with you. Examples of this data include the login credentials used to access the Services, user contact information, and analytics associated with data entered or actions taken when interacting with the Website or Services.

Reify’s Use of Cookies. Reify may automatically collect information that your browser sends when you visit our Website or use our Services. (The mechanisms we use to collect this information are referred to in this policy as “Automatic Data Collection Tools”). Examples of Automatic Data Collection Tools we may use include: cookies; pixel tags; web beacons; and embedded web links. These Automatic Data Collection Tools collect certain standard information such as your Internet Protocol (“IP”) address, browser type, operating system, cookie data, access times, user-agent string, and click-stream behavior. Reify uses this information to monitor the usage of our Website and Services and to understand how to serve our users better. 

If you prefer Reify not use Automatic Data Collection Tools when you interact with our Website or the Services, you may decline to provide consent when prompted, or you may update or revoke your consent at any time using the link provided at the top of our Cookie Policy.

For additional information regarding our usage of Automatic Data Collection Tools, please see our Cookie Policy.

Reify as Data Processor. When Reify is the Data Processor, we process personal data that our Customers have provided to the Services in order for us to deliver those Services. This may include information about individuals who are candidates for, or participants in, clinical trials. When Reify is a Data Processor, we comply with our contractual obligations to our Customers as well as with the terms of this Privacy Policy.

3. Use of Personal Data

Reify does not process personal data without a valid legal basis. Here is more information about how and why we may process personal data:

To Facilitate the Use of our Services. Subject to our Customer agreements, Reify may use personal data to communicate with Customers (including Customer users) about user accounts, respond to Customer inquiries, comply with Customer instructions, and provide the Services. For example, Reify may use personal data to send critical updates and notifications to Customer users to ensure security and to prevent fraudulent activity.

To Operate, Secure, and Improve our Services. Reify may use personal data to operate, secure, and improve our Services. For example, Reify may use aggregated data for business or research purposes such as to ascertain industry trends, to analyze privacy and security patterns, for internal record management and reporting, to perform statistical analyses, and to monitor compliance with our Customer agreements.

For Marketing and Promotional Purposes. Reify may use personal data, with prior consent where needed, to communicate relevant marketing and promotional content. If you would like to discontinue receiving this information from us, you may update your preferences by using the link found in the bottom of the email communications you receive, or you may contact privacyofficer@reifyhealth.com.

To Comply with Law. Reify may use personal data as required to comply with applicable law. 

4. Sharing of Personal Data

Reify requires all third-party subprocessors to meet Reify’s privacy and security standards, which include entering into written agreements to safeguard the confidentiality, security, and integrity of personal data. Reify takes precautions to ensure that any onward transfer of personal data is under terms that are consistent with this Privacy Policy. 

Reify may share personal data with third parties for purposes of providing the Services, for example to facilitate communications with our Customers, to monitor the security of our application, and to provide our cloud computing infrastructure. For a current list of these subprocessors, please visit https://www.studyteamapp.com/Subprocessors.html.

Reify also uses third parties to communicate marketing and promotional content. Additionally, Reify may disclose personal data to the extent necessary to comply with law.

5. International Data Transfers

Although Reify is based in the United States, we operate globally. Our Services are supported by regional datacenters worldwide, including within the European Union, Japan, and the United States.

Personal data may be transferred from the country of origin to one of the regional datacenters used by Reify. In such cases, Reify takes the necessary measures to ensure that personal data transferred receives adequate levels of protection as required by Privacy Laws. As appropriate, Reify requires third parties to sign international data transfer agreements to facilitate these transfers. Reify complies with laws governing the transfer of personal data between countries to help ensure that your personal data is protected.

Privacy Shield. While Reify recognizes that the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks are no longer valid transfer mechanisms for personal data from the EEA or Switzerland, the U.S. Department of Commerce has stated that it will continue to administer the Privacy Shield program and that participants are not relieved of their obligations under Privacy Shield. Reify therefore will continue to maintain compliance with its commitments under the Privacy Shield.

Reify complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States. Reify has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Reify is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Consistent with the Privacy Shield and in compliance with this Privacy Policy, Reify may transfer personal data to third parties across national borders. To the extent required under the Privacy Shield, Reify remains liable if a third party engaged by Reify to process personal data on Reify's behalf does so in a manner inconsistent with the principles of the Privacy Shield, unless Reify proves that it is not responsible for the matter giving rise to the damage.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For more information about binding arbitration under the Privacy Shield, to learn more about the Privacy Shield program, or to view our certification, please visit https://www.privacyshield.gov/.

Please note that Reify protects all cross-border transfers of personal data in accordance with current legal requirements including, where appropriate, with the use of standard contractual clauses approved by the European Commission.

6. Individual Rights to Personal Data

Reify’s Privacy Policy either meets or exceeds the requirements of global privacy laws. In relation to the personal data for which Reify acts as the data controller, individuals are invited to exercise the rights established by applicable data protection law. These rights may include:

  • Right to Access. Individuals may have the right to request confirmation of whether we are processing their personal data. Individuals may also have the right to request access and obtain copies of their personal data. 
  • Right to Rectification. Individuals may have the right to amend or correct their personal data, as permitted by law.
  • Right to Erasure. Individuals may have the right to request erasure of their personal data, as permitted by law.
  • Right to Restrict Processing. Individuals may have the right to request a restriction or limitation of Reify’s processing of their personal data, as permitted by law.
  • Right to Withdraw Consent. Where Reify’s processing activity is based on consent, individuals have the right to revoke their consent to our further processing of their personal data, as permitted by law.
  • Right to Data Portability. Individuals may have the right to receive their personal data, in a structured, commonly used, and machine-readable format, and to have that information transmitted to another organization under certain circumstances.
  • Right to Object. Individuals may have the right to object to Reify’s processing of personal data, as permitted by law. 
  • Rights in Relation to Automated Decision Making and Profiling. Individuals may have the right to object to being subject to a decision based solely on automated processing and profiling that legally or significantly affects them.
  • Right to Lodge a Complaint. Individuals always have the right to lodge complaints relating to the processing of their personal data with the relevant data protection supervisory authority.

To exercise these rights or for additional information or clarification, please email us at privacyofficer@reifyhealth.com

7. Children's Privacy

Our Website and Services are not intended for children, and we do not knowingly collect personal data from children under the age of 16. Children under the age of 16 are not invited to access, use, or submit, any personal data through our Website or Services.

If a child has provided us with personal data, a parent or guardian of that child may contact us at privacyofficer@reifyhealth.com with “Request for Child Information Removal” in the subject line. Upon verification, we will remove the child’s personal data from our databases.

8. Third Party Privacy Policies

Once you navigate away from our Website or the Services, the privacy policies of the site(s) to which you navigate will apply. This Privacy Policy applies solely to your interactions with, and information collected through, our Website and Services.

9. Data Retention

Reify retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy, Customer agreements, or as required by law.

10. Safeguards

We take reasonable precautions and follow standard industry practices to make sure your personal data is not impermissibly accessed, used, or disclosed. While we have reasonable safeguards in place to protect your personal data, and although we frequently review and try to improve the security of our Website and Services, we cannot guarantee that a third party will not impermissibly gain access to any information provided to or collected through our Website or Services.

If you have any questions about the security of personal data, please contact us at support@reifyhealth.com.

11. Changes To This Policy

Reify may modify this Privacy Policy from time to time without prior notice by publishing a new version of this Privacy Policy on our Website and Services. Any changes to the Privacy Policy will become effective immediately upon publication. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal data we collect. Please check the date on which this Privacy Policy was last updated to determine if there have been any changes since you last reviewed this Privacy Policy. 

12. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy, please contact Reify’s Privacy Officer directly at:

Reify Health, Inc.
Attn: Privacy Officer
33 Arch Street
17th Floor
Boston, MA
02110
USA

Email: privacyofficer@reifyhealth.com

Toll-free telephone (US & Canada): 855-222-4892

Reify’s EU-based representative may be contacted at:

Guidehouse Germany GmbH
Attn: Reify Health, Inc.
Albrechtstraße 10 c
10117 Berlin
GERMANY

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third-party dispute resolution provider by clicking here.

13. Local Appendices

(a) Australia

This section applies only to residents of Australia. For purposes of this section, “Personal Information” has the meaning given to it in the Privacy Act of 1988. You have the right to correct your Personal Information if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading. You also have the right to request access and obtain copies of your Personal Information in the form and format of your choosing, so long as the form and format is reasonable. Because of the global nature of Reify’s operations, Reify may transfer Personal Information that originates in Australia to a location outside of Australia. For more information about data transfers, to exercise any of the above mentioned rights, or to request additional information or clarification, please email us at privacyofficer@reifyhealth.com.

For information on how to file a privacy complaint, please click here.

(b) California

This section applies only to residents of California, United States. For purposes of this section, “Personal Information” has the meaning given to it in the California Consumer Protection Act (“CCPA”), as modified by the California Privacy Rights Act (“CPRA”) (together, we refer to these as the “California Privacy Rules”). 

For the purposes described in this Privacy Policy, Reify may process the following categories of Personal Information recognized by the California Privacy Rules: 

  • Identifiers
  • Internet or other electronic network activity information
  • Geolocation data
  • Professional information

As a California resident, you have the right to knowledge, access, and deletion, of your Personal Information. Additionally, you also have the right to opt out of the sale of your Personal Information, and the right not to be discriminated against for exercising a right granted by the California Privacy Rules. 

Reify does not sell Personal Information and does not discriminate in response to privacy right requests.

You have the right to submit a request to Reify and receive the following information within 30 days of our receipt of your request: (a) categories of Personal Information disclosed to third parties during the past year; (b) the names and address of the third parties with whom we shared Personal Information; and (c) if the nature of the third party’s business cannot be reasonably determined from the third party’s name, examples of its products and services. You also have the right to request information regarding any third parties with whom we have shared your Personal Information for direct marketing purposes in the preceding 12 months. 

To exercise your rights under the California Privacy Rules or for additional information or clarification, please email us at privacyofficer@reifyhealth.com.


(c) Україна (Ukraine)

Щоб прочитати цю політику конфіденційності українською, будь ласка, натисніть тут.

Last Modified: 27 April 2022