Privacy Policy

Updated: May 25, 2018

Blackfynn Inc. is strongly committed to protecting and respecting your privacy rights. The terms “Blackfynn,” “we,” “us,” or “our” includes Blackfynn Inc. and our affiliates and subsidiaries. This privacy policy (the “Privacy Policy”) explains our information collection and use practices of Blackfynn in connection with our online offerings made available to you through our website located at (the “Site”) and, if you are a Subscriber or User, use of our Data Management Platform or Application (the “Platform”).

Description of Users and Acceptence of Terms

This Privacy Policy applies to: 1) visitors to the Site who view publicly-available content we have posted on the Site (each a “Visitor”), and 2) any subscriber and/or User who has signed up to access and use our proprietary Platform (each a “Subscriber”).

  1. By visiting our Site, each Visitor is agreeing to the terms of this Privacy Policy and the accompanying Terms of Service.
  2. By signing up for, accessing, and/or using the Platform, each Subscriber and/or User is agreeing to the terms of this Privacy Policy and the accompanying Terms of Subscription Agreement (“TSA”) or Terms of Use.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use (when such term concerns Visitors or Users), or the TSA (when such term concerns Subscribers).

Information We Collect and/or Receive

Contact Information. In the course of operating the Site and the Platform and/or interacting with you, Blackfynn will collect (and/or receive) the following types of information.

When you contact us through the “Contact Us” page, or sign up to become a Subscriber and/or a User, you will be asked to provide certain information which may include first name, last name, e-mail address, job title, name of your organization, country, state/region and phone numbers (cell and/or landline, fax) (“Contact Information”). The Contact Information is used to provide the requested Platform service or information, and to contact subscribers and visitors for purposes of direct marketing of our current and future services.

Billing Information. In order to purchase a subscription to our Platform, you will be required to provide certain additional information which may include a credit card number, expiration date, billing zip code, activation code, and similar information (“Billing Information”). Billing Information is collected and processed by our third-party payment processor operating as our agent (See, Onward Transfers to Third Parties). Blackfynn does not directly obtain or process any Billing Information.

Data. In using the Platform, Subscribers and/or Users may provide us with Data (as defined in the TSA), Subject Data and/or Regulated Data (as defined in the Terms of Use) (collectively “Data”). We use the Data in accordance with the terms and conditions of the TSA and the Terms of Use. You agree to remove or anonymize all Sensitive Personal Information (as defined in the TSA) before transferring any Data to us. You agree not to upload and/or collaborate on, unless otherwise agreed to by us, Protected Health Information (“PHI”) Data as defined under the Health Insurance Portability and Accountability of 1996 Act as amended (“HIPAA”); Blackfynn disclaims all liability for such PHI. You are solely responsible for compliance with all applicable privacy laws and regulations (including the General Data Protection Regulation) in connection with providing us Data and your use of the Platform.

Other Information. In addition to the Contact Information and the Data, we may collect or receive the following information:

From Your Activity. In an ongoing effort to improve the Site and the Platform, we automatically collect certain information when Visitors visit the Site and when Subscribers and/or Users use the Platform. This information consists of IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site Visitors visit, and similar information concerning your use of the Site and the Platform (“Activity Information”).

From Cookies. We also collect Activity Information by using “cookie” technology. Cookies are small packets of data that a website stores on the hard drive of your computer or mobile device to “remember” information about your visit. We may use session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer/device until you delete them). If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Site and the Platform may not function properly. For more information on how we use cookies, please read our Cookie Policy.

Analytics. We use one or more third–party analytics services (such as Google Analytics) to evaluate your use of the Site and the Platform, compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Site you visit, number of links clicked while on the Site, search terms and other similar usage data), and analyze performance metrics. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Site and/or the Platform, you agree to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site or the Platform.

For Google Analytics, please visit:

Aggregate Data. In an ongoing effort to better understand our Subscribers, Users, the Site and the Platform, we may analyze your information in aggregate form to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Service, the Platform and the Site to current and prospective business partners and to other third parties for other lawful purposes.

Additional Uses. We also use Contact Information, Data (as set forth above) and other information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback regarding our Services, provide relevant content on our Site, and to communicate with you via email regarding our current and future Services. In addition we may also use information for which we have a legitimate interest, such as processing for research purposes (including marketing research), processing for historical, scientific or statistical purposes, enforcement of legal claims, fraud prevention, network and information security, direct marketing, and disclosure to affiliated organizations.

The Site and Platform may, from time to time, contain links to external websites. These other domains and websites are not controlled by us and Blackfynn does not endorse or make any representation about third party websites or services. Blackfynn encourages you to review the privacy and security policies of any externally linked websites that may be accessed through the Site or Platform. Blackfynn assumes no responsibility or liability for the information, collection and disclosure practices of any external websites that a user can access through the Site. Please check the privacy policies of these external websites before you submit any Personally Identifiable Information or other information to them.

Onward Transfer to Third Parties — Information We Share

Vendors and Service Providers. Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by Blackfynn. You may opt out of having your personal information transferred to any or all of our categories of agents by emailing the instructions to However doing so many limit or impair your ability to use the Site, the Platform and the Services. We will address your request in a timely manner.

Business Partners. Blackfynn may share information with our business partners, and affiliates for our and our affiliates’ internal purposes or to provide you with a product or service that you requested. Blackfynn may also provide information to business partners with whom we may jointly offer products or services. Blackfynn requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of information they maintain on our behalf and not to use it for any purpose other than the purpose for which Blackfynn provided them.

Displaying Contact Information, Data and other information via the Platform. The Contact Information, Data (including videos) and other information you submit, post or upload via the Site and/or the Platform may be shared with other Users and authorized parties (e.g., healthcare professionals engaged by clinical trial sponsors and/or others for clinical analyses, research, healthcare delivery and other purposes).

Marketing – Interest-Based Advertising and Third Party Marketing. Blackfynn may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Blackfynn related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” You may opt-out of interest based advertising at no cost by following the instructions in our Cookie Policy.

Disclosures to Protect Us or Others (e.g., as required by law and similar disclosures). We may access, preserve, and disclose your personal information and other information provided by you, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Blackfynn policies or contracts; (v) to collect amounts owed to Blackfynn; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Business Transfer. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, dissolution, receivership, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Opt-in to Certain Onward Transfers

We will not transfer your personal information to a third party acting as a controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.

We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. You may grant such consent by contacting us at In each instance, please allow us a reasonable time to process your response.

Your Choices

Unsubscribe. Should you choose to unsubscribe from any mailing lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Blackfynn communications.

Opt-out for Direct Marketing. In addition, you may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: To opt-out of interest-based advertising, please follow the instructions in our Cookie Policy. We will address your request in a timely manner.

Rights of Access, Rectification, Erasure and Restriction

We acknowledge the individual’s right to access their personal data. You may inquire as to whether Blackfynn is processing personal information about you, request access to personal information, and ask that we correct, amend or delete your personal information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to to request access to, receive (port), seek rectification, or request erasure of personal information held about you by Blackfynn. Please include your name, email address associated with your Subscriber or User account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Blackfynn makes good faith efforts to provide individuals with access to their personal information, there may be circumstances in which Blackfynn is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where it is commercially proprietary. If Blackfynn determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Blackfynn will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

International Data Transfers

You agree that all information, including personal information, collected or transmitted to Blackfynn may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your personal information may accessible to law enforcement or other authorities pursuant to a lawful request. Where required by law, international transfers of personal information will be supported by an adequacy mechanism.

Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy or to report a privacy issue, please contact us in one of the following ways:

  • Email:
  • Telephone: +1 (267) 455-0088
  • Postal mail: Blackfynn Inc., 121 South Broad Street, 5th Floor, Philadelphia, PA 19106

We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Blackfynn is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Blackfynn commits to seek to address any complaints about your privacy arising from our collection or use of your personal information in a manner consistent with EU-US Privacy Shield Principles. EU individuals with inquiries or complaints regarding this Privacy Policy should first contact Blackfynn at

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

How We Protect Your Information

Blackfynn takes reasonable and appropriate security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. You acknowledge that no internet transmission is 100% secure or error-free. In particular, e-mail sent to or from the Site and/or the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other electronic means. Where Blackfynn has given you a username and/or password which enables you to access certain parts of the Blackfynn Site or Platform, you are responsible for keeping such username and/or password confidential.

About Children

Blackfynn does not knowingly collect information from children under the age of 13 (and in certain jurisdictions under the age of 16) through the Site and/or the Platform. If you are under the age of 13 (or 16 in certain jurisdictions), please do not provide any information through the Site and/or the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any information on this Site or any other web site without their permission. If you have reason to believe that a child under the age of 13 (or 16 in certain jurisdicitions) has provided information to Blackfynn through the Site and/or the Platform, please contact us using the information in the Contact Us section of the Site, and we will endeavor to delete that information from our databases.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Blackfynn does not share personal information with third-parties for their own marketing purposes.

Blackfynn does not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.


This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any such changes on the Site as soon as they go into effect. If there are material changes to this Privacy Policy, Blackfynn will notify you by email or as otherwise required by law. By accessing the Site or the Platform after we make any such changes to this Privacy Policy and provide you with any required notice, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

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