Introductions

ResearchTrials.com is administered by Probity Medical Research Inc.

ResearchTrials.com is committed to respecting your personal information (defined below) and is aware of your concern for privacy when using ResearchTrials.com. Further to this commitment, we have adopted a Privacy Policy that guides how we collect, use, disclose, update and protect the information you provide to us and when we delete such information.

Probity complies with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable privacy and health information legislation. One of the underlying principles of this legislation is to obtain your consent to collect, use or disclose your personal information (defined below), and to ensure that you clearly understand the policies and practices regarding how this information is handled.

What is Personal Information?

“Personal information” is information about an identifiable individual. This includes any information that can be linked to an individual’s identity, such as name, address, contact information, age, gender, location, survey information, or any other information that might reasonably be used to identify someone. It does not apply to the information of non-individuals, such as corporations and other business entities and, generally speaking, to business contact information of physicians (“Physicians”) or pharmaceutical companies/medical device manufacturers (“Sponsors”).

Consent-Based Collection and Sharing for Clinical Trial Matching

ResearchTrials.com helps connect members of the public who are interested in participating in clinical trials with nearby clinical trial sites in our network. To provide this service, we need your consent to collect and use the personal information and related health information you choose to provide to ResearchTrials.com. We do not collect, use, or share personal information or related health information without first obtaining your consent.

When you choose to complete a registration, contact form, or survey on ResearchTrials.com, or provide information to us by email, telephone, or another direct communication method, you consent to our collection and use of the personal information and related health information that you voluntarily provide in that submission or communication. With your consent, and only if, based on the information you provide, it appears that you may be eligible for a clinical trial at a clinical trial site in your area that is part of our network, we may share that information with the site so that they can contact you about possible participation.

What Personal Information Do We Collect?

We limit the personal information and related health information we collect only to what is necessary to fulfill the purpose of ResearchTrials.com.

If you are interested in joining or learning more about a clinical trial, the information we request is generally limited to:

• your name;
• your contact information;
• your general location, including your city or town;
• the clinical trial or medical condition you are interested in; and
• related health or health information needed to help assess your potential eligibility for a clinical trial.

How do we Obtain Consent?

By voluntarily providing your personal information, you are consenting to our collection and use of your personal information for the purposes outlined below. Further, by using our website, you agree with the terms of this Privacy Policy.

Before submitting a registration form to express interest in a clinical trial, you are also required to agree to our Privacy Policy and/or applicable consent form. By agreeing to those terms and submitting the registration form, you consent to our collection, use, and handling of the personal information you voluntarily provide for the purposes described in this Privacy Policy and/or the applicable consent form.

You may withdraw this consent at any time or update your personal information by contacting our Privacy Officer at [email protected].

How do we Use Personal Information?

When you voluntarily provide your personal information and any health-related information to us through a study registration form, email, telephone call, or other direct communication with us, we may collect, use, and disclose that information for the following purposes:

• to identify and respond to your inquiry;
• to contact you about clinical research studies that may be relevant to you;
• to review the information you provide and conduct a preliminary assessment of whether you may be a potential match for a clinical trial, recognizing that final eligibility is determined by the applicable clinical trial site, investigator, or study team;
• to match or route your inquiry based on factors such as your location, the study or medical condition you are interested in, and the information you provide;
• to share your personal information and health-related information with one or more relevant clinical trial site(s) in our network so that they may review your inquiry and contact you about possible participation;
• with your consent, to receive limited information from clinical trial site(s) about whether your referral resulted in contact, screening, or enrollment, including the relevant clinical trial, so that we can evaluate the effectiveness of our recruitment services;
• to maintain records of your consent, registration, communications, requests, and preferences;
• to protect against error, fraud, misuse, unauthorized activity, and security incidents; and
• to comply with legal, regulatory, audit, reporting, and other compliance obligations.

Transfer of Personal Information to Research Sites

We will only transmit your personal information to a clinical trial site if we are working with a site in your area that you could reasonably travel to for participation in the clinical trial, or if you register for a study or condition at a specific clinical trial site that we work with.

This allows both ResearchTrials.com and the applicable clinical trial site to review your inquiry, assess whether you may be eligible for or interested in a clinical trial, and contact you about next steps where appropriate.

The research site that receives your personal information may be located in a country, province, state, or region different from the location where the ResearchTrials.com database is hosted or maintained.

Personal information will not be sold or rented and will not be exchanged with unaffiliated entities, except to fulfill the purposes set out above, unless you are first notified and expressly consent to such transfer.

Safeguarding Personal Information

Probity is aware of your concern for privacy when using ResearchTrials.com. Probity takes reasonable steps to protect your personal information as you transmit your information from your computer to our websites and to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. All information transmitted to our website is secured using industry standard physical, technical, and administrative safeguards to secure data against foreseeable risks such as unauthorized use, access, disclosure, destruction, and modification. You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. Email communications sent to or from us, including communications submitted through our website or email service, may not be secure. You should therefore use caution when deciding what information to send to us by email.

Your personal information is kept in strict confidence; Probity utilizes appropriate security safeguards to keep your information confidential and secure. Only authorized personnel have access to your personal information, and we do not release your personal information to third parties other than those third parties that are necessary to satisfy the purposes (as defined above) for which the personal information was collected, including third party service providers. While we cannot guarantee that errors, loss or unauthorized access to your personal information will not occur, our procedures and systems are designed to protect your personal information from such events. When your personal information is no longer required to fulfill the identified purposes, the information will be destroyed, erased, or made anonymous.

If a clinical trial site, investigator, study coordinator, or other member of a clinical research study team contacts you about possible participation in a clinical research study, that site or study team will be responsible for any additional personal information or health-related information that you choose to provide directly to them. Probity remains responsible for personal information under its control, but is not responsible for the clinical trial site’s collection, use, disclosure, retention, or safeguarding of information that you provide directly to that site or study team. We recommend that you review or ask for information about the clinical trial site’s privacy practices before providing additional information or participating in a study.

Retention of Personal Information

We retain personal information and health-related information that you provide to us for up to one year from the date it is collected, unless it is deleted earlier because it is no longer needed, or unless a longer retention period is required or permitted by law.

After the applicable retention period ends, we delete, destroy, or de-identify the information in accordance with our retention and deletion practices. In some cases, limited records may be retained for a longer period where necessary for legal, regulatory, audit, security, fraud prevention, complaint-handling, consent-management, or recordkeeping purposes.

If at any time you wish to request that we remove or update your personal information, please contact our Privacy Officer at [email protected]. Please note that if your information has already been shared with a clinical trial site, you may also need to contact that site directly regarding any information it maintains about you.

Access to Records and Other Information

You may request access to the personal information that you voluntarily provided to us, such as information submitted through a registration form, contact form, email, telephone call, or another direct communication method.

Where required by applicable law, we will tell you whether we still hold personal information that you voluntarily provided and provide access to that information, subject to any applicable exceptions. For example, we may refuse or limit access if we cannot confirm the identity of the person making the request, if disclosure would reveal personal information about another individual, if the information is protected by legal privilege, or if another exception under applicable law applies.

We retain information collected through the website, including information related to registrations, inquiries, requests, and communications, for up to one year from the date it is collected, unless it is deleted earlier. Except where required by applicable law, we are not obligated to maintain records of personal information that you provide to us and may delete such information at any time in accordance with our retention practices.

If the personal information you request has been deleted, whether after the standard one-year retention period or earlier, we will no longer have that information available and will not have a record to provide to you.

If you wish to request access to personal information that you voluntarily provided to us, please contact us at [email protected]. We may ask you to provide sufficient information to verify your identity and help us locate the requested information.

Non-Identifying Website Usage Information

We use strictly necessary cookies and similar technologies that are required for the website to function properly. If you consent to optional cookies or similar technologies, we may also collect non-identifying information about your visit and use of the website, such as the pages you view, searches you perform, general website activity, analytics information, and similar technical or usage information. We use information collected through optional cookies only to help operate, analyze, improve, and measure use of the website, understand website traffic, measure engagement, and support related website functions. We do not use this information to identify you personally, and we do not link it to any clinical trial registration, personal information, or health-related information you voluntarily provide, unless we have clearly disclosed this and obtained any required consent.

IP Address Information

ResearchTrials.com may collect Internet Protocol (IP) addresses and related technical information when users visit the website. Depending on applicable privacy laws, IP addresses may be considered personal information or personal data.

We may use IP address information to:

• Maintain website security;
• Detect fraud, abuse, or unauthorized activity;
• Diagnose technical issues;
• Improve website performance;
• Analyze website traffic and usage patterns; and
• Support compliance and recordkeeping obligations.

Where IP address information is collected through analytics or advertising technologies, such collection will be subject to the user’s consent preferences where required by applicable law.

Probity may also collect non-personally identifiable information in aggregate form to track data such as the total number of visits to our websites, the number of visitors to each page of our websites, and the domain names of our visitors’ Internet service providers. We may use this information, which remains in aggregate form, to understand how our visitors use our websites so that we may make the websites better.

De-Identification and Separate Storage of IP Addresses

When IP addresses are collected through this website, they are de-identified by truncation before they are stored or used. Truncation means that a portion of the IP address is removed so that the remaining information no longer identifies, and cannot reasonably be used to identify, a specific individual or device.

Truncated IP address information is stored separately from any personal, medical, health-related, or clinical trial information that visitors may provide through the website. We do not store full IP addresses together with information you submit about your health, medical history, eligibility for a clinical trial, or other personal details.

Because IP addresses are truncated and stored separately from health-related information, we cannot identify you by IP address based on the searches you perform, the pages you view, or the way you interact with the website. This separation is intended to help ensure that an IP address cannot be used to infer health or health information about you, and that truncated IP address information cannot be linked back to you as an individual.

When We May Be Able to Identify You

We are only able to identify you when you consent to provide, and explicitly provide, your name, contact information, or other identifying information through the website. For example, this may occur if you choose to complete a contact form, request information about a clinical trial, or submit information so that someone may follow up with you.

If you do not choose to provide identifying information, we do not use your truncated IP address, website searches, page views, or other website activity to identify you. By truncating IP addresses and keeping them separate from health-related information, we reduce the risk that website usage information could be associated with a specific person or with any health information they provide.

Cookies and Consent Management

ResearchTrials.com uses cookies and similar technologies, including pixels, tags, local storage objects, and other tracking technologies, to operate the website, understand website usage, improve user experience, measure website performance, and support marketing and advertising activities.

ResearchTrials.com utilizes a Consent Management Platform (“CMP”) provided by Cookiebot by Usercentrics to obtain and manage user consent for the use of non-essential cookies and tracking technologies.

Cookies and similar technologies used on our website may fall into the following categories:

Strictly Necessary Cookies

These cookies are required for the operation, security, and functionality of the website and cannot be disabled through our consent banner. These cookies do not require consent where permitted by applicable law.

Analytics and Performance Cookies

These cookies help us understand how visitors interact with our website, including information about website traffic, visitor behavior, page usage, and website performance. We may use technologies such as Google Analytics 4 for these purposes.

Analytics cookies are only activated after the user has provided consent where required by applicable law.

Advertising and Marketing Cookies

These cookies may be used to measure advertising performance, support remarketing activities, deliver relevant advertising, and evaluate marketing campaigns. ResearchTrials.com may use technologies such as Google Ads, Meta Pixel, LinkedIn Insight Tag, and similar advertising technologies.

Advertising and marketing cookies are only activated after the user has provided consent where required by applicable law.

Managing Your Consent

When you first visit ResearchTrials.com, you will be presented with a cookie consent banner that allows you to:

• Accept all cookies;
• Reject non-essential cookies; or
• Customize your cookie preferences.

You may change or withdraw your consent at any time through the cookie preferences tool available on our website.

Your consent preferences will be stored and respected in accordance with applicable privacy laws.

Consent Records

ResearchTrials.com may maintain records of cookie consent decisions, including the date, time, consent status, and related technical information, for compliance, audit, legal, and recordkeeping purposes.

Google Consent Mode

ResearchTrials.com may use Google Consent Mode to communicate consent choices to Google services and to ensure that Google Analytics, Google Ads, and related technologies operate in accordance with user consent preferences.

Cookie Retention

Cookies may remain on your device for different periods of time depending on their purpose. Some cookies are deleted when your browser session ends, while others may remain until they expire or are deleted by you.

Third-Party Analytics and Advertising Providers

ResearchTrials.com may use third-party service providers to assist with website analytics, website administration, performance monitoring, advertising measurement, advertising effectiveness, user experience improvement, and related business operations.

These service providers may include, but are not limited to:

• Google Analytics;
• Google Tag Manager;
• Google Ads;
• Meta (Facebook) Pixel;
• LinkedIn Insight Tag; and
• Other analytics, advertising, marketing, or technology service providers that support the operation and improvement of ResearchTrials.com.

These technologies may collect information about your interactions with our website, including:

• Internet Protocol (IP) address;
• Browser type and version;
• Device type and operating system;
• Referring websites and pages;
• Pages visited and content viewed;
• Date and time of visits;
• Session information;
• Advertising interactions and campaign performance data; and
• Other technical and usage information associated with website activity.

ResearchTrials.com utilizes a Consent Management Platform (“CMP”) provided by Cookiebot by Usercentrics to obtain and manage user consent for the use of non-essential cookies and tracking technologies.

Where required by applicable law, analytics, advertising, marketing, and other non-essential tracking technologies will only be activated after the user has provided consent through the consent management platform. Users may accept, reject, or customize their cookie preferences and may withdraw or modify their consent at any time through the cookie preferences tool available on the website.

ResearchTrials.com may use Google Consent Mode and similar consent signaling technologies to communicate users’ consent choices to Google services and other technology providers, and to help ensure that data collection and processing activities respect users’ consent preferences.

Information collected through analytics and advertising technologies may be processed by third-party service providers in Canada, the United States, the European Union, Australia, Chile, or other jurisdictions in which those providers operate or maintain infrastructure. As a result, information may be subject to the laws of those jurisdictions.

ResearchTrials.com may maintain records of consent preferences, including consent status, date and time of consent, consent categories selected, and related technical information, for compliance, auditing, legal, security, and recordkeeping purposes.

Tracking on Sensitive Research Pages

ResearchTrials.com recognizes that visitors may access information relating to medical conditions, clinical research opportunities, and other health-related topics.

Where practicable, ResearchTrials.com seeks to limit the use of advertising, remarketing, and behavioral profiling technologies on pages involving study enrollment, participant screening, informed consent processes, questionnaires, or other sensitive participant-facing interactions.

ResearchTrials.com periodically reviews its use of analytics, advertising, and marketing technologies to ensure that they remain appropriate for the nature of the information being collected and the purposes for which the information is processed.

Users are encouraged to review the privacy policies of third-party service providers used by ResearchTrials.com for additional information regarding their data collection, processing, storage, and privacy practices.

Retention of Website Use, Registration, and Communication Information

We retain information collected about your use of this website, as well as any information related to your registrations, inquiries, requests, or communications with us through the website, only for as long as necessary and in no event longer than one year from the date it is collected.

After the one-year retention period ends, this information is deleted from our systems and is no longer accessible to authorized personnel. This means that website use information, registration-related information, and communication records submitted through the website are not kept indefinitely and are removed once the applicable retention period has expired.

This retention period applies to information collected through the website, including information about website activity and information you choose to provide when registering, requesting information, or communicating with us.

Changes to the Policy

Probity reserves the right to modify or amend this Privacy Policy without notice and at any time and for any reason. An up-to-date version of this Privacy Policy may be obtained on our website.

Governing Law

This Privacy Policy is governed by the laws of Canada.  By submitting personal information to us, you understand that your personal information will be subject to the laws of Canada.

Questions and Concerns

You have the right to know how we protect your privacy and what you should expect from us. If you have questions or a complaint, you may contact our Privacy Officer at [email protected].