Effective Date: September 18, 2020

This CCPA Privacy Notice relates solely to the website https://www.SyneosHealthCovid19.com and all related subdomains of that site (collectively, the “Site”). Syneos Health (“we”, “us”, “our”) are required by the California Consumer Privacy Act of 2018 (“CCPA”) to explain to California residents (“Consumers”) about online and offline practices with regard to how we collect, use and share their personal information, and about the rights and choices we offer them regarding our handling of the personal information. Syneos Health is an end-to-end, fully integrated Business-to-Business solutions company primarily servicing our biopharmaceutical and health care customers (our “Customers”).

Personal Information Defined

When we use the term personal information in this notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

  • Information that is lawfully made available from federal, state, or local government records.
  • Information that is de-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, including:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or certain clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
    • Other information subject to an exemption from the CCPA’s coverage.

Personal Information We Collect, Use and Share

As we explain in our Privacy Notice:

  • Cookies and other Tracking Tools
    We use cookies and other tracking tools to analyse website traffic. If you would like to opt out of our use of cookies and/or other tracking tools, please review the instructions provided in the Tracking Opt-Out section below.
  • Directed Disclosures
    When Consumers who visit the Site share their information with for the Purpose identified in the Site privacy notice. To fulfill the Purpose, we may share consumer’s information with sponsors and/or sites in connection with certain clinical trial recruitment activities. These disclosures are inherent to the Purpose and directed by the consumer.

How we collect, use and share personal information about Consumers.

The CCPA requires businesses to disclose their collection and use of specific categories of personal information enumerated in CCPA. Syneos Health does not sell your personal information. Below is a summary of how we currently collect, use and share personal information, and how we have used and shared the information in the preceding 12 months in relation to the Site:

CCPA Category of Personal Information: Identifiers

CCPA Definition: Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s licence number, passport number, or other similar identifiers.

  • From whom do we collect this personal information: Consumers
  • Purposes for which we use personal information: Purpose, Research and Development,
  • To whom do we disclose personal information: Customers, Healthcare Providers (e.g., trial sites), and Service Providers

CCPA Category of Personal Information: Internet or Network Information

Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.

  • From whom do we collect this personal information: Automatic Collection
  • Purposes for which we use personal information: Purpose, Research and Development, Security, Auditing Interactions with Consumers
  • To whom do we disclose personal information: Customers, Healthcare Providers (e.g., trial sites), and Service Providers

CCPA Category of Personal Information: Medical Information

Personal information about an individual’s health or healthcare, including health insurance information. Does not include (a) medical information governed by California’s Confidentiality of Medical Information Act, (b) protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 or (c) information collected as part of certain clinical trials.

  • From whom do we collect this personal information: Consumers
  • Purposes for which we use personal information: Purpose, Research and Development,
  • To whom do we disclose personal information: Customers, Healthcare Providers (e.g., trial sites), and Service Providers

CCPA Category of Personal Information: Online Identifiers

An online identifier or other persistent identifier that can be used to recognise a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.

  • From whom do we collect this personal information: Consumers, Automatic Detection
  • Purposes for which we use personal information: Purpose, Research and Development,
  • To whom do we disclose personal information: Service Providers, Customers, and Healthcare Providers (e.g., trial sites)

CCPA Category of Personal Information: Physical Description

An individual’s physical characteristics or description (e.g., hair colour, eye colour, height, weight).

  • From whom do we collect this personal information: Consumers
  • Purposes for which we use personal information: Purpose, Research and Development
  • To whom do we disclose personal information: Customers, Healthcare Providers (e.g. trial sites), and Service Providers

CCPA Category of Personal Information: Protected Classification Characteristics

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  • From whom do we collect this personal information: Consumers
  • Purposes for which we use personal information: Purpose, Research and Development
  • To whom do we disclose personal information: Customers, Healthcare Providers (e.g., trial sites), and Service Providers

We may also disclose all personal information (a) to our affiliates, (b) to comply with federal, state, or local laws; (c) to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (d) to cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (e) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (f) to professional advisers, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

California Residents’ Privacy Rights

The CCPA grants Consumers with certain rights, which are subject to certain limitations and exceptions. This section describes these rights. If we are not able to complete some or all of a Consumer’s verifiable consumer request, we will communicate the reason to the Consumer in writing.

  • Information. Consumers can request information about the personal information we have collected about them and how we have used and shared their Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including it in this notice, above.
  • Access. Consumers can request a copy of the personal information that we have collected about them over the past 12 months. In certain cases, we are not permitted by the CCPA to provide you with certain sensitive information in response to an access request, such as your social security or driver’s licence number.
  • Deletion. Consumers can ask us to delete the personal information that we have collected from them. In certain circumstances, the CCPA allows us to deny Consumer requests to delete their personal information, such as where we need the information to complete a transaction for which the personal information was collected or where we need the personal information to comply with a legal obligation.

Consumers are entitled to exercise the rights described above free from discrimination.

How to Submit a Verifiable Consumer Request

  • Requesting access to or deletion of personal information. With respect to your Personal Data Processed through this Site, please note that Syneos Health has instructed its Processor, X Factor Advertising, not to provide us with any identifying information about you. As a result, we receive anonymised data from X Factor. However, as the data controller, Syneos reserves the right to obtain any such identifying information about you from X Factor Advertising, and use such information in accordance with this Privacy Notice, in the future. We will update this Privacy Notice accordingly if any such change is implemented. If you wish to exercise your Personal Data rights, we ask that you contact our Processor, X Factor Advertising, as follows:
  • fax: 503-235-6572, Attn: Privacy Officer
  • email data.privacy@xfactoradvertising.com
  • postal mail: 33548 Edward Ln. Suite 110, Scappoose, Oregon 97056, Attn: Privacy Officer

    To help X Factor identify your Personal Data, please inform X Factor that your request relates to the Syneos Health COVID-19 recruitment site. If you are not satisfied with the manner in which X Factor addressed your rights, you may contact us directly as specified in the Raising Concerns portion of our main Privacy Notice.
  • Identity verification. The CCPA requires us to verify the identity of the individual submitting a Consumer request to access or delete personal information before providing a substantive response to the request. Where possible, we will attempt to verify your identity by asking you to confirm information that we have on file about your or your interactions with us. Where we must ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. You do not need to create an account with us to exercise your rights.
  • Authorised agents. You can designate an “authorised agent” who has registered with the California Secretary of State to submit verifiable consumer requests on their behalf. You can also make a Consumer request on behalf of your minor child. We will require the authorised agent to have a written authorisation confirming that authority.

How We Respond to Verifiable Consumer Requests

We will acknowledge receipt of your verifiable consumer request within 10 days of our receipt of your request, and we will endeavour to substantively respond within 45 days of our receipt of your request. If we need to extend our response time (up to 90 days from receipt of your request), we will inform you in writing of our reasons for doing so. We will deliver your personal information via your online account with us, if you have one, or by other secure electronic means. If we are unable to process your verifiable consumer request in whole or in part, we will explain our reasons for doing so.

Please note that we do not typically charge a fee to respond to verifiable consumer requests unless they are excessive, repetitive, or manifestly unfounded.  If we determine that your verifiable consumer request warrants the assessment of a fee, we will inform you of the reasons supporting our determination and provide you with our estimate of the costs to fulfill your request before we take action to enable you to determine whether you would like us to complete your request.

Requesting Additional Information

If you have any questions or comments about this notice or how we handle personal information, you may contact us via mail at:

Attn: Privacy Office
Syneos Health
1030 Sync Street
Morrisville, NC 27560
United States of America

You may also contact us via email at: data.privacy@syneoshealth.com.

Changes to This Privacy Notice

We may periodically update this notice. When we post changes to this notice, we will also revise the “Last Updated” date appearing at the top of the notice. If there are material changes to this notice, we will notify you by e-mail or by posting a notice on our home page. We encourage you to review this notice periodically to be informed of how we are using your information and to be aware of any changes to it. Your continued use of the Sources after the posting of any amended notice shall constitute your agreement to be bound by any such changes. Any changes to this notice are effective immediately after we post it.

Tracking Opt-Out Guide

Like many companies online, we may use services provided by others companies that use tracking technology. These services rely on online tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, about your interactions with websites, and about the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarised below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.