Data protection

Data protection information for website visitors, in particular potential study participants

(Data protection information according to Art. 13 DSGVO as well as § 12 IDG/ZH)

In summary, the most important information:

• The University of Zurich is initiating, organizing and financing a clinical study on an experimental therapy for the treatment of stress incontinence (hereinafter referred to as the “Study”). It is responsible for data collection.
• admedicum GmbH & Co. KG assists in the search for study participants strictly bound by instructions as a contract processor.
• Based on your answers in the online questionnaire, we would like to find out whether you could be considered as a study participant and whether you are interested in participating in the study.
• The online questionnaire is voluntary and anonymous.
• If you may be eligible to participate in the study and you are interested in the study, you may leave your contact information following the online questionnaire and consent to us contacting you regarding possible participation.
• If you provide us with the contact information, the online questionnaire will no longer be anonymous.
• admedicum GmbH & Co KG collects and receives this data and contacts you to clarify a possible participation in the clinical study. admedicum GmbH & Co. KG acts on behalf of the University of Zurich.
• Initially, the University of Zurich will not have access to your contact data. Only if you have finally decided to contact the University Hospital Zurich (study center) directly regarding the study, there is the possibility that your data will be forwarded. For this purpose, you will be additionally asked for your consent in advance.
• Your possible consent to this does not yet constitute consent to the study participation itself.

1. What is this document about?

This privacy notice explains how we handle your personal data when you

• visit our information website at https://www.muvon-studie.ch about a clinical study concerning stress incontinence therapy
• you complete the online questionnaire there, which helps you to determine whether you are eligible to participate in the study, and 
• you decide to leave us your contact information so that you can later receive further information about study participation.

In addition, we will inform you about your rights under the European General Data Protection Regulation (GDPR). If you reside in Switzerland, you may also invoke the Law on Information and Data Protection of the Canton of Zurich (IDG/ZH), but you may optionally invoke European law vis-à-vis us.

This document does not refer to data processing in the context of the study by the study center. If you later decide to participate, you will receive separate, comprehensive information on this from the study center and provide separate data protection consent.

2. How do I contact the data controller and data protection officer?

As the data protection officer, we are legally responsible and required by law to provide our contact information:

University of Zurich
Wyss Zurich Translational Center
Weinbergstrasse 35
CH 8092 Zurich
Tel. +41 44 255 1223
E-mail: markus.veit@wysszurich.ch

However, if you have any questions regarding data protection, please contact directly the data protection officer of our service provider and processor according to the GDPR, admedicum GmbH & Co. KG:

Dr. Ruth Reimann
admedicum GmbH & Co. KG
Industriestraße 171
50999 Cologne
Telephone: +49 2236 947 33 60
E-mail: dataprotection@admedicum.com 

3. What data do we collect and for what purpose?

The University of Zurich (hereinafter referred to as “UZH”) is developing a therapy for the treatment of stress incontinence. UZH is the “sponsor” of the clinical study (“study”), which is conducted by a “study center” (University Hospital Zurich). The sponsor is responsible for the study in that it initiates, organizes and finances the study. Within the framework of the MUVON project, the UZH has set up a website with the objective of making the clinical study in stress incontinence better known and to find new study participants in Switzerland, Germany and Austria.

a) Questions about eligibility for the study (online questionnaire)

With the online questionnaire you can find out whether you are eligible to participate in the study. You do not have to give us your name or contact details. The online preliminary questionnaire is therefore anonymous and, of course, voluntary.

b) Consent to be contacted by admedicum

If you might be suitable for participation in the study on the basis of the information entered in the online pre-survey and you are interested, you can leave your contact details by telephone or electronically following the questions on suitability and allow admedicum to contact you regarding possible participation. 

The corresponding online consent will then read:

Data Protection Consent – Contact regarding possible participation in a clinical trial.

I agree that admedicum GmbH & Co KG, on behalf of the University of Zurich, Wyss Zurich Translational Center, Weinbergstrasse 35, 8092 Zurich, may link my provided contact data (name, e-mail/telephone) and my answers from the online preliminary survey and that admedicum GmbH & Co KG may contact me by e-mail and/or telephone (as requested by me). The purpose of contacting me is to clarify a possible participation in a clinical study on stress incontinence therapy. 

My consent includes personal data about my health (stress incontinence disease).

By giving your consent, you are not yet agreeing to participate in the study. If you participate in the study, you will receive further information from the study center and provide a separate consent form.

If you give your consent, we will subsequently ask you for your name and the desired form of contact (e-mail/telephone) and accordingly for your e-mail address and/or telephone number via an online form. You can also provide an ALIAS name and/or an ALIAS e-mail address to contact us.

In addition, we ask you to tell us which language you speak and in which region you live.

Note: This data protection consent on your part is voluntary. You can revoke it at any time with effect for the future. To do so, please contact the data protection officer of our service provider, admedicum GmbH & Co KG. With your consent, you do not yet agree to participate in the study.

c) Consent to be contacted by the study center

We can also assist you in making an appointment at the study center. If you give consent, we may provide your contact information to the study center. If you do not provide consent, we cannot assist you in making an appointment at a study center. However, you may alternatively contact the study center directly.

The appropriate online consent to forward contact information to the study center will then be:

Data protection consent – contact by the study center of the University Hospital Zurich.

I agree that admedicum GmbH & Co. KG, on behalf of the University of Zurich, Wyss Zurich Translational Center, Weinbergstrasse 35, 8092 Zurich, may link my contact data provided below (name, e-mail/telephone) with my answers from the online preliminary questionnaire, as well as the data collected by telephone and via other communication, and forward this data to the study center (University Hospital Zurich), if necessary. The forwarding of the data serves the purpose of further clarification and contact by the study center regarding possible participation in a clinical study on stress incontinence therapy. 

My consent includes personal data about my health (stress incontinence disease).

If you do not provide consent, the study center will not be able to contact you regarding an appointment at the study center. 

Notes: This data protection consent on your part is voluntary. You can revoke it at any time with effect for the future. Please contact the data protection officer of our service provider, admedicum GmbH & Co KG. With your consent, you do not yet agree to participate in the study.

4. How long do you store my data?

We store your data from the questionnaire for contacting you and for documentation and follow-up purposes until 8 months after the patient recruitment of the study.  After that, your data will be deleted. If you withdraw your consent, we will delete your data immediately.

5. Who receives my data?

We may also use technical service providers who process your data according to our instructions (so-called “order processors”). Currently, we use admedicum GmbH & Co. KG as a service provider and order processor, who in turn uses the following sub-processors: 

• ALL-INKL.COM – Neue Medien Münnich, Inhaber: René Münnich, Hauptstraße 68 | D-02742 Friedersdorf
• Zacher Media GmbH
• Google (see point 9)
• Momentive Europe UC, 2 Shelbourne Buildings, Second Floor, Shelbourne Rd
  Ballsbridge, Dublin 4, Ireland, for the purpose of conducting the online questionnaire

a) ALL_INKL.COM – Neue Medien Münnich (ALL-INKL.COM)
(ALL_INKL.COM – New Media Münnich (ALL-INKL.COM))
The website containing the clinical trial information is hosted by ALL-INKL.COM. For details of data collection via the web server, please refer to section 7.

b) Zacher Media GmbH
The company Zacher Media GmbH in cooperation with admedicum GmbH & Co. KG and provides technical support for the site.

c) Google Analytics
We use the company Google Analytics for website analysis and thereby set so-called cookies. For details on the data collection via the web server, please refer to section 9.

d) The information that you provide anonymously in the preliminary questionnaire, as well as all personal data that you provide after giving your consent to be contact, is stored exclusively on the Momentive platform on European servers. The name of this company is:

Momentive Europe UC
2 Shelbourne Buildings,
Second Floor,
Shelbourne Rd
Ballsbridge,
Dublin 4,
Ireland

Contact 

Momentive Europe UC’s privacy policy can be viewed in detail here: https://www.surveymonkey.com/mp/legal/privacy/. 

Should admedicum further process your data collected via the Momentive platform and other communications with you (telephone, email, etc.), admedicum will ensure that your electronically stored data is secure against loss, destruction, manipulation or access by unauthorized persons by storing it on a cloud service certified with the highest industry standard ISO27018. Written notes and documents are also digitized and secured electronically. Paper originals are also stored in a secure location.

6. What legal basis do you rely on?

The legal basis for processing your data from the online preliminary inquiry is your data protection consent (Art. 6 para. 1 lit. a) DSGVO) or § 8 IDG/ZH in conjunction with. § 2 UniG/ZH. 

7. What data do the servers collect in the background?

When you access a single page of our website (ALL-INKL.COM), our web servers record in a log file the address (URL) of the page accessed, the date and time of access, any error messages and, if applicable, the operating system and browser software of your end device as well as the website from which you are visiting us.   

The incoming IP address is stored by our servers for one week and then irrevocably deleted from the log file. 

The IP address is a number that your Internet provider assigns to your PC, smartphone or other end device, either temporarily or permanently. With a complete IP address, it would be possible to identify the connection owner in individual cases, for example, using additional information from your Internet access provider. However, neither the information you provide anonymously in the preliminary inquiry nor any personal data you provide after giving your consent to be contacted will be stored on the website server, but on the Momentive platform (see there). The online pre-screening is therefore not collected by ALL-INKL.COM (and Google Analytics, see section 9).

ALL-INKL.COM also does not have access to e-mails.

Log file data is used by us exclusively to ensure the functionality of our services (e.g. error analysis, ensuring system security and protection against misuse). Insofar as log data qualifies as personal data in individual cases, the legal basis for the processing of log file data is our aforementioned legitimate interests, Art. 6 para.1 lit. f DSGVO or § 8 IDG/ZH in conjunction with. § 2 UniG/ZH.

8. Do you use cookies?

When you perform the online questionnaire, our server sets cookies on your computer, i.e. small text files whose content is transmitted to our server each time you visit our site. 

The first cookie contains a random identification number and is technically necessary because it is used to enable you to answer or interrupt and continue the online pre-query. This cookie is deleted when you close the browser (so-called “session cookie”). 

With the second cookie, we store your language setting. This cookie expires after 30 days. 

The third cookie stores your cookie settings. This cookie has a duration of one year.

You can deactivate the use of cookies via your browser settings, but participation in the online pre-survey will then no longer be possible. 

Further cookies are set as part of Google Analytics. Please read section 9 for more information.

9. Do you use tools to evaluate website visits?

1. Use of Google Analytics

Yes. We use – subject to your consent – the “Google Analytics” service from Google to anonymously record how users use our website, to create anonymous evaluations and to design our website accordingly in line with requirements. We do not integrate Google Analytics in the online preliminary inquiry and the form for your contact data, so that no information in this regard reaches Google.

When you access our website for the first time, we have asked you for certain cookie and privacy consents. The consents are voluntary and can be revoked by you at any time with effect for the future. 

You can view the status of your consent here and change it at any time: 

[borlabs-cookie type=”btn-cookie-preference” title=”Cookie Einstellungen”/].

If you give us your consent to data processing for statistical purposes, we use the “Google Analytics” service from Google to record how users use our website in a pseudonymized form, to create anonymized evaluations and to design our website accordingly in line with requirements. This enables us to find out, for example, which end devices are used to visit our site and which content is particularly in demand, and then optimize the content and technology of the site accordingly. 

With your consent to data processing for statistical purposes, you also consent to the transmission of your data to Google LLC in the USA, an “unsafe third country”. For details on your consent in this regard, please refer to chapter 9.b) “Consent to data transfer to unsafe third countries”. 

On the pages of the questionnaire and the form for your contact details, we do not integrate Google Analytics, so that no information in this regard reaches Google.

You can view the status of your consent here and change it at any time: 

[borlabs-cookie type=”btn-cookie-preference” title=”Cookie Einstellungen”/]

Google Analytics is an analytics tool provided by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (“Google”). 

Google acts as our processor when providing Google Analytics. 

Supplementary information on data protection at Google can be found in Google’s privacy policy.

Using Google Analytics, we record when you visit which pages of our website, your rough location, and data about the terminal device you use (e.g. device type, operating system, or screen resolution). This data is processed pseudonymously, i.e. used in such a way that the data is not linked to information that directly identifies you (e.g. name, e-mail address). 

Google Analytics uses cookies for this purpose, which are stored on your terminal device and which enable an analysis of your use of the website. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. The cookie has a lifespan of 3 months. Details on the use of cookies can be found in chapter 8). 

IP anonymization has been activated on our website so that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and, where applicable, providing other services relating to website activity and internet usage to us as the website operator. 

Your data accrued within the scope of Google Analytics will be deleted after 14 months.

The processing of your data is based on your consent.

Terms and explanations

Cookie: A cookie is a small text file that is stored on your computer. The contents of this file are transferred to our servers each time you visit a website.

IP Address: The IP address is a number that your Internet provider assigns to your terminal device, either temporarily or permanently. With a complete IP address, it is possible, for example, on the basis of additional information from your Internet access provider, to identify the connection owner in individual cases.

Processors: These are technical service providers who process personal data for us for a specific purpose and according to our specifications. We have entered into contractual agreements with order processors in accordance with the requirements of the DSGVO to ensure data protection.

Legal basis

The European GDPR only permits processing of personal data if a legal basis allows it. We are required by law to inform you of the legal basis for processing your data. 

In the following, we explain the terms used when naming the legal bases.

Also according to the Swiss IDG/ZH, there is no legal ground preventing data processing for the purpose of contacting and testing for suitability to participate in the clinical trial.

1. Consent to data transfer to unsafe third countries.

If you give consent to data processing for statistical purposes, you give us your consent – revocable at any time with effect for the future – to transfer your data to the company Google LLC for which there is no decision by the EU Commission stating that the country has a level of protection for personal data adequate to that of the EU (so-called “unsafe third country”). 

You can view the status of your consent here and change it at any time: 

[borlabs-cookie type=”btn-cookie-preference” title=”Cookie Einstellungen”/]

To withdraw consent for data transfer to unsafe third countries, please uncheck all optional checkboxes.

By giving your consent, you expressly agree, while accepting the risks mentioned below, that we transfer your data to Google LLC and thus to unsecure third countries, in particular the USA.

The processing takes place in these countries without having to comply with the data protection principles of lawfulness, processing in good faith, transparency, purpose limitation, data minimization, accuracy and storage limitation, integrity and confidentiality enshrined in the EU. In addition, your rights to information, access, rectification, erasure, restriction of processing, data portability and objection guaranteed under EU law may not be guaranteed in these countries. 

The rule of law (e.g. the principle of proportionality), respect for human rights and fundamental freedoms (e.g. the right to protection of personal data) in the country concerned may not meet EU standards. This is the case, for example, with respect to public security, defense, national security and criminal law regulations, as well as access to and application of personal data by public authorities. There may also be insufficient protection for onward transfers of personal data to other unsecure third countries. Administrative or judicial enforcement of your rights may be limited in unsecure third countries compared to the EU.

Unsecure third countries also may not have data protection supervisory authorities comparable to those in the EU or may not operate effectively. Authorities in unsecure third countries may not have sufficient enforcement powers and assistance and advice for data subjects, and supervisory authorities may not cooperate with those in the EU. 

In the U.S. specifically, government agencies can also access data more easily and extensively, without proportionality and necessity restrictions comparable to those in the EU. In addition, you cannot litigate compliance with data access requirements by non-U.S. government entities. 

10. What applies when using the contact form?

Using the contact form on the website, you can send requests directly to our order processor, admedicum GmbH & Co. KG. We only need your e-mail address. Providing your name or telephone number is voluntary. The data transmission is encrypted.

We will use your contact data to contact you as well as for documentation and follow-up purposes for up to 8 months after the end of patient recruitment for the study. After that, your data will be deleted. For data concerning study participation, section 4 applies.

The legal basis for this is our legitimate interest in enabling you to contact us quickly and directly, Art. 6(1)(f) DSGVO, and insofar as your request concerns health data, your consent, Art. 6(1)(a) DSGVO. If you do not wish to provide consent, please use an alternative means of contact. If the IDG/ZH applies, § 8 IDG/ZH in conjunction with. § 2 UniG/ZH.

11. What rights do I have under the GDPR?

By law, we are required to inform you of your rights under the GDPR. We explain these rights below. You are entitled to the rights under the conditions of the respective provisions of data protection law. They also comprehensively cover the rights to which you are entitled under the Swiss Data Protection Act. The following description does not grant you any further rights.

a) Information

You have the right to request confirmation from us as to whether we are processing personal data relating to you; if this is the case, you have a right of access to this personal data and to the information listed in detail in Article 15 of the GDPR.

1. Rectification

You have the right to request from us without undue delay the rectification of any personal data relating to you that is inaccurate and, where applicable, the completion of any personal data that is incomplete, Art. 16 DSGVO.

1. Deletion

You have the right to demand that we delete personal data concerning you without undue delay, provided that one of the reasons listed in detail in Art. 17 DSGVO applies, e.g. if the data is no longer required for the purposes pursued.

d) Restriction of processing (blocking).

You have the right to demand that we restrict processing (blocking of data) if one of the conditions listed in Art. 18 DSGVO applies.

e) Data portability

You have the right, under certain conditions, to receive data relating to you that you have provided to us in a structured, common and machine-readable format, to transmit it and, if technically feasible, to have it transmitted, Art. 20 DSGVO.

f) Complaint

 You have the right to lodge a complaint with a supervisory authority, irrespective of any other administrative or judicial remedy, if you consider that the processing of personal data concerning you by us infringes the GDPR, Art. 77 GDPR. You may assert this right before a supervisory authority in the Member State of your residence, workplace or the place of the alleged infringement.

g) Revocation (of consent)

If you have given us data protection consent, you have the right to revoke this at any time with effect for the future. 

In the event of a revocation of your consent printed above, we will delete your data and not pass it on to study centers. A revocation does not affect the lawfulness of the processing of your data until the revocation. Please note that the study centers are independent data controllers with regard to the handling of data that we have forwarded to them.

h) Objection

You also have the right to object at any time to the processing of personal data relating to you on grounds relating to your particular situation, provided that we base the processing on Art. 6 (1) lit e. or f DSGVO. We will then no longer process this data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims (Art. 21 DSGVO).