What Information We Collect; the Purpose of Collection and Use. We limit our collection of personal data to the minimum necessary to fulfill the stated purposes as set forth below.
Contact Information: We may collect contact information on our Site from visitors who wish to obtain information, subscribe to our email alerts, and contact us with questions. Contact information is provided via browser forms and may include first name, last name, e-mail address, job title, name of the organization, and other information necessary for us to properly respond. This contact information is used by our public relations, investor relations, customer service and Product teams to contact our Site visitors, and to compile and deliver our responses. Our business development team uses the contact information provided by prospective business partners to contact them and provide requested information.
Clinical Trials: Corbus sponsors clinical research studies under the jurisdiction of the U.S. Food and Drug Administration (“FDA”) and other foreign regulatory authorities regarding the effectiveness and safety of our Products (“clinical trials”). All clinical trials require pre-approval from an appropriately constituted institutional review board or ethics committee. Your participation in a clinical trial is completely voluntary, and requires that you consent in writing to the scope of the research to be conducted using the information gathered from and about you during the clinical trial by contract research organizations and other personnel engaged for this purpose (“clinical trial personnel”). Such information may include, as applicable, your name, demographic information (age, race, gender, and ethnicity), medical history, disease state, information regarding biological specimens and tissue samples, and adverse events. Corbus receives only a subset of this information in the form of Key-Coded Data (see below).
Key-Coded Data: Clinical trial personnel remove information that identifies individual clinical trial participants from data collected at the clinical trial site to create data sets (“Key-Coded Data”), which are provided to Corbus. The Key-Coded Data applicable to each clinical trial participant is identified by a unique key code, which is retained by clinical trial personnel and not shared with Corbus. There are no circumstances where we receive the key code or identify the individual. Corbus will use and share your Key-Coded Data for the general research purposes for which it was originally collected and for research that is consistent with your original consent, or to which you have subsequently consented. When the key code is held only by the clinical trial personnel and not given to Corbus, then a transfer of Key-Coded Data from the European Economic Area to the United States does not constitute a transfer of personal data under the Privacy Shield (although Key-Coded Data may be subject to other Union or Member State laws).
Cookies. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visits to our Site and other sites as described under “Google Analytics,” above. If you do not want us, Google Analytics or the Site to place a cookie on your hard drive, you may be able to turn that feature off on your device. Please consult your Internet browser’s documentation for information on how to do this, such as by using your browser in private mode to block cookies. However, if you decide not to accept cookies from our Site, the Site may not function properly.
Aggregate Data. In an ongoing effort to better understand our users and the Site, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Products and the Site to current and prospective business partners and to other third parties for other lawful purposes.
Disclosure to Public Authorities. We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Disclosure to Regulatory Authorities and Researchers. We may disclose Key-Coded Data to government regulators in the United States and foreign regulatory authorities for regulatory and supervision purposes. We may also disclose Key-Coded Data to public and/or private researchers, subject, as applicable, to the Privacy Shield Principles.
Direct Marketing and Email Preferences. Corbus will not use or share your personal information for direct marketing purposes. However, you cannot opt out of receiving transactional e-mails related to your requests for information or materials.
Access to personal information. Upon request to email@example.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to access, correct, amend or delete your personal information, restrict the processing of your personal information, receive a copy of your personal information, and/or transfer your personal information to a third party. Please allow us a reasonable time to respond to your inquiries and requests.
If you are participating in a “blinded” clinical trial for one of our Products, your request to access your Key-Coded Data during the trial will be declined, provided that this restriction was explained to you when you entered the trial and the disclosure of such information would jeopardize the integrity of the research effort. Following the conclusion or other termination of the blinded clinical trial and analysis of the results, we will forward your request for access to your Key-Code Data to clinical trial personnel that have the Key Code. We recommend that you first request Key-Coded Data directly from your health care provider in the clinical trial (who can also provide access to other data collected at the clinical trial site) and secondarily from us.
If you withdraw, or are asked to withdraw, from a clinical trial of our Products, your Key-Coded Data collected previously to your withdrawal may still be processed along with other data collected as part of the clinical trial, if this was made clear to you in the notice at the time you consented to participate in the clinical trial.
Important Notice to All Individuals Located Outside the US. Our servers may be located outside of the U.S. and the European Economic Area. If you are located outside of the U.S., please be aware that any information provided to us, including personal information, will be transferred from your country of origin. Except in the case of data transfers under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Site, constitutes your consent to this data transfer.
Corbus is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Product Safety and Efficacy Monitoring. As a pharmaceutical company, Corbus does not have to apply the Privacy Shield Principles with respect to the Notice, Choice, Accountability for Onward Transfer, and Access Principles in its product safety and efficacy monitoring activities, including the reporting of adverse events and the tracking of patients/subjects using certain medicines or medical devices, to the extent that adherence to the Privacy Shield Principles interferes with compliance with regulatory requirements. This is true both with respect to reports by, for example, health care providers to pharmaceutical companies, and with respect to reports by pharmaceutical companies to government agencies like the FDA.
California Privacy Rights. Corbus does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
Phone: +1 617 963 0100
Rev: May 2018