Privacy Policy
Last Updated: May 2025
INTRODUCTION
At PhaseV, we recognize that privacy is important. This Privacy Policy applies to your access to PhaseV's website (the "Website") and the use of services available through the Website (collectively, the "Services").
Personally Identifiable Information ("PII") is information that can identify you or be associated with you, the user (“you” or the "User"). When you use our Services, your PII will be processed according to this Privacy Policy. Please read our Privacy Policy carefully to get a clear understanding of how We organize, collect, use, protect or otherwise handle your PII in accordance with our Website.
You are not legally required to provide PII; however, we need certain information to provide you with access to our Services. By using the Services, you consent to this Privacy Policy.
Questions? Contact us at: michal@phasevtrials.com
You hereby acknowledge, agree and explicitly consent of your own free will and although not necessarily required to do so under law, that your PII, will be stored, processed, used, held and managed by PhaseV and/or on our behalf, inter alia, by magnetic or optical means that are designated for digital processing or in other forms of database(s) in accordance with applicable law.
I. INFORMATION AND HOW WE USE IT
The Website may collect, process and use the data which includes PII, the legal basis of which is your consent, which you give when you use the Services. Types of PII that may be used include the following, without limitation:
1. We may process data about your use of our Website and Services (“User Data”). User Data may include your IP address, location, type of browser and version, operating system, referral source, visit length, page views and website navigation paths, as well as information about the frequency and timing of your use of the Services. We may use cookies as a source of User Data (as further detailed under our Cookies Policy (“Cookies Policy”)).User Data may be processed in the manner set forth in this Privacy Policy for the purposes of analyzing the use of the Website and Services, operating our Website, improving and customizing the Services, ensuring the security of our Services, maintaining back-ups of our databases and communicating with you.
2. When registering on our Website you may be asked to enter your full name, email address, or other details (“Entered Data”). You are the source of such data, and such data may be processed for the purposes of operating the Website, providing the Services, ensuring the security of the Website and Services, maintaining back-ups of our databases and communicating with you. In addition, you may have the option to upload photo content to PhaseV’s platform. Such content may be used and/or processed by PhaseV or any party on its behalf, as part of the Services. Should you choose to upload any content and/or create content to be used on PhaseV’s platform, you agree that such content may be viewed and/or used by PhaseV or any party on its behalf to provide the Services.
3. We may process information contained in or relating to any communication that you send to us (“Correspondence Data”), for example, when you leave your contact information The Correspondence Data may include communication content and/or metadata associated such communication. The Correspondence Data may be processed for communicating with you and record-keeping.
4. We may collect and retain metadata and statistical information concerning the use of the Services which are not subject to the deletion procedures in this Privacy Policy and may be retained by us for no more than required to conduct its business. Some data may be retained also on our third-party service providers’ servers in accordance with their retention policies. You will not be identifiable from this retained metadata or statistical information.
5. We may process any of the types of data described in this Chapter A if We are required to do so by court-order, any legal obligation to which We are subject, or when necessary, for the establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interests, namely of PhaseV’s legal rights, your legal rights and the legal rights of others.
6. Please do not supply any other person's PII to us without the specific and explicit consent of all parties, including the owner of such PII.
II. PROVIDING YOUR PII TO OTHERS
1. We may disclose PII to any member of our group of companies, including subsidiaries, holding companies and all their respective subsidiaries, insofar as reasonably necessary for the purposes set out in this Privacy Policy.
2. We may disclose your PII to professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3. We may disclose your PII to third-party service providers, vendors and subcontractors reasonably necessary to provide the Services. Such third-party provider’s vendors and subcontractors will only use the PII to the extent necessary to allow them to perform the services they provide to PhaseV.
4. We will only disclose your PII to third parties who provide sufficient guarantees that they implement appropriate technical and organizational measures in such a manner that their processing of your PII will meet the requirements of Data Protection Regulation (as defined below) and ensure the protection of your rights and with whom we have written contracts that conform to our legal obligations under Data Protection Regulation.
5. We may assign PhaseV’s rights and obligations and share PII in the event of a sale and/or merger in which control of PhaseV and/or most of its assets is transferred to a third party, provided that such third party steps into the shoes of PhaseV for all intents and purposes relating to the provisions of this policy.
III. INTERNATIONAL TRANSFERS OF YOUR PII
1. Your PII may be accessed from our main office in Cambridge, MA, USA, and our office in Tel Aviv, Israel. When you use our Services, your information may be transferred to and processed in countries other than your own, including countries inside and outside the European Economic Area ("EEA").
2. For transfers to Israel, the European Commission has made an "adequacy decision" with respect to Israel's data protection laws, recognizing that they provide an adequate level of protection for personal data.
3. For transfers of PII to the United States, which has not received an adequacy decision from the European Commission, we rely on standard contractual clauses (SCCs) adopted by the European Commission, specifically those annexed to the EU Commission Decision 2010/87/EU of 5 February 2010 for the Transfer of PII to Processors established in Third Countries under the Directive and pursuant to the Implementing Decision 914/2021/EU on standard contractual clauses for the transfer of PII to third countries pursuant Regulation (EU) 679/2016 adopted by the European Commission on 4 June 2021 (the "Model Clauses"), to establish appropriate safeguards for the protection of your PII.
4. For all international transfers, we comply with applicable data protection laws including, without limitation, the General Data Protection Regulation (EU) 679/2016, the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000, the Privacy and Electronic Communications regulations, applicable US data protection laws, and where applicable, the guidance and codes of practice issued by relevant regulatory authorities.
5. By using our Services, you acknowledge that PII submitted by you may be transmitted around the world via the internet for the purpose of performing the Services, subject to the terms of this Privacy Policy and your agreement with us.
IV. RETAINING AND DELETING PII
1. This Chapter IV sets out our data retention policies and procedures, which are designed to help ensure that We comply with our legal obligations in relation to the retention and deletion of PII.
2. We will retain your PII for the duration of the Services and for a reasonable period thereafter as needed to comply with our legal and business requirements. The retention period will be determined based on the nature and sensitivity of the data, applicable legal requirements, and legitimate business needs.
3. Notwithstanding the other provisions of this policy, we may retain your PII where such retention is necessary for compliance with a legal obligation to which we are subject, protection of your vital interests or the vital interests of another person, resolution of disputes, or enforcement of our agreements.
V. YOUR PRIVACY RIGHTS
Depending on your location, you may be entitled to certain rights regarding your PII. We comply with privacy laws in multiple jurisdictions where we operate or serve users, with our offices located in the United States and Israel.
Your principal rights under applicable Data Protection Regulation may include all or some of the following:
1. The right to access: You have the right to confirmation as to whether or not we process your PII and, where we do, access to the PII, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of PII concerned and the recipients of the PII. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your PII. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
2. The right to rectification: You have the right to have any inaccurate PII about you rectified and, taking into account the purposes of the processing, to have any incomplete PII about you completed.
3. The right to erasure: In some circumstances you have the right to the erasure of your PII without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the PII have been unlawfully processed. There are certain general exclusions of the right to erasure, including where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
4. The right to restrict processing: In some circumstances you have the right to restrict the processing of your PII. Those circumstances include: you contest the accuracy of the PII; processing is unlawful but you oppose erasure; we no longer need the PII for the purposes of our processing, but you require PII for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted, we may continue to store your PII but will only otherwise process it with your consent, for legal claims, to protect the rights of others, or for important public interest.
5. The right to object to processing: You have the right to object to our processing of your PII on grounds relating to your particular situation. If you make such an objection, we will cease to process the PII unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
6. The right to data portability: To the extent that the legal basis for our processing of your PII is consent, and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7. The right to complain to a supervisory authority: If you consider that our processing of your PII infringes Data Protection Regulation, you have a legal right to file a complaint with a supervisory authority responsible for data protection.
8. The right to withdraw consent: To the extent that the legal basis for our processing of your PII is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you are a US resident, you may have additional rights depending on your state of residence, including rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) as detailed in the California Residents' Rights section of this policy.
You can exercise any of your rights in relation to your PII by contacting us at michal@phasevtrials.com. We may ask you for additional information to confirm your identity and for security purposes before processing your request.
VI. OPT-IN
When you provide us with PII for a secondary reason, like marketing or other secondary reasons which we will convey to you from time to time if applicable, we will ask for your consent. After you opt-in, you may withdraw your consent at any time by contacting us at michal@phasevtrials.com.
VII. INFORMATION SECURITY
We implement industry-standard security measures to protect your information:
1. We follow generally accepted industry standards to protect against unauthorized access, use, alteration, disclosure, or destruction of PII. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect PII, we cannot guarantee its absolute security.
2. Your PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required by contract to keep the information confidential.
3. We implement a variety of security measures to maintain the safety of your PII.
VIII. CALIFORNIA RESIDENTS' RIGHTS
1. California residents have specific rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"). This section provides information about these rights and how to exercise them.
2. Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information").
We collect the following categories of Personal Information:
• Identifiers such as name, email address, and IP address
• Personal information categories listed in the California Customer Records statute
3. We obtain this information directly from you when you use our Services or contact us, and automatically through your interaction with our platform.
4. Use of Personal Information
We use the Personal Information we collect for business purposes including:
• Providing and improving our Services
• Responding to your inquiries and requests
• Maintaining the security of our platform
• Complying with legal obligations
5. Sharing Personal Information
We may disclose your Personal Information to service providers and third parties who help us operate our business. We do not sell Personal Information as commonly understood (exchanging information for money). However, the CCPA/CPRA defines "sale" and "share" broadly to include the sharing of Personal Information for targeted advertising or analytics. Under this definition, we may "share" certain information with analytics providers.
6. Your California Privacy Rights
As a California resident, you have the right to:
• Know what Personal Information we collect about you and how we use it
• Request deletion of your Personal Information (with certain exceptions)
• Correct inaccurate Personal Information
• Opt-out of the sale or sharing of your Personal Information
• Limit the use of sensitive Personal Information (if collected)
• Non-discrimination for exercising your rights
7. To exercise these rights, please email us at michal@phasevtrials.com . We will respond to verifiable requests within 45 days.
IX. COOKIES AND TRACKING TECHNOLOGIES
Our Website uses cookies and similar technologies to enhance your experience. For detailed information about the cookies we use, please see our Cookies Policy.
To the extent legally permitted, we may allow third-party behavioral tracking. We adhere to the standards set out in this Privacy Policy and do not monitor or respond to Do Not Track browser requests.
X. FAIR INFORMATION PRACTICES
In order to be in line with Fair Information Practices, we will take the following responsive actions should a data breach occur:
1. We will notify you within the time required by applicable law, but no later than three business days from becoming aware of any such breach.
2. We also agree to the Individual Redress Principle, which requires that individuals have enforceable rights against data collectors and processors who fail to adhere to the law, including recourse to courts or government agencies to investigate and/or prosecute non-compliance.
XI. EMAIL COMMUNICATIONS
1. We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions
• Send you additional information related to our Services
• Market to our mailing list or continue to send emails to our clients after the original engagement
2. To be in accordance with CAN-SPAM Act requirements, we:
• Will not use false or misleading subjects or email addresses
• Will identify the message as an advertisement in a reasonable way
• Will include the physical address of our business
• Will monitor third-party email marketing services for compliance, if used
• Will honor opt-out/unsubscribe requests promptly
• Will allow users to unsubscribe via the link at the bottom of each email
XII. THIRD-PARTY SERVICES
1. Third-party Service Providers
The third-party providers we use will only collect, use, and disclose your information to the extent necessary to allow them to perform the Services they provide to us. However, certain third-party service providers have their own privacy policies regarding the information we provide to them.
We recommend that you read their privacy policies to understand how your PII will be handled by these providers. Remember that if you use services that involve third-party providers, your information may become subject to the laws of the jurisdiction(s) where those providers or their facilities are located.
Once you leave our Website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.
2. Third-party Links
Occasionally, we may include or offer third-party services on our Website. These third-party sites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
XIII. AGE OF CONSENT
By using our Website, you represent that you are at least the age of majority in your state, province, or country of residence, or that you are the age of majority and you have given us your consent to allow any of your minor dependents to use this site.
XIV. LAW AND JURISDICTION
1. The law that applies to activity on the Website and this Privacy Policy is the law of the Commonwealth of Massachusetts, United States.
2. Exclusive jurisdiction to hear any dispute regarding the Website and/or this Privacy Policy is conferred to the competent courts located in Middlesex County, Massachusetts, United States.
XV. CHANGES TO THE PRIVACY POLICY
1. We reserve the right to modify this Privacy Policy at any time. Changes and clarifications will take effect immediately upon posting on the Website. In the event of a material change, we will notify you via email or by means of a prominent notice on the Website.
2. If we are acquired or merged with another company, your information may be transferred to the new owners so that we may continue to provide our Services to you.
XVI. CONTACTING US
If you have any questions regarding this Privacy Policy, you may contact us at: michal@phasevtrials.com
Last updated: May 1, 2025