Effective Date: July 9, 2025

 

ICE Global Consulting, Inc. (“ICE Global Consulting,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information in accordance with applicable data protection and clinical research standards. This Privacy Notice describes how we collect, use, disclose, and safeguard information when you visit our website www.iceglobalconsulting.com, contact us, or engage with our services.

 

This policy applies to all data processed in the course of our business activities, including services provided to clinical research sponsors, contract research organizations (CROs), trial sites, and vendors.

 

Scope of this Notice

This Privacy Notice applies to:

• Website visitors and business contacts
• Clients and service providers
• Clinical trial site personnel and related third parties

 

ICE Global Consulting does not directly collect or process identifiable personal data of clinical trial participants. However, in the course of providing financial and administrative services, we may receive limited coded information, such as unique patient identifiers, to align payments with procedures completed at clinical trial sites.

Clinical Trial Data and Pseudonymized Identifiers

While ICE Global Consulting supports financial management services related to clinical trials, we do not receive or process any directly identifying information (e.g., names, contact details, national IDs, medical records) of research participants.

 

We may receive pseudonymized data—such as site-assigned subject numbers or protocol-specific patient codes—for the following limited purposes:

• Verifying clinical procedures completed at research sites
• Facilitating compensation or reimbursement to sites in accordance with contracts
• Supporting Sponsor-directed payment and reporting obligations

 

ICE Global Consulting is unable to identify any individual participant based on the limited coded data we process. We do not receive the key that links coded identifiers to participant identities, and we do not attempt re-identification.

Information We Collect

Depending on your interaction with us, we may collect:

• Contact Information: Name, email address, phone number, and professional title (only if voluntarily provided)
• Business Communication Data: Information exchanged during service delivery, contracting, and customer service
• Website Usage Data: Anonymous interaction data (e.g., browser type, page views) via cookies or Google Analytics
• Clinical Trial Payment Data (pseudonymized): Limited subject identifiers (e.g., patient codes), trial procedure codes, and visit information tied to payment processing

Legal Basis for Processing

We process personal and pseudonymized data under the following legal bases, as applicable:

• Contractual necessity (e.g., executing service agreements with Sponsors or CROs)
• Legitimate interests (e.g., financial and operational management)
• Legal obligations (e.g., regulatory compliance or audits)
• Consent, where required under local law

How We Use Your Information

We use the data we collect to:

• Respond to website inquiries and correspondence
• Deliver contracted services to clients
• Support trial site compensation processes using coded subject data
• Comply with contractual, regulatory, and audit obligations
• Maintain internal records, reporting, and reconciliation documentation

 

We do not use coded trial subject identifiers for marketing, profiling, or decision-making about individuals.

Data Security

We maintain appropriate technical and organizational safeguards to protect personal and pseudonymized information, including:

• Role-based access restrictions
• Secure data transfer and storage protocols
• Vendor and subcontractor confidentiality obligations
• Training for personnel on handling sensitive data
• Documented incident response procedures

Data Retention

We retain data only as long as necessary for the purposes for which it was collected or as required by applicable laws, including:

• Clinical trial documentation retention periods
• Tax, audit, and contractual requirements
• Statutory obligations in relevant jurisdictions

 

When no longer required, data is securely deleted, anonymized, or returned to the client.

Your Rights

Depending on your jurisdiction, you may have rights under applicable law, including the right to:

• Request access to your personal data
• Request correction or deletion of your data
• Object to or restrict processing
• Request data portability

 

To exercise your rights, please contact us at: [email protected].
We will work with our clients and applicable data controllers to respond appropriately, especially where we act as a processor of coded clinical data.

Third-Party Links

Our website may contain links to third-party websites. This Privacy Notice does not apply to those websites. Please consult their privacy policies before submitting any information.

Children’s Privacy

Our website and services are not intended for individuals under 13 years of age, and we do not knowingly collect personal information from minors.

Changes to This Notice

We may update this Privacy Notice periodically in response to legal, technical, or operational changes. Updates will be posted to our website with a revised effective date.

Contact Us

If you have questions about this Privacy Notice or our data handling practices, please contact: [email protected]

 

If you are a clinical trial participant, we encourage you to direct inquiries about your data to the trial sponsor or site, as ICE Global Consulting is not able to identify or access your personal information.

California Privacy Rights (CCPA)

While we receive coded subject identifiers (e.g., patient codes) related to trial procedures for payment processing purposes, we do not collect directly identifiable personal information about clinical trial participants as defined under the CCPA.

 

This section applies only to California residents and supplements the general Privacy Notice in accordance with the California Consumer Privacy Act (CCPA).

 

Information Collected in the Past 12 Months

Category	Examples	Collected
Identifiers	Name, email address, IP address	NO
Internet Activity	Interaction with our website	YES
Geolocation	General location (City/State)	YES

 

We do not sell or share personal data. We have not disclosed any personal information for a business purpose in the past 12 months.

CCPA Rights

California residents have the right to:

• Know what personal information we collect and how we use it
• Request deletion of personal information
• Request access or data portability
• Not be discriminated against for exercising privacy rights

 

To exercise your CCPA rights, email us at: [email protected]

 

We will respond within 45 days (or provide notice of an extension if needed). Requests must be verifiable and made by you or an authorized agent.