When you use the Site or otherwise communicate or interact with us through the Services, we collect information that you provide to us directly. For example, we collect information in the following circumstances: when you contact us; when you register for and engage with our Services; and when you otherwise communicate with us. Occasionally, you may choose whether or not to provide or disclose Personal Information in connection with your use of the Services. If you choose not to provide the Personal Information we request, you may still visit and use parts of the Site, but may be unable to access or use certain features, options, programs, and services of the Site. In addition, as we need certain Personal Information for the performance of the Services, the consequence of not providing such information might be that the Services cannot be provided as requested.
The Personal Information you provide to us may include the following:
|Type of Cookies||Description||Managing Settings|
|Performance cookies||These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Site functions and performs. From time-to-time, we may engage service providers to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.||To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.|
|Functionality cookies||Functionality cookies allow our Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.||To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.|
Some browsers have a "Do-Not-Track" feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the Do-Not-Track setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug-in providers, and other web services that you may encounter while browsing the Internet, instructing them to stop tracking your activity via cookies or other online tracking technologies. The Site does not currently respond to browser based Do-Not-Track signals. For information regarding Do-Not-Track and how to enable this setting if available on your devices, please see https://allaboutdnt.com.
We may also obtain data from third-party sources such as a registrant's authorized representative or guardian, our customers or vendors such as data providers. Our data providers include Human API and iPatient Axis, the entities that we partner with to provide free patient medical record retrieval for clinical trial recruitment. For more information, please visit Human API at https://www.humanapi.co (email@example.com) or iPatient Axis at https://ipatientaxis.eu (firstname.lastname@example.org).
We may use Personal Information obtained through the Services in the following ways:
If you register for our Services, SubjectWell uses algorithms that enforce criteria to select the clinical trial most suitable to you, which is the service that you (as the data subject) request from SubjectWell. The decision on the clinical trial matching is therefore necessary for the performance of the contract between you and SubjectWell. Furthermore, our patient recruitment marketplace is voluntary and when you choose to participate and disclose your information to us, you also provide your explicit consent, which is freely given and can be withdrawn at any time by contacting us through the contact details further below.
The logic that is used for the decision-making is created by SubjectWell employees reviewing study protocols that define inclusion/exclusion criteria for study eligibility. The SubjectWell systems then enforce these criteria based on the responses collected during the phone screening process. The most important consequences of the automated decisions in question is that you will or will not have the opportunity to participate in a clinical trial.
In order to safeguard your rights and freedoms and legitimate interests, you have the right to obtain human intervention on the part of SubjectWell, to express your point of view and to contest the decision.
Also note that we only provide clinical trial participant recruitment services and are not involved in clinical trials or informed about the results. Therefore, SubjectWell does not determine the purposes or means of the further processing of your Personal Information, including your health information, by principal investigators, clinical research sites or clinical trial service providers once you are brought in contact with them.
We may disclose Personal Information you provide to us or that we collect automatically on the Site or in and through the Services with the following categories of third parties:
Once you register for our Services, if you have opted in to certain communications, you may be contacted at the phone number you provide including wireless number (if provided), by a representative of SubjectWell or its database administrator. You may opt out of these calls or texts at any time by sending an email to email@example.com or by calling (844) 612-6317. If you would like to stop receiving text messages, you may text STOP in reply to any messages that you receive.
With your consent (unless otherwise permitted by applicable law) we use the Personal Information you provide us to send you information on our products and Services and other information based on the interests that you have indicated to us. You have the right to opt out of getting those messages. If you do not wish to receive these messages, click the unsubscribe link in your email. Please note that these selections are not permanent; they may be changed in the event you register for other Services or communications and consent to receive marketing messages. Please also note that even if you unsubscribe from commercial email messages, we may still email you non-marketing emails related to your account or the Services for which you have registered. You may also email us at firstname.lastname@example.org for assistance.
Please note that as of the effective date of this Policy, the CCPA implementing regulations have not been finalized by the California Attorney General. Accordingly, we may update this section, our relevant data practices, or our processes for handling CCPA requests, in response to the final CCPA regulations or other CCPA legal developments.
In accordance with the California Consumer Privacy Act of 2018 ("CCPA"), this section describes the Personal Information we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting the information, and the third parties with whom we shared that information. Please refer to the corresponding sections of this policy above for details on the following:
Under the CCPA, California residents have certain rights with regard to their Personal Information. Those rights may only apply in certain circumstances and may be subject to limitations or exceptions. A summary of those rights is provided below as well as information on how to exercise your rights. Please note that we will require certain identifying information about you as necessary for us to verify your request in accordance with applicable law.
We will not discriminate against you for exercising any of the rights noted above. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to access, or right to deletion in accordance with applicable law.
You can exercise these rights yourself or you can designate an authorized agent to make a request on your behalf. If you would like an authorized agent to submit a request on your behalf, please send us an email at email@example.com for instructions and details on proof and information required for use of an authorized agent.
Where we process Personal Information pertaining to individual located in the European Economic Area ("EEA") or Switzerland, those individuals are entitled to ask us for an overview of the Personal Information we have about them and also to access, correct or delete certain Personal Information, restrict processing of their Personal Information, or to ask us to transfer Personal Information to other organizations. Certain individuals can also object to some processing of their Personal Information and, where we have asked for their consent, they can withdraw their consent at any time. Insofar as Personal Information about them is processed, certain individuals also have a right to know more about the protection we apply when transferring Personal Information to areas outside the EEA.
Note that we are not legally obligated to agree to such requests in all circumstances, and in certain circumstances, agreeing to a request may be infeasible - for example, a deletion request when we are required by law to maintain the Personal Information. Please also note that we are not able to act on any of the above requests if we are not in a position to identify an individual filing such request.
Where applicable, these rights can be exercised by completing the request form available here or by sending us an email through the contact details further below. Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Information. We encourage you to first reach out to us at firstname.lastname@example.org so we have an opportunity to address your concerns directly before you do so. We are committed to compliance with the General Data Protection Regulation ("GDPR") where applicable, so please contact us through the details listed below if you have any questions about these rights.
In compliance with the Privacy Shield Principles, SubjectWell commits to resolve complaints about your privacy and our collection or use of Personal Information about you. Persons in the EEA or Switzerland who have inquiries or complaints regarding this Statement should first contact us via email at: email@example.com.
SubjectWell has committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Pursuant to the Privacy Shield, SubjectWell remains potentially liable for the transfer of Personal Information to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
In cases of onward transfer to third parties of Personal Information of individuals in the EEA or Switzerland received pursuant to the EU-U.S. and Switzerland-U.S. Privacy Shield, SubjectWell is potentially liable.
We keep Personal Information for as long as it is needed to fulfill the purposes for which it was collected, to provide our Services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. If you register for our Services, we keep your Personal Information for seven (7) years from the point of collection in order to match you to a clinical trial. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.
We follow generally accepted industry standards to protect the Personal Information we collect or process through the Platforms. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
The Site is not intended for children under the age of 13. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age through the Site. If we become aware that a child under age 13 has provided Personal Information through the Site, we will delete such information from our files.
Address: 7000 N MoPac Expy
Austin, TX 78731
You can also contact our representative in the European Union:
European Data Protection Office (EDPO):
Name: Lucia Canga Roza
Phone number: +32 499 24 28 45