Privacy Policy

1. Who we are

Arsuda Consulting Inc. ("Arsuda", "we", "us") operates this website and is responsible for the personal information described in this policy. We do business as Arsuda Clinical Research, a contracted physician site network for sponsor-funded clinical studies in Armenia and the United States, and Arsuda Consulting, which provides quality and operations consulting to research sites and site management organizations.

2. What this policy covers

This policy covers information collected through this website and through emails, calls and messages with sponsors, contract research organizations, investigators, partners and other business contacts.

It does not cover personal or health information about participants in clinical studies. That information is handled under each study's protocol, the participant's informed consent, the applicable data-protection and clinical research regulations, and the agreements between Arsuda, the investigator and the sponsor. Participants with questions about their study data should contact their study site or the contact named in their consent form.

3. Information we collect

Information you give us. When you email, call or message us, or send a synopsis, protocol, feasibility questionnaire or other material, we receive your name, contact details, job title and organization, and the content of your message and any attachments.

Information about investigators and site staff. For physicians and staff in our network, we hold professional details such as name, qualifications, appointments, certifications (for example, ICH-GCP training), research experience and contact details, as needed to manage the network and respond to feasibility requests.

Information collected automatically. When you visit the website, our hosting provider automatically records standard technical information: IP address, browser and device type, operating system, pages visited, referring page, and the date and time of each request.

We do not ask for, and ask you not to send, health information about any individual through this website or by email.

4. How we use information

We use personal information to:

• respond to inquiries and requests for site feasibility or consulting;
• assess, negotiate, enter into and perform agreements with sponsors, contract research organizations, investigators and clients;
• manage our investigator network and its qualifications;
• operate, secure and improve the website, and prevent misuse;
• keep business records and comply with legal, regulatory and audit obligations;
• establish, exercise or defend legal claims.

We do not use personal information for automated decision-making that has legal or similarly significant effects, and we do not use it for third-party advertising.

5. Legal bases (EEA, UK and similar laws)

Where the EU or UK General Data Protection Regulation or a similar law applies, we rely on:

• legitimate interests: responding to business inquiries, running and developing our business, and keeping the website secure, balanced against your rights;
• contract: steps taken at your request before entering into an agreement, and performing that agreement;
• consent: where we ask for it; you can withdraw consent at any time;
• legal obligation: record-keeping and regulatory requirements.

6. How we share information

We share personal information only as needed, with:

• service providers that act on our behalf, such as our website host and our email and file-storage providers, under contracts that require them to protect it and use it only for us;
• investigators and site staff in our network, when needed to assess or run a study you have asked us about, and only under a confidentiality agreement where one applies;
• sponsors and contract research organizations, limited to the professional details of investigators and staff needed for study feasibility, qualification and conduct;
• professional advisors, such as lawyers, auditors and accountants, under duties of confidentiality;
• authorities, regulators and ethics committees, when the law requires it, or to protect the rights, safety or property of Arsuda or others;
• a successor, if Arsuda is involved in a merger, acquisition or sale of assets, subject to this policy.

WhatsApp and LinkedIn. If you contact us through WhatsApp or visit our LinkedIn page, those services are operated by Meta and LinkedIn under their own privacy policies, and they receive information about your use of them.

Confidential sponsor material, such as protocols and synopses, is handled under the confidentiality agreement or contract in place with that sponsor.

7. International transfers

Arsuda operates in the United States and Armenia, and our service providers may process information in other countries. Where information is transferred from the European Economic Area, the United Kingdom or Switzerland to a country without an adequacy decision, we use recognized safeguards such as the European Commission's standard contractual clauses. You can ask us for a copy of the relevant safeguards.

8. How long we keep information

We keep personal information only as long as needed for the purpose it was collected for:

• general correspondence and inquiries that do not lead to an engagement: up to 3 years after our last contact;
• records connected to an agreement, an engagement or a clinical study: for the term of the agreement plus the retention period required by law, regulation or the agreement, which for clinical research records can be many years;
• website server logs: kept by our hosting provider for no more than 90 days, unless needed to investigate a security incident.

When information is no longer needed, we delete or anonymize it.

9. Your rights

Depending on where you live, you may have the right to:

• access the personal information we hold about you and receive a copy;
• correct inaccurate information;
• delete your information;
• restrict or object to our use of it, including use based on legitimate interests;
• receive it in a portable format;
• withdraw consent at any time, without affecting earlier use.

California residents have the right to know what personal information we collect, use and disclose; to delete and correct it; and not to be discriminated against for exercising these rights. We do not sell personal information, and we do not share it for cross-context behavioral advertising.

Residents of Armenia have the rights given by the Law of the Republic of Armenia on Protection of Personal Data.

To make a request, email info@arsuda.com. We will confirm your identity before acting and reply within 30 days, or within the period the applicable law sets. You may use an authorized agent where the law allows. If you are in the EEA or UK and are not satisfied with our response, you can complain to your local data-protection authority.

10. Cookies and similar technologies

This website does not use advertising or analytics cookies, and it does not track you across other websites. Its fonts are loaded from Google Fonts, a service operated by Google, which receives your IP address and basic browser information when a page loads; Google's own privacy policy applies to that information. If you pause the background animation, your browser stores that choice locally so the animation stays paused on other pages. It is not sent to us and is not used to identify or track you. If we add analytics or other tracking, we will update this policy first and, where the law requires it, ask for your consent.

11. Security

We use reasonable administrative, technical and physical safeguards appropriate to the information we hold, including access controls, encrypted connections and confidentiality obligations on staff and service providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your personal information, we will notify you and the relevant authorities where the law requires.

12. Children

This website is intended for business and professional users. It is not directed at children under 16, and we do not knowingly collect their personal information. If you believe a child has sent us personal information, contact us and we will delete it.

13. Changes to this policy

We may update this policy. The "Last updated" date at the top shows when it last changed. If we make a material change, we will highlight it on the website before it takes effect.

14. Contact

Questions or requests about this policy:

• Address: Arsuda Consulting Inc., 225 E Broadway, Suite B104, Glendale, CA 91205, United States
• Email: info@arsuda.com
• Phone: +1 (503) 500-0040