KitVerify UK
UK PRIVACY NOTICE FOR Impala Kit Verify App
Last Updated 18 February 2025
INTRODUCTION
This Privacy Notice describes the practices of Pfizer Inc. (“Pfizer” or “we”) in connection with the data collected through the Kit verify App (the “App”).
The App is intended to help clinical site personnel (“you” or “the user”) manage the clinical trials, inventory and trial participants use of the Pfizer Internal Interactive Response Technology (IRT) system. The App’s functionality is designed to assist clinical site personnel with validation of the appropriate container assigned by the IRT system prior to dispensing. The App also confirms the dispensing of the appropriate container to the correct participant.
PERSONAL DATA
We do not require any login data for this App, so we don’t collect information about you, that can identify you either directly or indirectly (“Personal Data”) from you, third parties (others) or through the App.
However, when you scan the QR Code the Subject ID of the participant to whom the container is assigned to will be displayed and read directly from the QR Code. This information is not retained, but is only temporarily stored and is destroyed after each session.
In addition we collect “Nonpersonal Data” when you use the App, including:
- protocol numbers, site IDs, lot numbers, container numbers, bar codes
- Scans of the drug assignment confirmation report
HOW WE USE THE INFORMATION YOU PROVIDE
We use Personal Data to:
Facilitate the correct drug assignment to study participant for you
We use Nonpersonal Data to:
- Provide the App’s functionality, operate our business and fulfill your requests including
- To manage the App’s operation, facilitate access to and use of the App or provide service.
- To complete the dispensing transaction
- Operate our business to comply with our legal obligations and to meet our legitimate interests in maintaining our business, including (where appropriate on an aggregated level):
- To conduct data analysis to improve the user experience.
- To identify usage trends in the use of our App.
- To develop new products and services.
- To enhance, improve, or modify our services.
- To operate and expand our business activities.
HOW WE DISCLOSE THE INFORMATION YOU PROVIDE
We disclose Nonpersonal Data as follows:
- To our third-party service providers, to provide services such as data analysis, related infrastructure provision and for the management of user events.
DATA COLLECTED AUTOMATICALLY AND AGGREGATED
We use tracking technologies like a Session ID so that we can understand how the App is used, optimise user engagement with the App and customize and enhance your experience. We may also use the data collected to deliver personalised services to you. These technologies collect certain data automatically, such as:
- Data about your device, such as your screen resolution, operating system, device manufacturer and model, language, and browser type. We use this data to ensure that the App functions properly.
- Data about your use of the App, including content viewed, features used and the dates and times of your interactions with the App. We use this data to understand how users engage with the App and to customise and improve the App experience.
INDIVIDUAL RIGHTS
You may stop all collection of data by the App by uninstalling the App.
You may have a right to lodge a complaint with a data protection authority competent for your habitual residence, place of work, or place of alleged infringement. Please click here for contact information for such authorities.
DATA SECURITY
We seek to use reasonable organisational, technical and administrative measures to protect your Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
RETENTION PERIOD
We will retain your Non-Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Notice. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the App to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the App Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).
CROSS-BORDER TRANSFER
The data we collect through the App may be stored and processed in any country where we have facilities or in which we engage service providers, including in the United States and where our affiliates operate.
Some non-European Economic Area (“EEA”)/UK countries are recognised by the European Commission and the UK government as providing an adequate level of data protection according to EEA and UK standards (the full list of these countries is available here. For transfers from the EEA/UK to countries not considered adequate by the European Commission and/or the UK government, we have put in place adequate measures, such as by ensuring that the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data. You may obtain a copy of these measures by visiting https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.
UPDATES
From time to time, we will update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice in the App. This Privacy Notice was last updated as of the “Last Updated” date shown above.
CONTACT US
The company responsible for collection, use, and disclosure of your Personal Data under this Privacy Notice is
Pfizer Inc.
Privacy Officer
66 Hudson Boulevard East
New York, NY 10001-2192 USA
If you have questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please contact us at privacy.officer@pfizer.com.
You may also contact our data protection officer responsible for your country or region, if applicable. To find their contact information, visit DPO.Pfizer.com.