Privacy Notice
20 January 2025
This Privacy Policy applies to the personal data that we process as
part of the proposed study. At Ad Scientiam, we respect your privacy
and want to inform you about the processing of your personal data
while allowing you to exercise your rights. The purpose of this
Privacy Policy is to inform you of the personal data we collect, the
purposes for which we process it, the length of time we keep your
personal data, and your privacy rights.
Taking part in this research is voluntary. You may decide not to
participate, or you may leave the study at any time. Your decision
will not result in any penalty or loss of benefits to which you are
otherwise entitled.
If you have any questions, concerns, or complaints or think this
research has hurt you, talk to the research team at the phone
number(s) listed in this document.
What is the purpose of this study?
The objectives of this study are to validate the clinical performance
of ME&MG compared to standard in-clinic testing and to evaluate the
safety, usability, and satisfaction of the solution. By participating
in this study, patients can contribute to the validation of an
innovative solution that may improve the monitoring of gMG by doctors
and patients in autonomy.
How will my personal information be protected and kept confidential?
The processing of your personal data is governed by the General Data
Protection Regulation (EU) 2016/679 (“GDPR”) and by the laws
applicable in your country of residence.
Sponsor will work with Alexion Pharmaceuticals, Inc (“Alexion”) to
support the study; as such, Alexion and Sponsor are Joint Controllers
of your personal data. If you agree to participate in the study,
certain personal information about you will be collected, stored,
processed, and used by:
-
Ad Scientiam, Sponsor of the clinical study, acting as “Data
Controller” and located in France.
-
Alexion, its affiliates or other third parties designated by
Alexion. to collect or review study data, acting as “Data
Controller” and located in the United States.
-
Popsicube, its partners and affiliates, a Clinical Research
Organization in charge of the organization of the clinical study,
acting as “Data Processor” and located in the European Union.
-
Services providers, providing services related to the organization
of clinical studies, data hosting and the compensation of
participants, acting as “Data Processor(s)” located in the
European Union, the United Kingdom and the United States.
-
Investigators, Investigating sites and staff, for the conduct of
the study, acting as “Data Processor(s)”, located in the European
Union and the United States.
-
The Institutional Review Board/ Ethics Committee that oversees the
research study at your site.
-
Government regulatory agencies including US Food and Drug
Administration, European Medical Agency, Therapeutic Goods
Administration, Health Canada, and other Regulatory Authorities
worldwide.
The legal basis selected by the Data Controllers is the pursuit of
legitimate interests. Study data, including your coded medical
information, may be processed, which means it will be collected,
entered into computer databases, stored, accessed, verified, analyzed,
transferred, printed and reported as necessary for legitimate
scientific purposes, including use in future medical or pharmaceutical
research. This processing is authorized because it is necessary for
scientific research purposes. The Data Controllers must implement
appropriate measures to guarantee your rights and freedoms, including
the collection of only strictly necessary data for research purposes.
If you have any question on the legal basis for the processing of your
personal data, you may contact the Investigator at the number(s)
listed at the beginning of this document. In order to maintain your
confidentiality to the Sponsor, comments, communications, and
complaints addressed to the Sponsor’s Data Protection Officer (
privacy@adscientiam.com) should be first relayed to Investigator, if at all possible.
Where applicable, the data transfer is made pursuant to an adequacy
decision of the European Commission (art 45 of the GDPR) or
appropriate safeguards such as contractual clauses between the Data
Controllers and/or Data Processors (art 46 of the GDPR). By
participating in this study, your personal data will be transferred in
the European Union, the United Kingdom and the United States. If you
would like more information about the transfer of your personal data,
you may contact the Investigator at the number(s) listed at the
beginning of this document. In order to maintain your confidentiality
to the Sponsor, comments, communications, and complaints addressed to
the Sponsor’s Data Protection Officer (
privacy@adscientiam.com) should be first relayed to Investigator, if at all possible.
Which data will be collected?
If you agree to participate in the study, the following data will be
collected:
-
Socio-demographic data (month and year of birth, sex, country,
family situation, level of education, socio-professional category,
professional life),
-
Clinical data (weight, height, therapy followed in the context of
the research, concomitant therapy, test results, adverse events,
personal or family history, diseases or associated events, health
status likely to influence the results or to make participation
impossible due to medical contraindications, tobacco/alcohol/drug
consumption),
-
ME&MG tests and questionnaires raw data (timestamp, sensory
sensors, accelerometer, gyroscope, relative position, voice sound,
face image, user responses to questions about weakness of arm),
and questionnaires (user responses to the various application
questionnaires)
-
ME&MG tests and questionnaires metadata (start date, completion of
the test of questionnaire, exit reason etc.)
-
Data that is created or collected from you during your
participation in the study, including the dates of treatments and
visits, participation in other ongoing studies, travel to the care
facility, lifestyle and behaviors, reimbursement of expenses
incurred by the person concerned related to the research, results
of the tests above and any other procedures performed during the
study.
- During the "My Eyelids" test, you will be prompted to take a selfie. For iOS users, the tools built into your smartphone are used to detect your face's position in order to trigger the selfie. This facial positioning data is processed exclusively on your device and is not shared with Ad Scientiam or Apple. Once the selfie is taken, only the photo itself will be processed by Ad Scientiam.
-
The following data will be collected in order to compensate you
for your participation:
-
First and last name, date of birth, e-mail address, billing
address, shipping address (for delivery of plastic cards, if
applicable), cell phone number, IP address, IBAN (optional, if the
user makes a transfer to their account), identification number in
the clinical study, follow-up of the participation in the clinical
study, follow-up of the realization of the study visits, expenses
to be reimbursed with their justifications.
-
If you would like more information about the personal data
collected, you may contact the Investigator at the number(s)
listed at the beginning of this document. In order to maintain
your confidentiality to the Sponsor, comments, communications, and
complaints addressed to the Sponsor’s Data Protection Officer (privacy@adscientiam.com) should be first relayed to the Investigator, if at all
possible.
For how long will my personal data be kept?
This informed consent form and the personal information collected as a
part of this study will be kept until 2 years after the publication of
the final study report, unless legal retention requirements force the
Data Controllers and/or their Data Processors to keep the data for a
longer retention period.
After this 2 years period, your personal data will be archived by the
Sponsor and/or Data Controllers for twenty-five (25) years after the
study has ended, in accordance with applicable regulations.
Your personal data will be archived by the Investigators,
Investigating sites and staff for fifteen (15) years after the study
has ended, in accordance with applicable regulations.
After this delay, your personal data will be securely deleted or
anonymized, for example it can be used in a non-identifiable way for
statistical analysis and business planning.
Will study results be confidential?
The results of the research may be presented at scientific meetings or
in publications; however, your identity will not be disclosed.
You will provide personal information as a result of participating in
this study, leading to a slight risk of loss of confidentiality. Every
effort will be made to protect this information from disclosure.
However, the U.S. Food and Drug Administration (FDA) and other
regulatory offices may inspect study records. At the initial session
you will be assigned a unique participant number that will be used
throughout the study. Your personal identity will not be revealed in
publications that may result from this study, nor will your name be
used in other research communications such as lectures at scientific
meetings. Experimental data as well as personal information will be
kept securely by the Investigators and will not be released in any way
that could be identified with you personally. Only summary statistics
such as your age and gender will be included in published experimental
results. This consent form, as well as any form which contains your
personal contact information, will be stored in a location accessible
only to the Site Investigator or approved designee.
A description of this clinical trial will be available on
http://www.ClinicalTrials.gov, as required by U.S. Law. This Web site will not include information
that can identify you. At most, the Web site will include a summary of
the results. You can search this Web site at any time.
What if I change my mind?
Participation in this study is entirely voluntary. You may choose not
to take part or may leave the study at any time. Refusing to take part
or leaving the study will not result in any penalty or loss of
benefits to which you are otherwise entitled. If you change your mind
at any time, you are free to end the session and to withdraw from the
study. Your decision of whether or not to participate in this study
will not affect the quality of the medical care you receive at this
facility. You may take as much time as you need to make up your mind
if you will participate.
Your decision regarding the processing of your personal data will not
result in any harm. You may withdraw your consent to the processing of
your personal data at any time without justification and without
consequence. If you choose not to consent or to withdraw your consent
to the collection, access, use, storage, disclosure, and transfer of
your data, you will not be able to participate in the study, as your
data is needed to conduct the study. If you revoke your consent, your
participation in the study will end with the completion of the Early
Termination/End of study visit(s) and the study personnel will not
collect any new medical information from you.
You have the right to access your personal data, the right to rectify
inaccurate data , the right to be forgotten allowing you to request
the deletion of your personal data, the right to restrict the
processing of your data, and the right to object, at any time, to the
processing of your personal data as permitted under your country’s
applicable data protection laws and laws related to the conduct of
clinical trials.
To exercise these rights or if you have any questions about the
processing of your data, you can contact the Investigator at the
number(s) listed at the beginning of this document. In order to
maintain your confidentiality to the Sponsor, comments,
communications, and complaints addressed to the Sponsor’s Data
Protection Officer (
privacy@adscientiam.com) should be first relayed to Investigator, if at all possible.
In accordance with Article 77 of the GDPR, if you believe, after
contacting us, that your rights are not being respected, you have the
right to lodge a complaint with the privacy or data protection
regulator in your country of residence.