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With this in mind, we're\nproviding this Privacy Policy to explain how your information is\ncollected, used, and disclosed by TrialSpark, Inc. (\"**TrialSpark**\",\n\"**we**\", or \"**us**\") in connection with our program (the\n\"**Program**\") that connects patients to researchers, trial sponsors,\nand pharmaceutical companies (\"**Researchers**\") that conduct research\nstudies and clinical trials (\"**Studies**\") appropriate to their\ndiagnoses or conditions. This Privacy Policy (\"**Policy**\") applies to\nPersonal Information that is Managed by TrialSpark in the course of our\nbusiness, including on TrialSpark websites, mobile applications, and\nother online offerings (together with any and all future online\nofferings operated by or on behalf of TrialSpark, the \"**Services**\"),\ne.g. the participants in the Program who are patients or supporters of\npatients. Except as otherwise indicated herein, \"**you**\" as used herein\nrefers to all types of users located in the United States. This Policy\nis intended to meet requirements in the United States.\n\nTrialSpark's Services may contain links to other websites for your\nconvenience and information. TrialSpark does not control Third-Party\n(defined below) websites or their privacy practices, which may differ\nfrom those set out in this Privacy Policy, even if they are accessible\nthrough our Program or Services. TrialSpark does not endorse or make any\nrepresentations about Third-Party websites. Any Personal Information you\nchoose to give to unrelated Third Parties is not covered by this Policy.\nTrialSpark encourages you to review the privacy policy of any company or\nwebsite before submitting your Personal Information. Some Third Parties\nmay choose to share their users' Personal Information with TrialSpark;\nthat sharing is governed by that company's privacy policy, not this\nPrivacy Policy.\n\nBy providing information through the Program, you signify that you have\nread, understood and agree to the collection, storage, use and\ndisclosure of your personal information as described in this Privacy\nPolicy.\n\nClinical Trial Data\n\nPersonal Information collected as part of participation in a clinical\nstudy will be additionally governed by that study's Informed Consent\nForm (\"ICF\") and any associated privacy policies.\n\nRevisions to this Privacy Policy\n\nAny information we collect is covered by the Privacy Policy in effect at\nthe time such information is collected. We may revise this Privacy\nPolicy from time to time. If we make any material changes to this\nPrivacy Policy, we'll notify you of those changes by sending you an\nemail or other notification, and we'll update the \"Last Updated Date\"\nabove to indicate when those changes will become effective. TrialSpark\nencourages you to review this Policy periodically to remain informed\nabout how TrialSpark is using and protecting Personal Information and to\nbe aware of any policy changes. By your continued relationship with\nTrialSpark after the posting or notice of any amended Privacy Policy,\nyou indicate your understanding and acknowledgement of the amended\nPrivacy Policy and consent to the collection and Managing of your\nPersonal Information as provided in the amended Privacy Policy. Any\nchanges to this Policy take effect immediately after being posted or\notherwise provided by TrialSpark.\n\nCollection and Use of Information\n\nThe types of Personal Information we may collect (directly from you or\nfrom Third-Party sources) and our privacy practices depend on the nature\nof the relationship you have with TrialSpark and the requirements of\napplicable law. We endeavor to collect only that information which is\nrelevant for the purposes of Managing. Below are the legal bases and\nsome of the ways we collect information and how we use it.\n\nInformation Collected or Received from You\n\nTrialSpark collects Personal Information regarding its current,\nprospective, and former Researchers, patients, Employees, users,\nvisitors, and guests.\n\nOur primary goals in collecting information are to provide and improve\nour Program, to administer your use of the Program (including your\naccount, if you are an account holder), and to enable you to enjoy and\neasily navigate our Program.\n\nThe types of personal information we collect from you depends on the\ncircumstances in which the information is collected. The most common\ntypes of information we collect and the ways we collect it are set out\nbelow:\n\n1. Account Information. If you register for the Program and fill out a screening form (\"**Screening Form**\"), we'll collect certain\n information that can be used to identify you, such as your name,\n email address, postal address, phone number, economic, cultural or\n social identification, sexual behavior or preference, racial or\n ethnic origin, and other Personal Information you may choose to\n provide. We may use this information for the purpose of outbound\n clinical trial site. If you are a parent or legal guardian, you may\n also register for the Program and fill out a Screening Form on\n behalf of your child (\"**Child**\"). Any personally identifiable\n information you submit on behalf of a Child will be deemed Personal\n Information for the purposes of this Privacy Policy.\n\n2. Health Information. As part of the Program, we may send you\n health-related surveys to collect information including, but not\n limited to, your or your Child's age, gender, date of birth, smoking\n status, height, weight, number of children, diagnoses, medical\n conditions, medications, medical history and other\n healthcare-related information. Any such information collected from\n you in connection with a survey or Screening Form is referred to as\n \"**Health Information**.\"\n\nYou acknowledge and agree that we may use the Health Information to\ncreate de-identified or aggregated data that does not identify you or\nyour Child (\"**De-Identified Data**\"). We may use and share\nDe-Identified Data for research and analysis purposes, to improve the\nProgram or to promote the Program.\n\n3. Third-party Patients. If you submit Health Information or\n personally-identifiable information (\"**PII**\") on behalf of your\n Child, you represent and warrant you have all rights necessary to do\n so and to permit TrialSpark to use such PII and Health Information\n as set forth in this Privacy Policy.\n\n4. Information Collected Using Cookies and other Web\n Technologies. Like many website owners and operators, we use\n automated data collection tools such as Web Beacons (defined below)\n to collect certain information.\n\n\"**Cookies**\" are small text files that are placed on your device by a\nweb server when you access our Program. We may use both session Cookies\nand persistent Cookies to identify that you've logged in to the Program\nand to tell us how and when you interact with our Program. We may also\nuse Cookies to monitor aggregate usage and web traffic routing on our\nProgram and to customize and improve our Program. Unlike persistent\nCookies, session Cookies are deleted when you log off from the Program\nand close your browser. Although most browsers automatically accept\nCookies, you can change your browser options to stop automatically\naccepting Cookies or to prompt you before accepting Cookies. Please\nnote, however, that if you don't accept Cookies, you may not be able to\naccess all portions or features of the Program. Some third-party\nservices providers that we engage (including third-party advertisers)\nmay also place their own Cookies on your device. Note that this Privacy\nPolicy covers only our use of Cookies and does not include use of\nCookies by such third parties.\n\n\"**Web Beacons**\" (also known as web bugs, pixel tags or clear GIFs) are\ntiny graphics with a unique identifier that may be included on our\nProgram for several purposes, including to deliver or communicate with\nCookies, to track and measure the performance of our Program, to monitor\nhow many visitors view our Program, and to monitor the effectiveness of\nour advertising. Unlike Cookies, which are stored on the user's device,\nWeb Beacons are typically embedded invisibly on web pages (or in an\ne-mail).\n\n5. Information Related to Use of the Program. Our servers\n automatically record certain information about how a person uses our\n Program (we refer to this information as \"**Log Data**\"), including\n both account holders and non-account holders (either, a \"**User**\").\n Log Data may include information such as a User's Internet Protocol\n (\"**IP**\") address, browser type, operating system, the web page\n that a User was visiting before accessing our Program, the pages or\n features of our Program to which a User browsed and the time spent\n on those pages or features, search terms, the links on our Program\n that a User clicked on and other statistics. We use Log Data to\n administer the Program and we analyze (and may engage third parties\n to analyze) Log Data to improve, customize and enhance our Program\n by expanding the features and functionality and tailoring them to\n our Users' needs and preferences. We may use a person's IP address\n to generate aggregate, non-identifying information about how our\n Program is used.\n\n6. Information Sent by Your Mobile Device. We collect certain\n information that your mobile device sends when you use our Program,\n like a device identifier, user settings and the operating system of\n your device, as well as information about your use of our Program.\n\n7. Location Information. When you visit our website, we may\n collect and store information about your location by converting your\n IP address into a rough geo-location or by accessing your mobile\n device's GPS coordinates or coarse location if you enable location\n services on your device. We may use location information to improve\n and personalize our Program for you. If you do not want us to\n collect location information, you may disable that feature on your\n mobile device.\n\nAdditionally, in some cases, TrialSpark is obligated to collect certain\nPersonal Information (defined below) to comply with regulatory\nrequirements, including information relating to adverse effects you may\nhave experienced when using our Services.\n\nYou can choose not to provide information to us directly, but some of\nthis information is required to participate in some of the Services, and\nsome Services may not function properly if you choose not to provide the\ninformation requested.\n\nInformation We Obtain from Other Sources.\n\nWe may receive information about you from other sources, including\nthrough Third-Party services and organizations. TrialSpark may\nindirectly collect information about your health condition, diagnosis,\nand treatment from your healthcare professional, but only where your\nhealthcare professional has obtained your consent to disclose that\ninformation to us, as required by law. TrialSpark may collect various\ninformation from healthcare professionals as part of marketing\nactivities to healthcare professionals, including first name, last name,\nage, gender, home address, home phone number, medical specialization,\nprofessional qualifications, license number and scientific society\nmembership number.\n\nTrialSpark may also collect information about you from Third-Party\nsources to supplement information provided by you. This supplemental\ninformation allows us to verify information that you have provided to\nTrialSpark and to enhance our ability to provide you with information\nabout our business, products, and services. TrialSpark's agreements with\nthese Third-Party sources typically limit how TrialSpark may use this\nsupplemental information\n\nHow TrialSpark Collects Personal Information\n\nYou may provide Personal Information directly to TrialSpark through\ninteracting with the Services, participating in surveys, during events,\non telephone conversations, and requesting products, Services, or\ninformation. As you navigate the Services, certain passive information\nmay also be collected about your visit, including through cookies and\nsimilar technologies as discussed above.\n\nHow TrialSpark Uses Personal Information\n\nWe acquire, hold, use, and Manage Personal Information based on the\nlegal grounds and for the legitimate business purposes outlined in this\nPolicy, including:\n\n1. To Provide Services or Information Requested: TrialSpark may\n use information about you to fulfill requests for Services or\n information, including information about potential or future\n Services, including to:\n\n - Generally manage Individual (as defined below) information and\n accounts;\n - Respond to questions, comments, and other requests;\n - Provide access to certain areas, functionalities, and features of\n TrialSpark's Services;\n - Allow you to register for events and Programs.\n
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\n\n2. Administrative Purposes: TrialSpark may use Personal\n Information about you for its administrative purposes, including to:\n\n - Measure interest in TrialSpark's Services;\n - Develop new Services;\n - Ensure internal quality control;\n - Verify Individual identity;\n - Communicate about Individual accounts and activities on TrialSpark's\n Services and systems, and, in TrialSpark's discretion, changes to\n any TrialSpark policy;\n - Process payment for Services purchased;\n - Manage applications and transactions;\n - Comply with regulatory requirements, including collecting and using information relating to adverse effects you may have experience when using our Services;\n - Prevent potentially prohibited or illegal activities.\n
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\n\n3. Marketing TrialSpark Services: TrialSpark may use Personal\n Information to provide you with materials about Services that may be\n of interest, including new content or Services. TrialSpark may\n provide you with these materials by phone, postal mail, facsimile,\n email, or other means of communication as permitted by applicable\n law. Such uses include:\n\n - To tailor content, advertisements, and offers;\n - To notify you about Services that may be of interest to you;\n - To provide Services to you and our Researchers;\n - For other purposes disclosed at the time that Individuals provide\n Personal Information; or\n - Otherwise with your consent. You may contact us at any time to opt\n out of the use of your Personal Information for marketing purposes,\n as further described below.\n
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\n\n4. Research and Development: TrialSpark may use Personal\n Information to create non-identifiable information that we may use\n alone or in the aggregate with information obtained from other\n sources, in order to help us to optimally deliver our Services or\n develop new Services.\n
\n\n5. Information Submitted Via Services. You agree that TrialSpark\n is free to use the content of any communications submitted by you\n via the Services, including any ideas, inventions, concepts,\n techniques, or know-how disclosed therein, for any purpose including\n developing, manufacturing, and/or marketing Services. TrialSpark\n will not release your name or otherwise publicize the fact that you\n submitted materials or other information to us unless: (a) you grant\n us permission to do so; (b) we first send notice to you that the\n materials or other information you submit to a particular part of a\n Service will be published or otherwise used with your name on it;\n or (c) we are required to do so by law.\n
\n\n6. Sharing Content with Friends or Colleagues. TrialSpark's\n Services may offer various tools and functionalities. For example,\n TrialSpark may provide functionality on its Services that will allow\n you to forward or share certain content with a friend or colleague.\n Email addresses that you may provide for a friend or colleague will\n be used to send your friend or colleague the content or link you\n request, but will not be collected or otherwise used by TrialSpark\n or any other Third Parties for any other purpose.\n
\n\n7. Information Anonymized or Aggregated. Including the analytics\n information discussed below, TrialSpark may use and share anonymized\n or aggregated information within the TrialSpark group of companies\n or with Third Parties for public health, research, analytics, or any\n other legally permissible purpose.\n
\n\n8. Other Uses. TrialSpark may use Personal Information for other\n purposes disclosed to you at the time you provide Personal\n Information or with your consent.\n
\n\nResearch/Survey Solicitations\n\nFrom time to time, TrialSpark may perform research (online and offline)\nvia surveys. We may engage Third-Party service providers to conduct such\nsurveys on our behalf. All survey responses are voluntary, and the\ninformation collected will be used for research and reporting purposes\nto help us better serve Individuals by learning more about their needs\nand the quality of the Services we provide. The survey responses may be\nutilized to determine the effectiveness of our Services, various types\nof communications, advertising campaigns, and/or promotional activities.\nIf an Individual participates in a survey, the information given will be\nused along with that of other study participants. We may share anonymous\nIndividual and aggregate data for research and analysis purposes.\n\nInformation that We Share with Third Parties\n\nWe will not share any Personal Information or Health Information that we\nhave collected from or regarding you except as described below:\n\n1. Information Shared with Our Researchers. We may share the\n Personal Information and Health Information you submit with the\n Researchers who have contracted with us to have access to our\n database. The Researchers have access to such information only for\n the purposes of selecting candidates for and conducting the Studies.\n\n2. Information Shared with Our Services Providers. We may engage\n third-party services providers to work with us to administer and\n provide the Program. These third-party services providers have\n access to the Personal Information and Health Information you submit\n only for the purpose of performing services on our behalf and, they\n are expressly prohibited from disclosing or using such information\n for any other purpose.\n\n3. Information Shared with Third Parties. We may share\n aggregated information and non-identifying information, including,\n without limitation, the De-Identified Data, with Third Parties for\n research and analysis, demographic profiling, promotion of the\n Program, and other similar purposes.\n\n4. Interest-Based Advertising. Through our Services, TrialSpark\n may allow Third-Party advertising partners to set tracking tools\n (e.g., cookies) to collect information regarding your activities\n (e.g., your IP address, page(s) visited, time of day). We may also\n share such de-identified information we have collected with\n Third-Party advertising partners. These advertising partners may use\n this information (and similar information collected from other\n websites) for purposes of delivering targeted advertisements to you\n when you visit non-TrialSpark related websites within their\n networks. This practice is commonly referred to as \"interest-based\n advertising\" or \"online behavioral advertising.\"\n\n5. Information Shared with Web Analytics Services Providers.\n\n - Google We utilize Google Analytics, a service provided by\n Google, Inc. (\"**Google**\"), to gather information about how\n users engage with our website and Services. For more information\n about Google Analytics, please visit\n www.google.com/policies/privacy/partners/. You can opt out of\n Google's collection and processing of data generated by your use\n of the Services by going\n to .\n\n - Facebook. We may use certain tools offered by third\n parties (e.g., Facebook) to enable them to collect or receive\n information about actions users take on our Site and elsewhere\n on the internet through use of Cookies, Web Beacons and other\n storage technologies. These third parties may use the data that\n they collect to provide measurement services, targeted ads and\n other services. For more information regarding the collection\n and use of such information by Facebook, please see the Facebook\n Data Policy, available\n at: .\n\n - Opt-out of Ad Tracking. You can opt out of the collection\n and use of your information for ad targeting by going\n to or to\n limit collection through our website.\n\n6. Information Disclosed in Connection with Business\n Transactions. Information that we collect from our users,\n including Personal Information and Health Information, is considered\n to be a business asset. Thus, if we are acquired by a third party as\n a result of a transaction such as a merger, acquisition or asset\n sale or if our assets are acquired by a third party in the event we\n go out of business or enter bankruptcy, some or all of our assets,\n including your Personal Information and Health Information, may be\n disclosed or transferred to a third party acquirer in connection\n with the transaction.\n\n7. Information Disclosed for Our Protection and the Protection of\n Others. We cooperate with government and law enforcement\n officials or private parties to enforce and comply with the law. We\n may disclose any information about you to government or law\n enforcement officials or private parties as we, in our sole\n discretion, believe necessary or appropriate: (i) to respond to\n claims, legal process (including subpoenas); (ii) to protect our\n property, rights and safety and the property, rights and safety of a\n third party or the public in general; and (iii) to stop any activity\n that we consider illegal, unethical or legally actionable activity.\n\nTrialSpark has executed appropriate contracts with the service providers\nthat prohibit them from using or sharing Personal Information except as\nnecessary to perform the contracted services on our behalf or to comply\nwith applicable legal requirements.\n\nYour Choices\n\nWe offer you choices regarding the collection, use and sharing of the\nPersonal Information and Health Information you submit and we will\nrespect the choices you make. Please note that if you decide not to\nprovide us with the Personal Information or Health Information that we\nrequest, you may not be able to access or participate in all of the\nfeatures of the Program.\n\nWhere you have consented to TrialSpark's Managing of your Personal\nInformation, you may withdraw that consent at any time and opt out to\nfurther Managing by following the instructions in this section.\n\nAdditionally, before we use Personal Information for any new purpose not\noriginally authorized by you, we will provide information regarding the\nnew purpose and give you the opportunity to opt out.\n\nPrior to disclosing Sensitive Data to a Third Party or Managing\nSensitive Data for a purpose other than its original purpose or the\npurpose authorized subsequently by the Individual, TrialSpark will\nendeavor to obtain each Individual's explicit (opt-in) consent. Where\nconsent of the Individual for the Managing of Personal Information is\notherwise required by law or contract, TrialSpark will comply with the\nlaw or contract.\n\n1. Opt-Out. We may periodically send you free newsletters and\n e-mails that directly promote our Program. When you receive such\n promotional communications from us, you will have the opportunity to\n \"opt-out\" by following the unsubscribe instructions provided in the\n e-mail you receive. We do need to send you certain communications\n regarding the Program and you will not be able to opt out of those\n communications -- e.g., communications regarding updates to our\n Terms of Service or this Privacy Policy, without opting entirely out\n of the Program or Services.\n\n2. Advertising Choices. If TrialSpark participates in\n interest-based advertising, an opportunity to opt out of such\n interest-based advertising will be provided through an AdChoices\n link. Advertisements on Third-Party websites that contain the\n AdChoices link and that link to this Policy may have been directed\n to you based on anonymous, non-Personal Information collected by\n advertising partners over time and across websites. These\n advertisements provide a mechanism to opt-out of the advertising\n partners' use of this information for interest-based advertising\n purposes. Even if you opt out through AdChoices, we may still\n collect and use non-Personal Information regarding your activities\n on our Services and/or information from the advertisements on\n Third-Party websites for non-interest-based advertising purposes,\n such as to determine the effectiveness of the advertisements.\n\n3. Modifying Your Information. You can access and modify the\n Personal Information and Health Information submitted in connection\n with a Screening Form by emailing support@trialspark.com. If you\n want us to delete your Personal Information and Health Information,\n please contact us at support@trialspark.com with your request.\n We'll take steps to delete your information as soon we can, but some\n information may remain in archived/backup copies for our records or\n as otherwise required by law.\n\nResponding to Do Not Track Signals\n\nOur website does not have the capability to respond to \"Do Not Track\"\nsignals received from various web browsers.\n\nThe Security of Your Information\n\nWe take reasonable administrative, physical and electronic measures\ndesigned to protect the information that we collect from or about you\n(including your Personal Information and Health Information) from\nunauthorized access, use or disclosure. When you enter sensitive\ninformation on our forms, we encrypt this data using SSL or other\ntechnologies. Please be aware, however, that no method of transmitting\ninformation over the Internet or storing information is completely\nsecure. Accordingly, we cannot guarantee the absolute security of any\ninformation.\n\nLinks to Other Sites\n\nOur Program may contain links to websites and services that are owned or\noperated by Third Parties (each, a \"**Third-party Service**\"). Any\ninformation that you provide on or to a Third-party Service or that is\ncollected by a Third-party Service is provided directly to the owner or\noperator of the Third-party Service and is subject to the owner's or\noperator's privacy policy. We're not responsible for the content,\nprivacy or security practices and policies of any Third-party Service.\nTo protect your information, we recommend that you carefully review the\nprivacy policies of all Third-party services that you access.\n\nInternational Transfer\n\nYour Personal Information and Health Information may be transferred to,\nand maintained on, computers located outside of your state, province, or\nother governmental jurisdiction where the privacy laws may not be as\nprotective as those in your jurisdiction. All Personal Information\ncollected via or by TrialSpark will be stored in the United States, on\nour servers, on the servers of our affiliates or the servers of our\nservice providers. Your Personal Information may be accessible to law\nenforcement or other authorities pursuant to a lawful request. By\nproviding information to TrialSpark, you consent to the storage of your\nPersonal Information in these locations.\n\nData Retention\n\nTrialSpark retains the Personal Information we receive as described in\nthis Policy for as long as you use our Services or as necessary to\nfulfill the purpose(s) for which it was collected, provide our Services,\nresolve disputes, establish legal defenses, conduct audits, pursue\nlegitimate business purposes, enforce our agreements, and comply with\napplicable laws. We will retain your data for the duration of the trial\non active databases. Your data will be de-identified after the duration\nof the trial.\n\nRedress/Compliance and Accountability\n\nIf after reviewing this Policy, you would like to submit a request or\nyou have any questions or privacy concerns, please contact: TrialSpark\nSupport at support@trialspark.com, or at 16 East 34^th Street, Floor\n10, New York, NY 10016. TrialSpark will address your concerns and\nattempt to resolve any privacy issues in a timely manner.\n\nOur Policy Toward Children\n\nOur Services are not specifically directed to minors and we do not\nknowingly collect Personal Information, including Health Information\nfrom children under 13 (and, where applicable, in certain jurisdictions\nunder the age of 16) except where that Personal Information is provided\nby an authorized parent or guardian and/or pursuant to an authorized\nparent's or guardian's consent, such as through an ICF. If we learn that\nwe have collected Personal Information or Health Information directly\nfrom a child under 13 (and, where applicable in certain jurisdictions,\nunder the age of 16) without any necessary consent from an authorized\nparent or guardian, we will take steps to delete such information from\nour files as soon as possible.\n\nQuestions\n\nPlease contact us at support@trialspark.com if you have any questions\nabout our Privacy Policy.\n\nAdditional Definitions\n\n\"**Employee**\" refers to any current, temporary, permanent, prospective\nor former employee, director, contractor, worker or retiree of\nTrialSpark or its subsidiaries worldwide.\n\n\"**Manage**\", \"**Managed**\" or \"**Managing**\" means any operation which\nis performed upon Personal Information, whether or not by automatic\nmeans, such as collection, recording, organization, structuring,\nstorage, adaptation or alteration, retrieval, consultation, use,\ndisclosure by transmission, dissemination or otherwise making available,\nalignment or combination, restriction, erasure, or destruction.\n\n\"**Personal Information**\" is any information relating to an Individual,\nincluding Internet Protocol addresses, information contained in cookies,\nand navigational data. 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