Last updated: November 1, 2022

1. Introduction

This Privacy Policy describes the types of information gathered by LINEA System, LLC (“LINEA System,” “us” or “we”) in the process of providing this website, https://www.lineasystem.com/, (the “Site”), and the associated services, software (including, but not limited to AcceleTrial^TM), data, information, tools, functionality, updates and similar materials (collectively, with the Site, the “Service”), as well as how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. This Privacy Policy does not apply to information received by us outside of the process of providing the Service, for example, our activities as a business associate of covered entities which are subject to the terms and conditions of applicable business associate agreements and other agreements.

By accessing or using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy.

We may revise or update this Privacy Policy by posting an amended version through the Service and making you aware of the revisions, which may be through posting to the Site or otherwise. Your continued access to or use of the Service following our notice of changes to this Privacy Policy (or other acceptance method) means you accept such changes. Please refer to the “Last updated” date above to see when this Privacy Policy was last updated.

• Territoriality.
  • Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. In all instances in this Privacy Policy, “our servers” means servers that we own or on which the Service is hosted, or which are otherwise utilized by the Service.  BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
  • This Privacy Policy may be subject to the provisions of the European Union’s General Data Protection Regulation (“EU GDPR”), the United Kingdom’s General Data Protection Regulation (“UK GDPR”, and together with the EU GDPR, the “GDPR”), and other applicable privacy laws. LINEA System agrees that under the GDPR, it is both a data “Controller” and a “Processor”, and you, if you are an individual and reside in the European Economic Area, United Kingdom, or Switzerland (collectively, the “EEA”), are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” We will take reasonable steps to maintain compliance with GDPR requirements. Your Personal Data may identify you as a person, and thus may be referred to as Personally Identifiable Information (“PII”).
• Who Collects Your Information On Our Site?

We do. Under the GDPR, LINEA System is what is known as a “Controller” and a “Processor” of the Personal Data that is processed by LINEA System and collected from you, and third party sources, including but not limited to publicly and commercially available databases.  Additionally, we may collect information from you on the Service, and we are responsible for protection of your information.

• What Information Do We Collect?
  • Personally Identifiable Information. We may request specific PII from you when you register for the Service, when you create or update your account, when you use the Service, from third parties, when you communicate or interact with us, or otherwise when you submit such information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Site and Service. The types of PII we may collect and save include:
    • Contact and account registration information such as username, name, address, email address, physical/mailing address, and telephone number;
    • Information you provide such as feedback, comments or other messages;
    • Technical information collected in our logs, such as standard web log entries that contain your IP address, keystrokes and clicks while using the Site, page URLs, the pages and features accessed most frequently, time spent on a page, how pages and features are used, previous page and referring page URLs, search terms entered, and similar analytics about use of the Site or Service; and
    • Clinical Trial Related, as defined herein.
  • Clinical Trial Related. We may collect information that you upload or otherwise submit, including but not limited to your CV/qualifications, a feasibility questionnaire, and regulatory documents, to the Service to use the clinical trial related functions the Service offers (“Clinical Trial Related Content”). We collect Clinical Trial Related Content only if, and to the extent that, you upload or otherwise submit it to the Service.
  • Anonymous Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider. We may create anonymous or de-identified information from PII. Information collected or created pursuant to this section will not be considered PII and not subject to the terms and conditions of this Privacy Policy.
• 5.             Why Is My Information Being Collected?
  • We need to collect your PII so that we can respond to your requests for information and demonstrations or to be added to our emailing lists, and to process your requests for access to our Site. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Site and Site, calculate usage levels, and otherwise provide services to you.
  • Clinical Trial Related Content. Clinical Trial Related Content is collected for purposes of processing your requests to related to clinical trials listed on the Service.
• How Do We Use the Information We Collect?
  • We use the PII that we collect for the purposes for the purposes of providing the Service, and:
    • Internal Uses. We may use your PII to respond to inquiries about clinical trials or the Service, to fulfill your requests for information, develop and improve the Service, and perform research and analytics.
    • Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to access and use the Service.
    • Communicating With You About Our Service. We may use your PII to send you information about new features of the Service, educational opportunities, webinars, marketing events and other items that may be of interest to you.
    • Sending Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account and your other PII, (b) provide you with information regarding the Service, (c) inform you of changes to this Privacy Policy, our other policies; or (d) provide you with information on our other services and products, or promotions related to the Service.
    • Clinical Trial Related Content. We may use Clinical Trial Related Content to provide certain functionalities of the Service, as directed by you, including processing your requests relating to clinical trials listed on the Service. We may also anonymize your Clinical Trial Related Content and use it for purposes of improving the design and content of our Service, analyzing how the Service is used, and performing analytics and benchmarking, and for general business purposes.
  • We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your Site experience. We also may use this information in the aggregate to analyze how the Service is used, analyze industry trends, as well as to offer you programs or services.
• Do We Share Your PII or Clinical Trial Related Content?

In general, we will not share your PII and Clinical Trial Related Content except: (a) for the purposes of engaging you in a clinical trial ; (b) with your consent, or as you direct; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) on a confidential basis with persons or organizations with whom we contract to carry out internal operations, which may include for example, analytical services, or as necessary to render the Service. With your knowledge and consent, we may share your PII with our business partners, such as the applicable clinical trial sponsors, contract research organization, or other third parties supporting clinical trials related to the Service.

We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Clinical Trial Related Content that you provide to us may be shared and with clinical trial sites, contract research organizations, and other parties involved in selecting sites to participate in an applicable clinical trial, or the organization sponsoring the clinical trial, or any combination of those,  and is subjected to an obligation of confidentiality.

Finally, we may transfer your PII and Clinical Trial Related Content to a third party, or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control.  After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

• How Can You Access and Control Your Information?

You can revise your PII and Clinical Trial Related Content from within the Service.  We may provide you with additional options to access and control your information in the future. If applicable, we will provide instructions on these options on the Service. If such options are provided, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information in order to protect your privacy and security. 

• How Do We Store and Protect Your Information?
  • After collecting your PII and Clinical Trial Related Content, we will store it on our Service for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.
  • If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our web servers and internal systems located within the USA.
  • We store your PII until we are required to remove it. We store our logs and other technical records in accordance with internal practices and policies, and potentially indefinitely.
• How Do We Use Cookies And Other Network Technologies?
  • To enhance your online experience with us, our web pages may presently or in the future use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. We may use session, persistent, first-party and third-party cookies. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie.  Certain features of our Service may not function properly without the aid of cookies.  LINEA System uses session cookies, which are necessary to allow you to seamlessly navigate from one page or area of the Site to another during your visit, and these are normally deleted when you close your web browser.  We also use persistent cookies for your convenience so that you can log in faster, your preferences are remembered from visit to visit, and that you have an overall more convenient experience while visiting our Site.
  • Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.
  • We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” embedded links, and other commonly used information-gathering tools in connection with some Site pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Site usage and response rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Site, to deliver customized services, and to help determine the effectiveness of our promotional and advertising campaigns, Site, and Service. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.
  • As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site and Service.
  • Do Not Track.  At present, the Service does not specifically respond to browser do-not-track signals.
• Collection of Information by Others

Our Service may provide links to certain third party websites and services that you may click on our Site. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.  This Privacy Policy only applies to our Service, not the services of any third party.

1. ‘EEA’ Privacy Rights.

1. If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject.  The GDPR requires that we, in our capacity as a Controller, have a legal basis to process your PII.  We process your PII under one or more of the following legal bases:

• Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• For the performance of a contract;
• To comply with a legal obligation; and/or
• If we have your consent to do so, such consent capable of being revoked at any time.

1. Under the GDPR, as a Data Subject you have certain rights. They are:

• The right to be informed. This is your right to be informed about what we are processing, why, and who else the data may be passed to.
• The right of access. This is your right to see what data about you is held by us.
• The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.
• The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
• The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
• The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
• Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making and profiling.

1. You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at info@lineasystem.com.
2. California Privacy Rights

California  law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at same as above info@lineasystem.com with “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

1. Children and Privacy

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR, the Children’s Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at info@lineasystem.com. Our Service will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Service without your permission, please contact us at info@lineasystem.com.

1. Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us at info@lineasystem.com.

Copyright © LINEA System, LLC. All rights reserved. The Site and Service are the property of LINEA System, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.