Privacy Notice For Volunteer Database Registration

This privacy notice explains how SGS NAM Cosmetics and Hygiene may collect, use, store and protect personal information when you register in the volunteer database or are screened for potential participation in clinical studies.

1. Information we may collect

Identification and contact information, such as name, email address, phone number, address, date of birth and communication preferences.
Volunteer profile information, such as availability, study preferences, participation history and account activity.
Eligibility and screening information, such as demographic information, cosmetic routines, product habits, skin, scalp, hair, nail or oral characteristics, allergies, sensitivities, pregnancy or breastfeeding status, medication use, relevant health information and other protocol related criteria.
Study-related information, if you later participate in a study, such as visit attendance, questionnaire answers, observations, measurements, images, product use information, adverse events or reactions, and payment related information when applicable.
Technical information related to the use of the registration platform, such as login activity, device or browser information, security logs and consent records.

2. Why we use your information

Create and manage your volunteer account.
Assess whether you may be eligible for current or future studies.
Contact you about study opportunities, appointments, reminders, administrative updates and follow-up requests.
Protect participant safety and support study quality.
Manage study operations, scheduling, compensation and participant support.
Meet legal, regulatory, contractual, quality, audit, security and record keeping obligations.
Improve operational processes, database quality and communication, where permitted by law and internal policies.

3. Health information and HIPAA aligned handling

Some information collected during screening or study participation may relate to your health or physical characteristics. Where the Health Insurance Portability and Accountability Act (“HIPAA”) applies, SGS NAM Cosmetics and Hygiene will handle protected health information in accordance with applicable HIPAA requirements, including appropriate safeguards, permitted uses and disclosures, minimum necessary access, and individual rights. Where HIPAA does not directly apply, SGS-NAM Cosmetics and Hygiene will apply privacy and security controls designed to protect sensitive health related information.

4. GDPR aligned transparency and lawful use

For individuals protected by GDPR or similar data protection laws, SGS NAM Cosmetics and Hygiene should provide clear information about the data controller, purposes of processing, legal bases, categories of data, recipients, international transfers, retention periods, individual rights, and how to contact the privacy team. Depending on the context, processing may rely on consent, performance of requested volunteer services, legitimate interests, legal obligations, or explicit consent for special category health related information.

5. How we may share information

Within SGS NAM Cosmetics and Hygiene and authorized personnel need access for volunteer database management, study operations, quality, safety, IT, privacy, finance or administrative purposes.
With service providers that support the registration platform, communication, scheduling, data hosting, security, study operations, payment administration or technical support, under appropriate contractual safeguards.
With study sponsors, auditors, ethics or review bodies, regulatory authorities, or other parties where required or permitted by law, contract, protocol or consent documentation.
With emergency or medical personnel if needed to protect participant health or safety.
SGS NAM Cosmetics and Hygiene will not sell volunteer personal information or use sensitive health information for unrelated marketing without appropriate authorization or consent.

6. International transfers

Information may be stored, accessed or processed in the United States and, where necessary, in other countries. Where GDPR or similar laws apply to international transfer, SGS NAM Cosmetics and Hygiene will use appropriate safeguards, such as contractual protection, transfer impact assessments where required, access controls, encryption and other organizational measures.

7. Retention

SGS NAM Cosmetics and Hygiene should keep volunteer database information only for as long as necessary for the purposes described in this notice, unless a longer retention period is required for legal, regulatory, contractual, audit, safety or quality reasons. If you ask to be removed from the volunteer database, SGS-NAM Cosmetics and Hygiene should deactivate or remove your profile, where permitted by law, while retaining records that must be kept for legitimate compliance, study integrity, safety or dispute management purposes.

8. Security

Access to personal information should be limited to authorized users based on role and need to know.
Sensitive information should be protected through technical and organizational safeguards such as authentication, access management, encryption where appropriate, audit trails, secure hosting, backup controls, staff training and incident response procedures.
No system can be guaranteed to be completely secure. Participants should use strong account credentials and notify SGS NAM Cosmetics and Hygiene if they suspect unauthorized access to their account.

9. Your choices and rights

You may choose not to register or not to answer certain optional questions. However, some information may be required to create an account, assess eligibility, protect safety, or participate in a specific study.
You may opt out of study opportunity communications or ask to be removed from the volunteer database, subject to any records SGS NAM Cosmetics and Hygiene is required or permitted to retain.
Depending on applicable law, you may have rights to access, correct, delete, restrict, object to, or receive a copy of your personal information.
Where processing is based on consent, you may withdraw consent at any time. Withdrawal will not affect processing that occurred before withdrawal or processing that SGS NAM Cosmetics and Hygiene must continue for legal, regulatory, safety or quality reasons.
Where HIPAA applies, you may have rights regarding protected health information, including access and amendment rights.

10. Contact

For questions about the volunteer database, participation, privacy rights, or removal from the database, contact SGS NAM Cosmetics and Hygiene using the contact details displayed on the registration platform or in the study specific documents provided to you.

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