Privacy Policy

1.0 OVERVIEW

1.1 PURPOSE

Orphanos, a subsidiary of TrialRunners, LLC, a North Dakota, LLC (“TrialRunners,” the “Company,” “We” or “Us”) is sensitive to privacy issues, and it is important to Us to protect the information provided to Us. Accordingly, TrialRunners provides this privacy and information practices policy to inform you about our online information practices, the kinds of information We may collect, how We intend to use and share that information, and how you can correct or change such information (“Privacy Policy”).

THIS WEBSITE IS NOT INTENDED FOR CHILDREN UNDER THE AGE OF 18. WE DO NOT KNOWINGLY COLLECT PERSONALLY IDENTIFIABLE INFORMATION FROM THIS AGE GROUP WITHOUT THE EXPLICIT CONSENT OF A PARENT OR GUARDIAN.

1.2 SCOPE

This Privacy Policy applies to information, including personal information, that is collected and processed by TrialRunners in the course of our business on this website (the “Site”).

This Site is not intended for use by visitors outside of the United States.

2.0 TRANSPARENCY/NOTICE–WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

We endeavor to collect information only relevant for the purposes stated herein. Below are the legal bases and some of the ways We collect information and how We use it.

2.1 Individuals

TrialRunners collects personal information regarding its visitors and guests (collectively “Individuals”). Certain information (name, address, telephone number, email) will be only be collected if it is voluntarily submitted via the forms on this site.

The personal and medical information We collect via the questionnaire will be generally used to: (i) assess the suitability of potential patients for clinical trials, (ii) contact, schedule and/or enroll pre-qualified patient referrals with study sites, (iii) other related recruitment, enrolment and retention Services and (iv) to improve the Site and it’s security.

The personal information collected and utilized may include name, phone number, email address, mailing address, user name, answer to a security question, password, diagnosis and other contact information.   If you meet the prequalification criteria for the trial, and grant Us explicit permission to do so, your information will be forwarded to a clinical trial site/investigator in your area for further evaluation; the investigator will be under strict constraints by laws governing the disclosure of personal information.

2.2      We acquire, hold, use and process personal information about Individuals for a variety of other business purposes including to:

  • generally manage Individual information and accounts;
  • respond to questions, comments and requests;
  • provide access to certain areas and features of the Site;
  • ensure internal quality control;
  • verify Individual identity;
  • communicate about Individual account and activities on the Site, and, in TrialRunners’ discretion, changes to any TrialRunners policy;
  • measure interest in and improve TrialRunners websites and systems;
  • develop new products, processes and services;
  • notify you about offers, products and services that may be of interest to you;
  • prevent potentially prohibited or illegal activities;
  • to provide services to you and our sponsors;
  • to enforce our Terms of Use; and
  • to share your anonymized or aggregated information with third parties (“Third Party” is any natural or legal person, public authority, agency or body other than you, TrialRunners or TrialRunners’ agents) for public health, research, analytics and any other legally permissible purposes.

2.3      Through our Site, TrialRunners may in the future allow third-party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-personal information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such information We have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering future targeted advertisements to you when you visit non-TrialRunners related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

2.4 Information from Third-Party Sources

TrialRunners may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows Us to verify information that you have provided to TrialRunners and to enhance our ability to provide you with information about our business, products and services. TrialRunners’ agreements with these third party-sources typically limit how TrialRunners may use this supplemental information.

2.5 Direct Mail, Email and Outbound Telemarketing

Individuals who provide Us with personal information, or whose personal information We obtain from third parties, may receive periodic emails, newsletters, mailings or phone calls from Us with information on TrialRunners or our business partners’ products and services or upcoming special offers/events We believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.

2.6 Research/Survey Solicitations

From time to time, TrialRunners may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help Us to better serve Individuals by learning more about their needs and the quality of the products and services We provide. The survey responses may be utilized to determine the effectiveness of our Site, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

2.7 All Internet Users – Cookies, Pixel Tags, Web Beacons and Aggregate Information

2.7.1 Cooki​es

Like many other websites, TrialRunners or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an Individual initiates a session on the Site. A cookie is set in order to identify you; tailor our Site to you; measure and research the effectiveness of our Site’ features, offerings and advertisements; and authenticate users for registered services. Cookies can only access personal information that you have provided on our Site and cannot be accessed by other sites. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some our Site, and to develop website content. This analytics data is not tied to any personal information. At any time, visitors may choose to opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on found at www.tools.google.com/dlpage/gaoptout.

You also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of TrialRunners’ Site.

2.7.2 Pixel Tags/​Web Beacons

TrialRunners may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow Us to monitor the use of our Site. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, We or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let Us know whether you received and opened our email.

2.7.3 Anonymous and A​ggregated Information

Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not personal information, and TrialRunners may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within TrialRunners and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

2.8 Mobile Computing

TrialRunners may provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of TrialRunners’ Site may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, TrialRunners may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal information to TrialRunners to enable you to access user accounts and to enable TrialRunners to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. TrialRunners may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices TrialRunners provides.

3.0 CHOICE/MODALITIES TO OPT OUT

You have the right to opt out of certain uses and disclosures of your personal information, as set out in this Privacy Policy.

3.1 General

Where you have consented to TrialRunners’ Processing of your information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before We use personal information for any new purpose not originally authorized by you, We will provide information regarding the new purpose and give you the opportunity to opt out.

3.2 Email and Telephone Communications

An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by TrialRunners so that you can opt-out. However, We will continue to send transaction-related emails regarding products or services you have requested.

3.3 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. TrialRunners does not recognize or respond to browser-initiated DNT signals.

4.0 ONWARD TRANSFER

4.1 Information We Share

TrialRunners does not sell or otherwise disclose personal information about you, except as described in this Privacy Policy or as you explicitly consent. TrialRunners may share personal information with our service providers, consultants, sites, sponsors, and affiliates for our and our affiliates’ internal business purposes.

TrialRunners may also provide personal information to business partners with whom We may jointly offer products or services, or whose products or services We believe may be of interest to you. In such cases, our business partner’s name will appear, along with TrialRunners’ name. TrialRunners requires our service providers, sponsors, and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which TrialRunners retained them or in the case of sponsors, for which they retained TrialRunners.

We may disclose information about you: (i) if We are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce TrialRunners policies or contracts; (v) 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 (vi) in the good faith believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

We reserve the right to disclose or transfer any information We have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, TrialRunners will endeavor to direct the transferee to use personal information in a manner that is consistent with this Privacy Policy.

4.2 Data Transfers

All personal information sent or collected via or by TrialRunners may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. By providing information to TrialRunners, you consent to the storage of your personal information in these locations.

5.0 RETENTION

TrialRunners retains the personal information We receive as described in this Privacy Policy for as long as you use our Site or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

6.0 SECURITY

The security of all personal information provided to TrialRunners is important to Us, and TrialRunners takes reasonable steps designed to protect your personal information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while TrialRunners strives to protect your personal information, We cannot ensure or warrant the security of any information you transmit to TrialRunners, and you do so at your own risk.

7.0      Telephone Consumer Protection Act (47 U.S.C. § 227).  In compliance with the Telephone Consumer Protection Act (TCPA) and the Cellular Telephone Industries Association (CTIA, an international industry trade group representing the interests of wireless telecommunications companies) We disclose on each opt-in page what users are to expect for SMS interaction and users agree to receive messages about current and future studies.

  • Users are given disclosure that text messages and data rates may apply.
  • Users are given opt out instructions with each SMS message and may opt out at any time by texting STOP.
  • When a user sends STOP We will prevent them from receiving any additional messages. Below is the exact message:

 

“You have successfully been unsubscribed. You will not receive any more messages from this number.”

 

  • Users receive an automated SMS message instantly after the user opts in via any web form.
  • In compliance with TCPA, follow up SMS communication initiated by Us will only be sent between 8 a.m. and 9 p.m. in the users’ time zone, as such zone is provided to Us.
  • All records are kept for a minimum of 4 years, which is the federal statute of limitations for bringing an action under the TCPA.

8.0 REDRESS / COMPLIANCE AND ACCOUNTABILITY

If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns, please contact:

TrialRunners

Attn: Chief Privacy Officer

[Address]

Email: privacy@trialrunners.com

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

9.0 OTHER RIGHTS AND IMPORTANT INFORMATION

9.1 Information Regarding Children

Due to the nature of TrialRunners’ business, services and benefits are not marketed to minors. TrialRunners does not knowingly solicit or collect personal information from children under the age of 18. If We learn that We have collected personal information from a child under the age of 18, We will promptly delete that information.

9.2 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. TrialRunners does not share personal information with third parties for their own marketing purposes.

9.3 Links to Third-Party Websites

Please note that our Site may contain links to other websites for your convenience and information. TrialRunners does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. TrialRunners does not endorse or make any representations about Third-Party websites. Any personal information you choose to give to unrelated third parties is not covered by this Privacy Policy. TrialRunners encourages you to review the privacy policy of any company or website before submitting your personal information. Some third parties may choose to share their users’ personal information with TrialRunners; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

9.4 Changes to the Privacy Policy

TrialRunners may update this Privacy Policy from time to time as it deems necessary in its sole discretion. TrialRunners encourages you to review this Privacy Policy periodically to be informed regarding how TrialRunners is using and protecting your information and to be aware of any policy changes. Your continued relationship with TrialRunners after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by TrialRunners.

[Updated 5/23/2018]