Privacy Policy

I. Personal data.

1. KAPADI Group* (hereinafter “KAPADI”) respects the privacy of users and visitors of the www.sanrecopvstudy.com website.

* KAPADI Group:

Kapadi Sp. z o.o., with registered office at: Racławicka 146 Street, 02-117 Warsaw (Poland)
Kapadi, Inc., with registered office at: 9650 Strickland Road, Suite 103-150, Raleigh NC 27615 (US)
Kapadi Spain SL, with registered office at: Avenida Menéndez y Pelayo 3-5, 46010 Valencia (Spain)
Kapadi Italy Srl, with registered office at: Corso Italia 22, CAP 20122 Milan (Italy)
Kapadi Germany GmbH, with registered office at: Frauenstraße 14 89073 Ulm (Germany)
Kapadi Operations, LLC, with a registered office at: 9650 Strickland Road, Suite 103-150, Raleigh, NC 27615 (US)
Kapadi Pty Ltd, with registered office at: Suite 6, Level 2 29-31 Lexington Drive, Bella Vista, NSW 2153 (Australia)
Agati Systems LLC, with registered office at: 8000 Preston Rd STE 401, Frisco, TX 75034 (US)
Agati Clinical Informatics, LLP, with registered office at: Kochar Bliss, 3rd Floor, A8 & A9 Industrial Estate, Guindy, Chennai, 600032 (India)

KAPADI acts as the data processor of personal data processed via the website.
This document defines the practices used by KAPADI regarding personal data, methods of collecting them, the purposes for which they may be used and the persons for whom the data are intended.
Your personal data are processed and secured in accordance with the principles set out in particular in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter “GDPR”.

II. Collection of personal data

When asking you to provide your data, KAPADI always explains why it needs it. Only the data that is necessary to achieve the specific purpose of processing is collected.
KAPADI will collect personal data only for specific, clearly defined and justified purposes presented before or during data collection, and will not use them in a manner that goes beyond these purposes.
Only information that is adequate, relevant and that does not exceed the purpose for which it is collected will be collected. If necessary, KAPADI will take all reasonable steps to check the accuracy and currency of the personal data collected.

III. Storage

Your personal data is stored by KAPADI on its servers, and on the servers of third-party, cloud-based database management services that KAPADI engages, located in the European Economic Area (EEA), the United States and India. Your personal data will not be stored longer than necessary to achieve the purposes for which the data was collected or longer than specified by law or the justified legal interest of KAPADI.

Data safety
KAPADI has taken measures to ensure the confidentiality, security and integrity of your personal data.
KAPADI attaches great importance to ensuring that your personal data will not be modified, shared or otherwise misused by third parties who are not authorised to access the data.
Personal data controller

KAPADI Group* (hereinafter “KAPADI”).

You can contact the data controller at the following email address: contact@kapadi.com.

What is the purpose, legal basis and period of personal data processing?

In connection with the use of the website, your personal data will be processed for the purposes, based on and for the period:

The service or functionality in connection with which personal data is processed	Purpose of processing	Legal basis	Processing period
Contact form	To enable you to communicate with KAPADI and ask about the clinical study	Article 6, section 1, letter f) GDPR, and the legitimate interest of the data controller is to answer the submitted enquiry	Until the limitation period for claims arising from the enquiry expires or until the obligation to store data resulting from legal provisions expires, or until an objection to data processing for this purpose is submitted.

The service or functionality in connection with which personal data is processed

Purpose of processing

Legal basis

Processing period

Contact form

To enable you to communicate with KAPADI and ask about the clinical study

Article 6, section 1, letter f) GDPR, and the legitimate interest of the data controller is to answer the submitted enquiry

Until the limitation period for claims arising from the enquiry expires or until the obligation to store data resulting from legal provisions expires, or until an objection to data processing for this purpose is submitted.

III. Is providing personal data mandatory?

Providing personal data is voluntary, but necessary to achieve the purposes for which they are or were collected.

IV. What are your rights regarding the processed data?

Each of you has the right to access data (Article 15 of the GDPR), rectification (Article 16 of the GDPR), deletion (Article 17 of the GDPR), restriction of processing (Article 18 of the GDPR), transfer (Article 20 of the GDPR) and the right to submit a complaint to the President of the Personal Data Protection Office. If your personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Due to your particular situation, you have the right to object to the processing of your data at any time based on the legitimate interest of the data controller. The data controller will no longer be allowed to process this personal data, unless they can demonstrate the existence of valid legitimate grounds for processing, overriding the interests, rights and freedoms of the data subject, or grounds for establishing, pursuing or defending claims.

In order to exercise this right, please inform us of this fact by writing to us by email at: privacy@kapadi.com

V. Who may be the recipient of the data?

Your personal data may be transferred by KAPADI to entities cooperating with it (recipients), in particular IT service providers and entities providing accounting, financial, legal, debt collection and marketing services. Such entities process data on the basis of an agreement with the data controller and only in accordance with the data controller’s instructions.
Your personal data may be made available to entities authorised under the law, only in situations in which the data controller will be legally obliged to make them available.

VI. Transfer of data to third countries

Some Kapadi Group entities are located outside the EEA. Information that we collect about you will be processed in the United States, the EEA, India, Australia and the Republic of Korea, and you acknowledge that your personal information will be processed in and transferred to these countries. Members of the KAPADI Group provide safeguards, primarily by means of:

cooperation with the entities processing personal data in countries for which an appropriate decision of the European Commission has been issued, which confirms an adequate level of personal data protection;
application of standard contractual clauses issued by the European Commission;
application of binding corporate rules approved by the competent supervisory authority;
regarding entities processing data based in the USA (Google Inc.), the Foundation cooperates with companies participating in the Data Privacy Framework programme; more information can be found at: https://www.dataprivacyframework.gov/s/.

In order to exercise this right, please inform us of this fact by writing to us by email at: privacy@kapadi.com.

VII. Children’s privacy

Our sites are not intended for, or directed to, children under the age of 13.  We do not knowingly receive personal data from children under the age of 13.  If you are under the age of 13, do not provide us with any personal data either directly, through any website forums or by any other means.  If you become aware that your child has provided us with personal data, please contact us.