Last Updated: November 15, 2023

Privacy Commitment

This Privacy Policy applies to all websites developed, maintained and operated by TEUTEBERG, INCORPORATED. TEUTEBERG, INCORPORATED is an innovative marketing services company. We work closely with our clients to foster a relationship that will bring about success be it by creating a full marketing strategy, to direct mail and fulfillment, to digital marketing, to custom data analytics. You are responsible for carefully reading this Privacy Policy in its entirety. This Privacy Policy describes the information we collect about you and how we keep your personal information safe and confidential.

TEUTEBERG, INCORPORATED understands that privacy is important to you. The information that we collect about you from our websites will be maintained and used in accordance with this Privacy Policy and applicable laws, rules and regulations. By accessing our websites, you agree to the terms and conditions set forth herein. If you do not agree to any of the terms or conditions in this Privacy Policy, please do not access or use any part of our websites.

By providing us with your Personally Identifiable Information (as defined below), including Personal Health Information (as defined below), you consent to the collection and use of any information you provide in accordance with this Privacy Policy.

TEUTEBERG, INCORPORATED may share information among its subsidiaries and third parties working with or on behalf of TEUTEBERG, INCORPORATED, and TEUTEBERG, INCORPORATED makes commercially reasonable efforts to ensure such information is protected in accordance with the terms of this Privacy Policy.
TEUTEBERG, INCORPORATED is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Information We Collect

We will collect information through the use of Cookies (as defined below), Web Logs (as defined below), or IP Address (as defined below). We will only collect Personally Identifiable Information (as defined below) including Personal Health Information (as defined below) if you voluntarily provide such information to us.

Cookies

We collect non-identifiable web usage data about your use of our website through the use of Cookies. A Cookie is a small piece of information that our server sends to your web browser when you access our websites. Every computer that accesses our websites is assigned a different Cookie by TEUTEBERG, INCORPORATED. Cookies are capable of storing many types of non-identifiable data. Cookies may be used to help us analyze usage of our websites or to restrict underage use of the website. We do not link basic data from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store Personal Health Information about you.

Most browser software can be set to reject all Cookies. Note, however, that some portions of our websites may not work properly if you reject Cookies.

IP Addresses
We may also receive IP addresses in the normal course of the operation of our websites. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

 

Web Logs

TEUTEBERG, INCORPORATED uses standard Web Logs that record basic data about your visit to our websites, such as the date and time of the visit, the pages viewed during the visit and the domain name of your Internet service provider.

We do not normally seek to identify individuals from Web Logs. However, we may use Web Logs to identify an individual whom we suspect tried to damage our websites or use them in an unauthorized way. We may share our Web Logs with law enforcement agencies if we believe there has been a violation of computer security or related laws or as otherwise required in order to comply with applicable law or legal process. In addition, we may share our Web Logs (which do not contain any Personally Identifiable Information) with our partners to assist them in better designing their websites for clinical research studies.

Google Analytics

Our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) which uses cookies to help analyze how users use the sites. The information generated by the cookies about your use of the websites (including your IP address) will be transmitted to and stored by Google on TEUTEBERG, INCORPORATED’s behalf under Google’s privacy policy, which you can access here: https://support.google.com/analytics/answer/6004245?p=privpol_data&hl=en&visit_id=637713885417185895-846539400&rd=1#zippy= You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our websites. By using our websites, you consent to the processing of your information by Google in the manner and for the purposes set out above.

Collection, Use and Disclosure of Personally Identifiable Information and Personal Health Information

Personally Identifiable Information that may be collected via a clinical research study survey or marketing campaign is information that can be traced back to an individual. Personal Health Information is a combination of your Personally Identifiable Information with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your name, it becomes Personal Health Information. Examples of Personally Identifiable Information include your name, home address, telephone number, email address, date of birth, and any other information that may be used to identify you.

You may voluntarily provide Personally Identifiable Information and/or Personal Health Information in a variety of circumstances, and if you choose to do so, you consent to our collection and use of such information as described in this Privacy Policy. For example, we may collect Personally Identifiable Information, including your name, company affiliation, telephone number and email address, when you provide such information to submit an inquiry to us on the “Contact Us” portion of our website. We will use such information to respond to your inquiry. We may also use the Personally Identifiable Information and Personal Health Information that you provide to determine if you may be eligible for research study participation or marketing campaign. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to TEUTEBERG, INCORPORATED. Inaccurate information will affect our ability to properly determine if you may qualify to participate in a research study or marketing campaign.

While you may view some of our study websites or marketing campaign websites without providing Personally Identifiable Information, this information will be required to be considered for participation in a research study and/or marketing campaign.

We will not use or disclose Personally Identifiable Information or Personal Health Information of users of our clinical research study websites and/or marketing campaigns for any purpose other than those described in this Privacy Policy. If these purposes change at any time, we will update the privacy policy on our websites. We use and disclose Personally Identifiable Information and Personal Health Information obtained from users in the following ways:

• COMMUNICATION WITH REGARD TO STUDY REFERRAL PRE-QUALIFICATION AND/OR OTHER STUDY-RELATED PURPOSES
  Personally Identifiable Information will be used by TEUTEBERG, INCORPORATED to follow-up with the clinical study site about your pre-qualification for and participation in the study and may be shared with the clinical study site for its assessment of your qualification for and participation in a study.
• COMMUNICATION WITH REGARD TO MARKETING CAMPAIGNS AND/OR OTHER MARKETING CAMPAIGN RELATED PURPOSES
  Personally Identifiable Information will be used by TEUTEBERG, INCORPORATED to follow-up with the marketing campaign about your pre-qualification for and participation in the marketing campaign.
• AGENTS AND SERVICE PROVIDERS SUPPORTING STUDY EFFORTS and MARKETING CAMPAIGN EFFORTS.
  We sometimes employ web hosting companies to maintain our clinical study websites and/or marketing campaigns and data collected through those websites on our behalf in support of our study recruitment efforts. We may share your personal information, such as your name, disease or condition, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information, with these hosting companies so that they may perform such web hosting services for us.  With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.

We may also be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, in response to a search warrant, subpoena, court order, or other valid legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or be inconsistent with our legal obligations.

We may also disclose Personally Identifiable Information and Personal Health Information in any of the following circumstances, in each case as permitted by applicable laws and regulations: (a) to protect our legal rights or the rights of users of our websites, (b) to protect the security or integrity of our websites, (c) to take precautions against liability, (d) to enforce this Privacy Policy, (e) if TEUTEBERG, INCORPORATED undergoes any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, (f) to detect, prevent, or otherwise address fraud, (g) pursuant to your explicit approval, or (h) during emergencies if physical safety is believed to be at risk.

Aggregate Data

We will combine the information you provide with information from other visitors to our websites to create Aggregate Data which does not contain any uniquely identifying information. We will share this Aggregate Data with the sponsors of our websites, and/or their consultants. We will periodically analyze this Aggregate Data and use what we learn to make improvements to our websites. We may also share this Aggregate Data with our partners to assist them in better designing their websites.

Children’s Privacy

We are committed to protecting the privacy of children. Neither TEUTEBERG, INCORPORATED, nor any of its websites or services, are designed or intended to attract children under the age of 13. We do not collect, solicit, or use Personally Identifiable Information from any person we actually know is under the age of 13.  If we learn that we collected Personally Identifiable Information from any child under the age of 13, we will endeavor to delete that information as soon as possible.  Please contact TEUTEBERG, INCORPORATED at info@teuteberg.com or phone number (414)-257-4110 if you have reason to suspect that we have collected Personally Identifiable Information of any child under the age of 13.

Data Security

We maintain generally accepted industry standard technical, physical, and organizational procedures to safeguard Personally Identifiable Information and Personal Health Information against unauthorized or unlawful processing and against accidental loss, alteration, disclosure and access.  Please note, however, that there are inherent risks in transmission of information over the Internet and electronic storage of information, and we cannot guarantee that unauthorized access or use of your Personally Identifiable Information or Personal Health Information will never occur.

Links to Other Websites

Our websites may contain links to other websites which are not operated or controlled by TEUTEBERG, INCORPORATED. Please keep in mind when you access websites operated by other parties, whether through links on our website or otherwise, that we do not control what happens on those websites. You should always check the privacy policy of the website you are visiting in order to be sure you know how the operator of that website will collect information from you and what the operator of that website will do with the information.

Internet Transmission Risks

We acknowledge that no internet transmission is ever 100% secure or error free. It is your responsibility to ensure that the computer or device you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer or other device, there is a risk that the information you provide could be disclosed to unauthorized third parties. Similarly, despite TEUTEBERG, INCORPORATED’s efforts to protect your Personally Identifiable Information and Personal Health Information, as noted above, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.

Rights to Access, Amend, and Delete Information

TEUTEBERG, INCORPORATED acknowledges under certain laws and regulations, individuals have rights to access, amend and/or delete their Personally Identifiable Information. To the extent such laws or regulations apply to TEUTEBERG, INCORPORATED, you may submit requests to us for access to, amendment of and/or deletion of your Personally Identifiable Information. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe and as required by applicable laws and regulations.

Changes to this Privacy Policy

As privacy laws and regulations evolve, as our business operations change or in other circumstances where we deem it necessary, we may revise or update our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Last Updated” date of this policy. Your use of our websites constitutes your acceptance of the terms of the Privacy Policy then in effect, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms.

Retention of Personally Identifiable Information and Personal Health Information

We will only maintain Personally Identifiable Information and Personal Health Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it was collected or processed. We will delete Personally Identifiable Information and Personal Health Information when such time period has ended.

International Transfers

We may transfer Personally Identifiable Information and/or Personal Health Information about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws and regulations. Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country. Accordingly, with respect to an international transfer, your Personally Identifiable Information or Personal Health Information may be subject to different protections depending on the laws and regulations of the country to which such information is transferred. In all cases, we will seek to apply reasonable safeguards to protect Personally Identifiable Information and Personal Health Information which we transfer internationally.

The EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF)

TEUTEBERG, INCORPORATED complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. TEUTEBERG, INCORPORATED] has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. TEUTEBERG, INCORPORATED has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the DPF Principles, TEUTEBERG INCORPORATED attests to the following:

• We are subject to the oversight and enforcement authority of the United States Federal Trade Commission.
• We acknowledge the right of EU, UK, and Swiss individuals to access their personal data that has been transferred to the United States and to amend or correct outdated or inaccurate information. Furthermore, said individuals have the right to erasure of personal data that has been handled in violation of the DPF Principles. Individuals wishing to exercise any of these rights may do so by contacting TEUTEBERG, INCORPORATED by utilizing the contact information below.
• We may be required to release personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
• We remain liable for the transfer of EU, UK, and/or Swiss personal data to third parties acting as our agents unless we can prove we were not a party to the event giving rise to the damages.

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), TEUTEBERG, INCORPORATED commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact TEUTEBERG, INCORPORATED at:

TEUTEBERG, INCORPORATED
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI  53222
info@teuteberg.com

TEUTEBERG, INCORPORATED has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf 

For Individuals in the European Union and United Kingdom

In some situations, TEUTEBERG, INCORPORATED acts as a data “processor” that processes personal data on behalf of clinical trial sponsors and/or consumer marketing organizations. Pursuant to the European Union’s General Data Protection Regulation and the United Kingdom’s General Data Protection Regulation (collectively, the “GDPR”), if you are interested, we may request that you opt-in/consent to our collection and processing of your personal data for purposes of recruitment for the relevant research study or marketing campaign website. These opt-in requests will be presented as check boxes under which you will have the opportunity to affirmatively indicate your consent to the processing of your personal data as described in this privacy policy and/or as described on our clinical research study or marketing campaign website (as applicable).

Under the GDPR your rights are as follows.

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• the right not to be subject to automated decision-making including profiling.

These rights are described further, as required by the GDPR, on our clinical research study websites or marketing campaign websites.

You also have the right to complain to a supervisory authority in the EU Member State in which you are located if you feel there is a problem with the way your personal data is handled. You can find a list of supervisory authorities here: http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm. If you are located in the UK, you may complain to the Information Commissioner’s Office using the following link: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/.

California Privacy

Introduction

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to individuals who reside in the State of California (“CA Consumers”). Below is a description of TEUTEBERG, INCORPORATED’s (“Teuteberg’s”) practices regarding the collection, use and disclosure of personal information about CA Consumers and CA Consumers’ rights relating to their personal information.

Please be aware that Teuteberg does not sell (and does not have any actual knowledge that it sells) personal information about any CA Consumers, including but not limited to any information about minors under 16 years of age.

Details about Teuteberg’s Collection of CA Consumers’ Personal Information

The chart below describes the categories of CA Consumers’ personal information Teuteberg has collected in the last 12 months, categories of sources from which that information was collected and the business or commercial purpose for which the information was collected:

Category of personal information Teuteberg has collected	Category of source from which information was collected	Business/commercial purpose for which information was collected
Identifiers (e.g., name, date of birth, email address, postal address and similar identifiers)	Universities; casinos; Membership & Associations; Direct-Marketers, and Non-profits	For Teuteberg’s provision of marketing services
Education information (e.g. information relating to students maintained by a university)	Universities	For Teuteberg’s provision of marketing services
Financial information (e.g., information concerning financial donations)	Universities; casinos; and Non-profits.	For Teuteberg’s provision of marketing services
Commercial information (e.g. information about consumer histories)	Universities; casinos; Membership & Associations; Direct-Marketers, and Non-profits	For Teuteberg’s provision of marketing services

Details about Teuteberg’s Disclosures of CA Consumers’ Personal Information

The following chart describes the categories of CA Consumers’ personal information that Teuteberg has disclosed to third parties for a business purpose and corresponding categories of third parties to whom the information was disclosed in the last 12 months:

Category of personal information that Teuteberg has disclosed	Category of third party to whom personal information was disclosed
Identifiers, education information, financial information and commercial information	Secure cloud storage service provider
Identifiers	Email marketing service provider

CA Consumers’ Rights

CA Consumers have the right to request that Teuteberg disclose what personal information it collects, uses, discloses and sells. Specifically, a CA Consumer may request details concerning any or all of the following: (i) specific pieces of personal information that Teuteberg has collected about the CA Consumer; (ii) categories of personal information Teuteberg has collected about the CA Consumer; (iii) categories of sources from which the personal information is collected; (iv) categories of personal information about the CA Consumer that Teuteberg sold or disclosed for a business purpose; (v) categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (vi) the business or commercial purpose for collecting or selling personal information. To make any of these requests, please either click on the following link: www.teuteberg.com/access-request, or call 800-222-6759. Once Teuteberg receives your request, it will need to verify that you are the person about whom Teuteberg has collected personal information. Depending on the type of request you make, Teuteberg may require you to provide additional information about yourself as part of this verification process; Teuteberg will inform you of the specific information it requires (if any) to verify your identity after it receives your request.

CA Consumers have the right to request the deletion of their personal information which is collected or maintained by Teuteberg. To make a deletion request, please either click on the following link: www.teuteberg.com/deletion-request, or call 800-222-6759. Once Teuteberg receives your request, as described above Teuteberg will verify that you are the person about whom Teuteberg has collected personal information. Please be aware that there are certain exceptions to the right of deletion of personal information. Teuteberg will inform you if there is any such exception when responding to your request.

CA Consumers also have the right to not receive discriminatory treatment for the exercise of privacy rights under the CCPA. Teuteberg will not discriminate against any CA Consumer for his/her exercise of those rights.

A CA Consumer may use an authorized agent (which may be another person or a business entity registered with the CA Secretary of State) to submit any of the requests described above on the CA Consumer’s behalf. The authorized agent should follow processes specified above for submitting such requests. When a CA Consumer uses an agent to submit a request, Teuteberg may require the CA Consumer to provide the agent with signed permission to submit such request and may also require the CA Consumer to verify his/her own identity directly with Teuteberg. Teuteberg may deny a request from an agent if the CA Consumer does not submit proof to Teuteberg that the agent has been authorized by the CA Consumer to act on the CA Consumer’s behalf.

Questions about California Privacy

CA Consumers may contact Teuteberg with questions or concerns about Teuteberg’s privacy policies or practices. Please see the section below (“Privacy Contact Information”) for Teuteberg’s contact information.

Privacy Contact Information

Questions or comments regarding this Privacy Policy or our practices should be submitted to:

TEUTEBERG, INCORPORATED
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI  53222
info@teuteberg.com