Privacy Policy
Last Updated: May9, 2023
GS Capsule is committed to protecting individual privacy and maintaining trust with our business clients
(“Clients”), and others who use or interact with our website (collectively, “End Users”). This Privacy
Policy (“Policy”) describes how we collect and use Personal Information (defined below) across our website –
www.GS Capsule.com (the “Site”), and as part of our services (“Services”). This Policy does not apply to
Personal Information we collect offline, or to our collection of applicant and employee Personal
Information, all of which may be governed by separate privacy policies.
Note that if you are a participant in a clinical study managed by one of our Clients we do not receive your
Personal Information from our Client. Therefore, if you have questions or requests regarding your Personal
Information you should direct these to the Client in whose study you are participating.
Table of Contents
1. Information We Collect
2. How We Use Information
3. How We Disclose Information
4. Our Use of Cookies
5. Do Not Track
6. Information Regarding Children
7. Your Privacy Rights
8. Legal Disclaimers
9. Links
10.Updates to This Policy
11.Contact Us
12.Additional Information for California Residents
13.Additional Information for Individuals Located in the European Economic Area (EEA) and United Kingdom
(UK)
1.Information We Collect
We collect information that identifies, describes, or is reasonably capable of being associated with an
individual (“Personal Information”). Personal Information does not include publicly available information
from government records, deidentified information, or aggregated information. We collect and use different
types of Personal Information for various reasons depending on how End Users interact with us and use our
Site or Services. The following describes the types of Personal Information we collect.
Personal Information We Collect Directly From End Users
We may collect Personal Information directly from End Users who interact with our Site. The Personal
Information we collect through our Site includes:
Contact Information. We collect information such as End Users’ first and last name, email, phone number, fax
number, employer, city, country, referral source, and areas of interest.
Message Contents. If an End User sends us messages through our Site of via email, we also collect message
contents, including responses to open ended or multiple-choice questions, and any other information End
Users may choose to provide.
Personal Information Collected Passively or Automatically
We may automatically collect the following Personal Information from or about End Users who visit our Site:
Device Identifiers. When an End Users visit our Site, we may automatically collect information such as IP
address, unique device identifiers, operating system, and other information related to the device used to
interact with our Clients via the GS Capsule Platform.
Network and Activity Information. We may collect information related to how End Users interact with our
Site, such as referring and exit web pages and URLs, browsing history, and other similar information. As
described below in the “Our Use of Cookies” section, we may use analytics providers and technologies,
including cookies and similar tools, to collect this information.
To the extent permitted by applicable law, we may combine this information with other information we
collect, including End Users’ Personal Information.
2.How We Use Information
We may use the Personal Information we collect for the following purposes:
Operate Our Business. We use Personal Information we collect via the Site to communicate with End Users,
send newsletters, respond to inquiries regarding our Services, and to otherwise run our day-to-day
operations. When we collect Personal Information from End Users as part of their use of our Services, we use
the Personal Information to ensure our development and manufacturing operations align with Client
expectations and requests.
Conduct Surveys. We use Personal Information we collect to conduct surveys, such as customer satisfaction
surveys and market surveys.
Augment Existing Information. We may use Personal Information to obtain additional information from our
vendors or other third parties.
Evaluate and Improve Our Site and Services. We may use the Personal Information we collect to evaluate and
improve our Site and improve how we communicate regarding our Services.
Security Purposes. We may use Personal Information to mitigate fraud and protect GS Capsule.
Legal Requirements. We may use Personal Information to comply with lawful court orders, law enforcement
requests, or other legal requirements.
Other Operational Purposes. We may use Personal Information for purposes not provided for in this Policy, but
if we do, we will notify the End User (and, if necessary, obtain consent) before using the Personal
Information in that way.
3.How We Disclose Information
We may disclose End Users’ Personal Information with the following parties:
Service Providers. We disclose information we collect from End Users to service providers, vendors,
contractors, or agents who perform functions on our behalf. This includes entities that host the GS Capsule
Site, provide marketing and direct mailing services on our behalf, assist with our research, development,
and manufacturing activities on our Clients’ behalf, and assist us in performing other duties necessary to
delivering our Site and Services.
Client and Business Partners. We disclose information we collect to our Clients and business partners as
necessary to deliver our Services.
Affiliates. We disclose the information we collect to our affiliates or subsidiaries.
We also may disclose End User Personal Information in the following circumstances:
At an End User’s Request. We may disclose information to others when requested, explicitly or implicitly, by
an End User.
Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by
another company, or (ii) if any of our shares or assets are or may be transferred to another company,
whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we
have collected from End Users to the other company. As part of the business transfer process, we may share
certain Personal Information with lenders, auditors, and advisors, including attorneys and consultants.
In Response to Legal Process. We disclose Personal Information to comply with the law, a judicial
proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others. We disclose Personal Information when we believe it is appropriate to do so to
investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving
potential threats to the safety of any person, violations of our terms of use or this Policy, or as evidence
in litigation in which we are involved.
With an End User’s Permission. We may disclose Personal Information in ways not described above. If we do
so, we will notify End Users, and if necessary, obtain consent.
4.Our Use of Cookies
We use cookies, tags, and similar tracking technologies (“Cookies”) on our Site to provide, customize,
evaluate, and improve our services. A Cookie is a small piece of text that is placed on your device’s
browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies
of our service providers and partners. Some Cookies are only stored temporarily and are destroyed each time
you close your web browser. We also use persistent Cookies, which do not delete when you close your browser
and may collect and store data for a set period of time after leaving our platform.
How We Use Cookies
We use Cookies for the following purposes:
Performance and Analytics. Cookies help us analyze how you interact with our Clients via the Site. These
Cookies enable us to monitor and improve our Site’s performance, our Services, and End User experiences.
How to Manage Cookies
If you wish to prevent cookies from tracking your activity on our Sites or visits across multiple websites,
you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete
cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from
accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete
cookies. Visitors to our Sites who disable cookies will be able to browse the Sites, but some features may
not function.
You can also control how participating third-party ad companies use the information that they collect about
your visits to our websites and use of our mobile applications, and those of third parties, in order to
display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information
and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices
(Digital Advertising Alliance).
You may also download the DAA AppChoices tool in order to help control interest-based advertising on apps on
your mobile device:https://youradchoices.com/appchoices
We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or
programs.
5.Do Not Track
Some web browsers and mobile operating systems offer a “Do Not Track” setting you can activate to signal
your preference not to have data about your online browsing activities monitored and collected. Currently,
Site does not recognize “Do-Not-Track” requests.
6.Information Regarding Children
We do not knowingly collect Personal Information from End Users under the age of thirteen (13) without
parental consent. If we become aware that we have collected information from a child under 13 years old
without parental consent, we will delete such information from our records. If you are a parent or legal
guardian and believe your child has given us information and you did not provide consent, please contact
using the information provided in the “Contact Us” section below.
7.Your Privacy Rights
Depending on where you are located, End Users may have certain rights regarding their Personal Information.
Please note these rights are generally exercisable against GS Capsule’s Clients and not against GS Capsule
because GS Capsule is acting as a service provider to our Clients.
End Users who have questions or concerns about the data handling practices of our Clients or who wish to
exercise privacy rights should contact the relevant Client directly. Where necessary, GS Capsule will assist
our Clients with an exercise of a privacy right by an End User.
Where GS Capsule collects End User Personal Information for its own purposes, End Users may have the right to
request the following:
Request Access. The right to request access to, and a copy of, Personal Information we have collected. This
may also include the right to know the categories of Personal Information collected, the sources from which
we have collected Personal Information, our business purposes, and the categories of third-parties to whom
we have disclosed Personal Information.
Right to Correct. The right to request we correct inaccurate Personal Information.
Right to Delete. Subject to certain conditions and exceptions, the right to request we delete Personal
Information.
Right to Opt-Out. The right to opt-out of our use of Personal Information for marketing and advertising
purposes.
If you would like to exercise your privacy rights, please contact us as described below.
Verification. Before we comply with your request, we may need to verify your identity. Please provide us with
your name, the email address with which you have communicated with us in the past, and, if applicable, the
name of the Client of vendor on whose behalf you interacted with us. In some cases, we may need to request
additional information to verify your identity. If we cannot verify your identity after a good faith
attempt, we may deny your request and will explain the basis for the denial.
8.Legal Disclaimers
Nothing in this Policy restricts our ability to:
Comply with federal, state, or local laws;
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state,
or local authorities;
Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith
believe may violate federal, state, or local law;
Exercise or defend legal claims;
Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible
for such activity;
Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other
transaction in which a third party assumes control of all or part of our business.
9.Links
Our Site may contain links to unaffiliated websites. Any access to and use of such linked websites is not
governed by this Policy, but instead is governed by the privacy policies of those websites. We are not
responsible for the information practices of such websites.
10.Updates to This Policy
This Policy is current as of the last updated date given above. We may change this Policy from time to time,
so please be sure to check back periodically. Where we make changes to this Policy that materially impact
the use of Personal Information we will attempt to notify End Users, such as via email or by placing a
notice on our homepage.
11.Contact Us
If you have questions about this Policy, our internal data handling practices, or would like to make a
complaint, please contact us at:
Email: gscapsule@GS Capsule.com
12.Additional Information for California Residents
This section of our Policy provides additional information about how we handle Personal Information of
California residents, as required under the California Consumer Privacy Act 2018, as amended by the
California Privacy Rights Act 2020 (the “CCPA”). In general, this section applies to employees of our
Clients and vendors who reside in California as well as any visitors to our Site from California.
Categories of Data We Collect, Disclose, and Sell
Categories of Personal Information Categories of Sources Do we disclose for a business purpose(s)? Do we
“sell” or “share”?
Name, Contact Information, and Other Identifiers: Identifiers such as a real name, address, unique personal
identifier, online identifier, Internet Protocol (IP) address, email address
From you directly.
From your employer.
YES NO
Usage Data: Internet or other electronic network activity information, including, but not limited to,
browsing history, clickstream data, search history,
From you directly.
YES NO
and information regarding a resident’s interaction with an internet website, application, or advertisement.
How We Use Personal Information
When we collect Personal Information from Client and vendor personnel, we use that Personal Information for
the following business or commercial purposes (and any directly related purposes):
for billing, collections, and payment purposes;
for security and safety when you visit our facilities;
to manage our technology resources (e.g., cyber-risk management, infrastructure management and business
continuity);
to detect and prevent fraud;
to protect and defend our rights or property, or the rights and property of others;
to perform corporate governance, training, and other internal functions;
for archiving and record-keeping;
in the event of corporate transactions such as a financing, merger, acquisition, takeover, amalgamation or
other disposal of assets or interests;
to investigate, enforce, and apply this Policy and to otherwise protect our own rights and interests, such
as to resolve any disputes or to respond to legal process;
to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations
and to respond to lawful requests, court orders, and legal process.
For our Clients, we process this Personal Information for the following additional purposes:
to provide you our Services, process your transactions, and fulfill your orders.
to maintain your account and otherwise run our day-to-day operations.
to conduct business with you, including to perform our contractual obligations to your employer or
principal;
to provide you and your employer with marketing materials about products, services, news, offers, promotions
and events which we think may be of interest to you;
to communicate with you and your employer, including to fulfill requests and orders, answer questions and
other requests from you, provide customer support, and communicate with you and your employer about business
opportunities;
to operate and expand our business activities and evaluate, develop, and improve the quality of our products
and services;
For our vendors, we process this Personal Information for the following additional purposes:
to manage our contracts with your employer or principal and receive products or services;
to ensure we are receiving products or services appropriately and on terms most beneficial to us;
for vendor management purposes, including vendor risk management;
Retention Of Personal Information
We retain the Personal Information we collect only as reasonably necessary for the purposes described in
this Policy, or otherwise disclosed to you at the time of collection. For example, we will retain certain
identifiers for as long as it is necessary to comply with our accounting and recordkeeping obligations, to
provide our Clients with Services, and for research, development, and safety purposes, plus an additional
period of time as necessary to protect, defend, or establish our rights, defend against potential claims,
and to comply with our legal obligations.
Deidentification Of Personal Information
Occasionally, we may deidentify Personal Information and use the deidentified information for our internal
purposes. We commit to maintaining and using this information in deidentified form and will not attempt to
reidentify the information except to determine whether our deidentification process is effective.
Additional Rights Regarding Personal Information
The CCPA provides California residents with specific rights regarding Personal Information. In addition to
the rights listed above under Your Privacy Rights, California residents may have the following rights:
Right to Opt-Out of Sale/Sharing of Personal Information. We do not currently engage in any activities that
would be considered “selling” or “sharing” Personal Information under the CCPA. Therefore, there is no need
to exercise this right.
Right to Limit the Use and Disclosure of Sensitive Personal Information.We do not collect any sensitive
Personal Information and therefore do not engage in uses of this type of information that would trigger this
right under the CCPA.
Right to Non-Discrimination.We will not discriminate against you in terms of price or service level for
exercising any rights described in this Policy.
You may exercise your rights by contacting us at market@gscapsule.com
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