Consumer Health Data Privacy Notice

Last Updated Date: April 1, 2024

This Consumer Health Notice applies to personal information defined as “consumer health data” under US state privacy laws, including Washington’s My Health My Data Act and Nevada’s consumer health privacy law.

Scope

This Consumer Health Data Privacy Notice (this “Notice”) describes how Subject Well, Inc. and its group entities (“SubjectWell,” “we,” “us,” or “our”) collect, use, share and otherwise process consumer health data in connection with our website https://www.trialsearch.com and mobile versions of our website or anywhere else we display this Notice (collectively, the “Site”) to offer clinical trial participant recruitment services (the “Services”). It also applies to consumer health data collected by email, phone, or other offline communication mechanisms.

When we use the term “consumer health data” in this Notice, we mean personal information that is linked or reasonably linkable to an individual who acts in an individual or household context and that identifies such individual’s past, present, or future physical or mental health status. It does not include publicly available information, aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you or your device (and certain measures are taken for ensuring compliance), information about individuals acting in the employment context, or personal information that is used to engage in public or peer-reviewed scientific, historical, or statistical research that meets applicable requirements at law.

Consumer Health Data We Collect, Use Cases, Data Sharing

The table below describes the categories of consumer health data collected and the purpose for which the data is collected and purpose for which it will be used or shared; the categories of such data that are shared; and the categories of third parties and specific affiliates with whom we share consumer health data.  We do not “sell” consumer health data in exchange or money or other valuable consideration or share consumer health data for cross-context behavioral advertising.

Sources of Consumer Health Data

Sources of consumer health data we collect and use are:

• Directly From You. When you interact with us on our Site or use our Services, we (or our service providers) may collect the consumer health data you choose to share with us.
• Inferences. We may infer certain information about you based on information provided from any of the sources listed above.

Consumer Health Data Rights

We offer certain privacy rights regarding your consumer health data as stated below, subject to certain limitations at law.

How to Exercise Your Privacy Choices Regarding Consumer Health Data

Please submit a request by filling out our Privacy Rights Request Form here or by emailing us at privacy@subjectwell.com and include “Consumer Health Data Request” in the subject line of your message.

We may need to authenticate your identity and request before processing it, which may require us to obtain additional personal information from you. In order to authenticate your identity, we will generally require either the successful authentication of your existing account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address, and mailing address in the original request, as well as an explanation of the rights you wish to exercise. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.

In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.

Right to Appeal

In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@subjectwell.com.  If your appeal is unsuccessful, Washington residents can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Additional Information for Nevada Residents

We limit third party collection of consumer health data over time and across different websites while you use our Site.  Where third-party cookies, pixels or tracking technologies are enabled on our Site, we require such third parties to act as our service providers.  However, third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device used to access our Site. Such collection by third parties is not related to SubjectWell’s collection of consumer health data from you.  We encourage you to view the privacy notices of those third parties for more information about their data practices and your privacy choices with regard to those activities.

We also offer data rights with respect to all personal information we process, which include the rights noted above and the right to correct your information.  You can submit a request by filling out our Privacy Rights Request Form here or by emailing us at privacy@subjectwell.com and include “Correction Request” in the subject line of your message.

If your appeal is unsuccessful, Nevada residents can raise a concern or lodge a complaint with the Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.

Changes in Notice

From time to time, we may change this Notice. We will notify you of any material changes to this Notice as required by law. We will also post an updated copy of this Notice on the Site. Please check the Site periodically for updates.