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Privacy Policy and Legal Notice

ABRITES Privacy Policy

This notice is effective as of 01 December 2017


Our Approach to Privacy

ABRITES LLC and all its affiliates (together “Abrites”) recognize that when we handle information about any individual, we must do so responsibly, with due care to individual privacy, complying with laws on data privacy and confidentiality.

This Global Privacy Policy (“Policy”) describes the main types of personal information we process within our organization, how that information is used and disclosed, and our commitments to the individuals whose information we handle. The Policy explains in general terms how we seek to comply with data privacy laws and regulations, including but not limited to Regulation (EU) 2016/679 (General Data Protection Regulation/GDPR).

ABRITES in its capacity of personal data controller, has enacted internal policies, procedures and training programs designed to support compliance with these laws and this Policy. Our policies, procedures and training programs are reviewed on a regular basis, and managed by a team of privacy professionals with senior executive oversight.


What Types of Personal Information Does ABRITES Handle and for What Purposes?

Consumers' Data

ABRITES collects, processes and analyzes consumers' data as follows: first name, family name, delivery address, address for VAT purposes (if any), phone number for contact, e-mail address.

ABRITES collects these data for the purposes of:

1. identifying the consumer;

2. sending the activation links by e-mail;

3. delivering devices via courier;

4. activation of/providing the service ordered;

5. warranty support;

6. performance of the obligations under the consumer’s contract;

7. for statistical purposes in order to improve the services offered;

8. when agreed, for sending information/offers abour our products/services by e-mail in compliance with the present Privacy Policy.

These categories of personal data are collected and processes in the consumers’ interest and after their explicit consent.

We do not collect any consumers' data like: age, date of birth, sex, bank accounts information, personal documents (number, date of issue, validity, copies), marital status, medical/health information, professional qualifications and/or any kind of other personal data. This would be in excess of the above mentioned purposes and we kindly ask you not to specify any such information before ABRITES. In case you specify personal information in excess, ABRITES will delete it immediately and no records will be kept.

Employee and Human Resource Data

ABRITES collects personal information from applicants to open positions within the company, including private contact details, professional qualifications and previous employment history to inform employment decisions. ABRITES conducts various background checks on applicants, including where law allows on criminal history and professional disbarment. Once employed, ABRITES collects information on staff for human resource, performance, payroll and tax purposes. ABRITES processes similar information relating to consultants contracted on a freelance basis, if any.

Web Visitors

ABRITES collects named information about visitors to company websites where this is voluntarily provided to meet a request from those individuals, for example where a client contact requests information on a company service, a health professional is interested in participating in a clinical trial or where someone wants to apply for a vacant position with the company. Through the use of cookie-based technologies, ABRITES may collect various data linked to virtual identities allocated to visitors when they access our websites. This data is used for various purposes, including site analytics and first party marketing (see Online Issues below). In certain cases, these virtual identities are linked to the real world identities of visitors when they provide their named information as described above. This allows ABRITES to tailor marketing messages to those individuals, inclusive of information that is likely to be of interest to them.

Internal and External Disclosures of Personal Information

Personal information will be shared within ABRITES, companies working as agents of ABRITES and third parties only on a “need to know” basis to meet stated legitimate business purposes. Access to databases and folders containing personal information is restricted to appropriate staff.

ABRITES does not trade or sell personal information.

Under some circumstances, ABRITES may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes.

ABRITES may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ABRITES’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.

Companies working as agents of ABRITES are required to sign “processor” and/or confidentiality agreements whereby they will commit to only process personal information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.

International Transfers of Personal Information

ABRITES is a global company serving an industry that is increasingly globalized in its approach to clinical research. Personal information will be shared across international borders as required to service global projects. ABRITES hosts personal information in databases in one location only - in its HQ in Bulgaria. In certain circumstances, ABRITES and client personal information will be hosted within vendor platforms located in the Internet cloud. ABRITES recognizes that many countries globally have regulations restricting the flow of personal information across international borders. ABRITES has put in place measures to ensure that adequate protection is provided to such data where legally mandated.

Notice and Consent

At the point of data collection, ABRITES will provide notice to individuals in a clear and conspicuous language about how their information will be processed, disclosed and transferred; what choices they have in relation to how their data are handled; what informational rights they have under data privacy law or under this Policy; and who to contact with any questions or complaints. These privacy notices are tailored to specific situations of data collection. In providing such notice, ABRITES meets its obligations to be transparent and fair with individuals as is required by data privacy laws. Dependent on the medium, notice may be given in person, by email, post, telephone, or by posting on our website.

In many situations, including where mandated by data privacy law, and also where it is a matter of good practice, ABRITES will seek consent of individuals to collect, use and disclose their data consistent with the relevant privacy notice. However, in certain cases where law allows, particularly where gaining consent will involve a disproportionate effort and the privacy risks are low, ABRITES will proceed to process personal information absent of consent. Also, ABRITES will use and disclose personal information without consent where required by law and judicial order.

Consistent with GDPR, laws on confidentiality and data privacy regulations, ABRITES will collect necessary informed consents of study subjects on behalf of its clients. ABRITES will suggest template consent language to its clients, including necessary content as dictated by local law.

Data Quality and Record Retention

In general, our privacy notices provide individuals easy means of validating, correcting errors and updating information. ABRITES retains personal information according to purpose and regulatory requirement, as directed by our corporate retention schedules.

Informational Rights

In jurisdictions with data privacy laws, and where contractual commitments require, ABRITES ensures that individuals can exercise all relevant informational rights with respect to their personal information processed by the company, including but not limited to the right of access and correction, to prevent direct marketing, block processing and erase data. In all other respects, where no overriding interest prevails, ABRITES will endeavor to allow the following informational rights under this Policy as a matter of good practice:

  • to allow access to copies of personal information within a reasonable timeframe;

  • to correct personal information where inaccurate;

  • to allow study investigators to opt out of future solicitations to participate in studies; and

  • to withdraw a previously provided consent to processing of personal information.

Study subjects must contact their investigator at site, who will be able to make the necessary link to subject identity.

Information Security

The company maintains a comprehensive information security policy that seeks to apply technical and organizational security measures that protect personal information against unauthorized access or loss. Consistent with regulatory requirements, ABRITES also maintains a detailed Security Breach Policy, which establishes a procedural response to dealing with any breach of personal information, including making any necessary notifications to individuals or governmental authorities.

Online Issues

ABRITES Web pages may contain links to websites outside of the company. Linked websites are not under the control of or endorsed by ABRITES. This Policy does not apply to linked websites outside the ABRITES organization. It is recommended that visitors review the privacy policy of each individually linked website.

A cookie is a data file that is placed by a website operator on the hard drive of a visitor to their site. Cookies with the following functions are enabled to the computers of visitors to ABRITES websites: to allow the site to deliver the service requested by the visitor; to remember repeat visitors; to improve the user experience of the site; to allow the company to perform site analytics; and to help tailor marketing messages to the visitor based on previous browsing. Company cookies are enabled and controlled by the ABRITES Web team, which is established on Bulgarian territory. The online relationship with ABRITES may be managed by using settings available on most internet browsers. For example, most browsers will allow a visitor to choose which cookies can be placed on his/her computer, to delete or disable cookies, and to set Do Not Track as a function. Please note that disabling cookies may prevent a visitor from using certain features on ABRITES websites.


Children's Online Privacy Protection

ABRITES does not collect information through our websites from individuals who are known to be under the age of 18, and no part of our online presence is directed to anyone less than 18 years.


Inquiries, Complaints and Requests to Exercise Rights

All communications, queries, requests to exercise informational rights (e.g., access to data) or complaints should be addressed to the attention of the Legal Counsel, ABRITES, 147 Cherni vrah Avenue, Sofia 1407, Bulgaria.


Legal Status of Policy and Policy Changes

Our Global Privacy Policy is not a contract, and it does not create any legal rights or obligations. ABRITES reserves the right to modify or amend this Policy. For instance, the Policy may need to change as new legislation is introduced or as it is amended. The updated Policy will be posted on We recommend that the Policy is reviewed from time to time.


Legal Notices


You are advised to review the information in this posting periodically. Current terms of the notices posted here are binding when you download any materials from this site, both now and in the future.

In the case of any violation of these conditions, Abrites Ltd. and all its affiliates (together "Abrites") reserves the right to seek all remedies available by law.

Printing or Copying of Website Information

All contents on this website are protected by copyright. Abrites invites you to print or copy materials from this website for non-commercial use within your organization. Copies of these materials must retain copyright and other proprietary notices in the same form as the originals. Other uses of the information are not authorized and use shall not confer by implication any license or right under any copyright, trademark or patent owned by Abrites or any third party.


Trademarks, logos and service marks (hereinafter referred to as marks) that appear on this website are the property of Abrites or other third parties. Readers are prohibited from using these marks without prior written consent of Abrites or any third party that may own the mark.


The information that appears on this website has been compiled in good faith by Abrites solely for the purpose of providing information about the company and the services/products that it offers. Abrites makes no commitment and disclaims any duty to have these materials updated at all times.


General Disclaimer

This website has been compiled in good faith by Abrites solely for the purpose of providing information about the company and the services/products that it offers. While the content of this website was believed to be accurate when prepared, Abrites disclaims responsibility for the completeness or accuracy of the information, text, graphics, links or any other material it contains. Mention of the products or services of other companies is for information purposes only and implies neither endorsement nor recommendation. In addition, Abrites makes no commitment and disclaims any duty to have these materials updated at all times. This publication and any references to services are provided "as is" without any implied term of any kind. Abrites also reserves the right to add, modify or delete any information at this website at any time.

Availability of Services

This website provides information on Abrites' international services. Please contact your local business development representative (if such) for information regarding services, since some Abrites services may not be available in your country.

Links to Third-Party Sites

Linked websites are not under the control of Abrites. Abrites does not endorse any website to which the Abrites website is linked and Abrites is not responsible for the content of any website linked to the Abrites website.

Access to Password-protected/Secure Areas

Access to and use of password-protected and/or secure areas of the Abrites website are limited to authorized users. Unauthorized individuals attempting to access password-protected or secure areas of the website may be subject to prosecution.