Last Updated: December 2022
Brado obtains confidential information directly from Participants, including consumers, patients, and healthcare professionals, as well as from third parties (such as recruiting firms and clients) you have authorized to share your PII.
The legal basis for processing PII is for the performance of our contracts with our clients and performance of obligations under a Study Agreement (defined herein) with you. We also process PII with your consent when we have asked for it and you have provided it. You can withdraw your consent at any time.
We use the term “PII” herein to include definitions from various jurisdictions. Depending upon the objective of a Study, Brado may collect the following categories of PII about you:
The exact categories of PII collected will vary by Study and will be defined in one or more separate agreements (“Study Agreement”) you will be asked to sign indicating consent. The Study Agreement will also address your obligations regarding confidentiality and confirm you are at least 18 years old. Your participation is voluntary, but if you choose not to sign the Study Agreement, you may not participate in a Study.
Brado recognizes and respects that Participants have the following rights regarding their PII:
If you want us to modify or delete your PII, you can contact us at InformationSecurity@brado.net with your request. We will take steps to delete your information as soon as is reasonably practicable, but some information may remain in archived/backup copies for our records or as otherwise required by Applicable Law. For purposes hereof, “Applicable Law” shall mean applicable United States law and the European Union General Data Protection Regulation (GDPR), as and when applicable with respect to certain Participants.
If the GDPR applies to our processing of your PII (which will be the case if you reside in a country or are a citizen of a country that is a part of the European Union or European Economic Area), you also have the right to request limited processing, to object to processing, or to request data portability.
We may disclose the PII we collect as described below or otherwise disclosed to you at the time the data is collected.
This section informs Participants about Brado’s priorities, processes and policies regarding PII and Studies.
Selection of Participants may be based on automated decision-making regarding demographics, attitudes, and behavioral information you provide.
We take appropriate physical, technical, and organizational measures to protect your PII from loss, misuse, unauthorized access or disclosure, alteration, and destruction. However, no system is guaranteed to be secure from intrusion or hacking, and there is always risk assumed by sharing PII online. If you have reason to believe there has been a security breach, please notify us immediately at InformationSecurity@brado.net.
Video recording of Studies, which include Participants’ personal likenesses and voice, may be shared with our clients, and may be retained after the Study is concluded, but shall not include other PII.
Study Agreements with your signature shall be retained as required by Applicable Law, client agreements or industry standards.
Brado manages Studies in the healthcare and medical fields and, therefore, we often request information related to health, symptoms, medications, and treatments. If you mention an adverse event (for example, a negative reaction to a medication) or a product quality complaint, understand that Brado is obligated by FDA regulations to report it. We may ask for additional details for evaluation. It is your right to provide additional details or to decline to do so.
If a Study involves children, we first require parent/guardian consent for the research and may require parent/guardian participation in the actual Study, as applicable to the laws of the jurisdiction. Otherwise, Brado does not knowingly solicit or collect PII from persons under 18 years of age. The Study Agreement requires a Participant to acknowledge they are at least 18 years old.
Your PII is stored only for as long as there is a need to fulfil the purposes for which the PII was collected. Mandatory legislation, such as bookkeeping, account keeping, or tax legislation, may require us to store some of your PII for longer periods.
PII processed based on your consent will be deleted in the event of your withdrawal of your consent.
To contact us about any matter relating to privacy or your rights, please email InformationSecurity@brado.net or write to Brado Cuneo Nollau, LLC, 900 Spruce St., St. Louis, MO, USA; Attention: Privacy Officer. We will respond to your request within 30 days.
In the communication, you must reference the name and date of the Study, your full name, email address and the recruiter’s company name. We may require additional information and documents, including PII, to authenticate and validate your identity and to process your request. We will retain such additional data for legal purposes.
We may only process requests with respect to the PII associated with the email address that sent the request.
We reserve the right to disclose your PII if required by law or if we believe use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or comply with a law, court order, or legal process.