Privacy and Data Protection Policy

CRA PLATFORM S.L. strives to ensure privacy in personal data processing. To this end we have updated our Privacy Policy to clearly describe the procedures for collecting, utilizing and protecting the data of persons who get in touch with our Company and request the provision of services.

By means of the present Privacy Policy, CRA PLATFORM S.L. provides detailed information about personal data processing and individual rights in accordance with the data protection regulations whenever the Company processes personal data.

A. PROCESSING RESPONSIBILITY

The interested party who provides CRA PLATFORM S.L. with personal data through this online platform or other channels (for instance, social media) is hereby informed that said data are processed by:

The interested party is able to voluntarily provide personal information through specific data collection forms included in different website sections or through email addresses established for said purpose, or through social media (Facebook, Twitter, Instagram) or direct contact and relationship with the Company responsible for data processing. Providing any personal data through any of said channels involves the acceptance and consent for processing thereof in accordance with the terms set forth in the present Privacy Policy.

B. PURPOSES OF PERSONAL DATA PROCESSING

In general, collecting and processing personal data is conducted for the purposes listed below:

1. Establishing contact with the interested party, respond to requests, consultations or opinions and manage the publication of consultations and comments or opinions as well as for subsequent follow-up.
2. Adequately managing requests for quotes sent through this media and managing and conducting the services engaged by the interested party, as well as invoicing and payments if applicable.
3. Managing and controlling client portfolios.
4. Conducting all necessary procedures for adequating the participation of candidates in personnel selection processes requested by registered companies and clients of CRA PLATFORM S.L. (pharmaceutical companies, CROs, laboratories, etc.)
5. Adequately managing user experience at this website.
6. Establishing contact with interested parties to offer customized contents, products and services.

Regarding data processing for promotional or advertising purposes, the appropriate data collection form will include appropriate simple and free procedures for the user to freely provide his/her consent for said purposes. Said consent may be revoked at any time without any costs for the user.

C. LEGITIMACY

Data processing for managing requests for information or registration is based on the execution of a contract or a negotiation thereof.

Prospective offerings of products and services to clients is based on the satisfaction of the legitimate business interest consist in offering clients additional products or services in order to increase loyalty. Said legitimate interest is accepted by applicable legal regulations (General Data Protection Rules) that explicitly allows processing personal data on that legal basis for direct marketing purposes. However, please be advised that you have the right to oppose said processing of your data by means of any of the communications channels described in this Policy. 

The dispatch of marketing communications to non client interested parties is based on the requested consent which may be revoked at any time. 

The basis for processing Curriculum Vitae is the consent given by the candidate when submitting same for participating in selection procedures.

In summary, the legal basis for conducting personal data processing in accordance with the General Data Protection Rules (“RGPD”) and with the appropriate subordinate laws is that of complying with the execution of a contract when the interested party is a member of a contractual or mercantile relationship, or the consent of the interested party when submitting his/her personal data for the appropriate purposes.

D.DURATION OF DATA PROCESSING 

Personal data of an interested party is only stored to the extent that it is required for use according to the purpose for which said data were obtained and based on the data processing laws. Personal data shall be kept for the duration of a contractual and/or commercial relationship with the interested party as long as the latter does not execute the right of suppression, cancellation and/or limitation of personal data processing.

In these cases, data will be adequately archived, without being used for any purpose, for as long as they may be necessary for carrying out or defending complaints or while some type of judicial, legal or contractual liability may be derived from the processing of said data which may require response and therefore recovery.

Data are related to the management of client relationships, and invoicing and collections of services shall be maintained throughout the duration of the contract. Once said relationship terminates data may be preserved during the period of time required by applicable laws and until the expiry of eventual liabilities derived from said contract.

Data for managing consultations and requests shall be preserved for the period of time necessary to give response thereto, with a maximum period of one year.

Data relating to publication of commentaries or opinions on our products will be kept throughout the validity and publicity of the products or services said publications refer to, unless the author thereof expresses the desire to eliminate them at any point in time.

Data for dispatching marketing communications of our products or services will be kept indefinitely until you express your desire to eliminate them.

Data related to Curriculum Vitae for selection processes shall be kept during one year, provided that they need not be kept longer due to the formalization of a contractual relationship and to determine possible liabilities that could be derived from said purpose and from data processing.

E.UNDERAGE PERSONS

Persons under 18 years of age must not send any personal information without the consent of their parents or guardians. CRA PLATFORM S.L. is not responsible for any personal information sent by persons under 18 years of age without appropriate authorization. 

F.SECURITY MEASURES 

Data being requested are strictly necessary for the adequate identification of the sender and for carrying out the purposes detailed above. CRA PLATFORM S.L. insists on its commitment to the responsible and confidential usage of data, and guarantees that the data of interested party will be processed in accordance with legal requirements and that will be used exclusively by CRA PLATFORM S.L. and the companies of its services environment for the established purpose. 

Requested data are adequate, appropriate and not excessive with regard to the scope and purposes described. In any case, the interested party shall be responsible for the truthfulness of data submitted. CRA PLATFORM S.L. reserves the right to exclude from registered services all parties who have provided false data, without prejudice to additional actions applicable according to the laws.

CRA PLATFORM S.L. takes adequate security measures to protect personal data against unauthorized access or modification, unauthorized publication or destruction. However, users should be aware that transmitting data through the Internet or other electronic means involves security risks, and CRA PLATFORM S.L. is unable to offer any guarantees related to the safety of data transmitted through said means.

G.RIGHTS OF DATA OWNERS

Any person that submits data by any of the described means enjoys the following rights:

Any person has the right to obtain confirmation about the treatment of his/her personal data. Interested parties have the right to access their personal data as well as request the modification of erroneous data or, if applicable, request the suppression thereof when said data are no longer necessary for the purposes for which they were obtained, among other reasons.

Under the conditions established by the General Data Protection Regulation, interested parties may request the limitation of the processing of their data or the portability thereof, in which case CRA PLATFORM S.L. will only keep said data for the execution or defense of complaints.

Under specific circumstances and for reasons related to their particular situation, interested parties may oppose the processing of their data. If you have given consent for any specific purpose, you have the right to withdraw it at any time without this affecting the validity of the processing based on the given consent prior to its withdrawal. In such a case, CRA PLATFORM S.L. shall cease processing said data or, if applicable, cease processing them for that specific purpose excepting for legitimate unavoidable reasons or for the execution or defense of possible complaints.

All of the rights mentioned above can be exercised:

•by written document addressed to CRA PLATFORM S.L. with address at 28033-Madrid, Spain, calle Caleruega 18 D local.

•By email sent to karina.garcia@cra-platform.com 

in the event of any infringement of your rights, particularly when you have not obtained satisfaction in the execution thereof, you can file a complaint at the Spanish Data Protection Agency at the following address: Calle Jorge Juan 6, 28001-Madrid, Spain (www.agpd.es) or any other competent control authority. You can also obtain additional information about your rights inquiring at said organizations.

H.THIRD-PARTY DATA 

if you provide third-party data, you assume the responsibility of previously informing them of the conditions set forth in article 14 of the General Data Protection Regulation under the conditions established in said rule.

I.COMMUNICATION OF YOUR DATA 

Data derived from contacts and consultations shall not be communicated to third parties unless being legally required. In the case that an order is subsequently placed, data shall be communicated if applicable to financial institutions in charge of managing collections and payments and to the competent public administrations in the cases stipulated by law and for the purposes defined therein, or when the provision of a service involves a contractual relationship with a data processor, in all cases in accordance with the general conditions approved by the the user prior to the formalization of the contract. Accordingly, when contracting the services of CRA PLATFORM S.L., the user accepts that some of these could be partially or fully subcontracted to other persons or companies who will be considered to be in charge of processing and with which the appropriate confidentiality contract has been formalized or have adhered to privacy policies established at their respective websites. Said user also accepts that some obtained personal data may be provided to said persons or companies in charge of processing whenever necessary for the effective discharge of the contracted services.

The objective of CRA PLATFORM S.L. is to provide a platform in which candidates may register and upload their CVs or information related to their personal data, professional experience, education, processing areas in which they have worked and availability of time and relevant data in an online environment with a view to being employed as part of a clinic trial or similar projects.

At the same time, CRA PLATFORM S.L. allows registered companies and clients (pharmaceutical companies, CROs, laboratories, etc.) to publish employment offers targeting specific professional profiles and selecting and interviewing candidates proposed by CRA PLATFORM S.L., in which case CRA PLATFORM S.L. shall send the candidate all the details of the interview. The Company may choose to accept or reject the candidate or close the employment offer. If the Company chooses to select the candidate, both parties shall sign the appropriate contracts with CRA PLATFORM S.L., without direct contract between the candidate and the company interested in securing the services of the candidate unless otherwise agreed. CRA PLATFORM S.L. is in continuous evolution and develops new tools of value for registered candidates.

Data transfer to organizations based in countries outside the European Union may be carried out if necessary for the purposes for which they were collected, when candidate selection companies are located outside the EU. CRA PLATFORM provides services to clients in different parts of the world outside the European Economic Area (USA, Australia, New Zealand, South Africa, Brazil).

J.MODIFICATIONS OF THIS PRIVACY POLICY 

The use of the website by the candidate implies full acceptance of the conditions included in this Privacy Policy (the version in force at the time of accessing the website) and therefore these terms and conditions must be read regularly. The use of certain services offered to candidates through the website may be subject to specific terms and conditions which could substitute, supplement and/or modify the present legal terms and conditions. Therefore, before using said services, the candidate must also read attentively and accept the appropriate specific terms and conditions.

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