1. INTRODUCTION

This Privacy Policy explains how CliniContact LLC (“CliniContact” or “we” or “us”) collects and uses Personal Data through its Websites and electronic communications with you. CliniContact values your privacy and is committed to protecting it. This Privacy Policy complies with the EU General Data Protection Regulation (“GDPR”) and other applicable privacy laws.

CliniContact complies with the EU-U.S. Data Privacy Framework (DPF) principles, including notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement, and liability, for all personal data received from the European Union (EU), United Kingdom (UK), and Switzerland. CliniContact has self-certified to the U.S. Department of Commerce regarding its adherence to the DPF principles.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our websites at https://mainpage.clinicontact.com/ or https://www.clinicontact.com (each, a “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on our Websites; and
• in email, text, and other electronic messages between you and our Website

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by CliniContact or any third-party;
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use our Websites. By accessing or using these Websites, you agree to this Privacy Policy. This Privacy Policy may change from time to time, so please check this Privacy Policy periodically for updates.

2. DATA CONTROLLER, DATA PROTECTION OFFICER, AND REPRESENTATIVE

CliniContact is the data controller of your Personal Data collected through the Websites. CliniContact has appointed a Data Protection Officer and a representative in compliance with the General Data Protection Regulation. If you have any questions about this Privacy Policy or your Personal Data, please contact CliniContact using the information set forth in the “Contact Information” Section below.

3. CHILDREN UNDER THE AGE OF 13; CHILDREN OVER THE AGE OF 13 BUT UNDER THE AGE OF 16

Our Websites are not intended for children under the age of 13. If you are under 13, you must not use our Websites. If you are over the age of 13 but under the age of 16, your legal parent or guardian must provide the information on your behalf (you must not provide such information yourself).

We do not knowingly collect Personal Data directly from children under 13. If you are under 13, do not use or directly provide any information on our Websites or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data directly from a child under 13, we will delete that information. If you believe we might have any information directly from a child under 13, please contact us using the information set forth in the “Contact Information” Section below.

4. INFORMATION WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED

At CliniContact, we gather various types of information about you, including data that can identify you directly, information that pertains to you but doesn't personally identify you, and data that we combine with that of other users. This encompasses information collected directly from you or through automated collection technologies.

In General:

As part of our Website usage, we collect multiple types of information from users ("Personal Data"), which may include:

• Personally identifiable details such as name, postal address, email address, telephone number, date of birth, medical history, and any other information allowing online or offline contact.
• Information about you that doesn't personally identify you, such as traffic data, location data, logs, communication data, resources accessed and used on the Websites.
• Information about your internet connection, as well as the equipment you use to access our Websites and usage patterns.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through our Websites. This includes information collected through cookies, web beacons, and other tracking technologies, such as usage details and IP addresses.

Information You Provide to Us:

The information we collect on our Websites includes:

• Details you fill in forms on our Websites, such as when registering, completing forms, using our screeners, or requesting services. This also encompasses additional information requested during promotions or when reporting problems.
• Records and copies of your correspondence with us, including email addresses.
• Your responses to surveys conducted for research purposes.
• Your search queries on our Websites.

The Personal Data we collect from you is necessary for entering into a contract with CliniContact, for us to fulfill our contractual obligations, and to provide you with our products and services. Failure to provide such Personal Data or withdrawing your consent to our data processing may result in us being unable to enter into the contract or fulfill our obligations to you.

Information We Collect Through Automatic Data Collection Technologies:

While you navigate and interact with our Websites, we employ automatic data collection technologies to gather specific information about your browsing actions, device, and patterns. This includes:

• Details of your visits to our Websites, such as traffic data, location data, logs, and communication data.
• Information about your computer and internet connection, such as your IP address, operating system, and browser type.

The information collected automatically may include Personal Data, which we may maintain or associate with other Personal Data collected through different means or received from third parties. This helps us improve our Websites and deliver better, personalized services by enabling us to:

• Estimate audience size and usage patterns.
• Store information about your preferences to customize our Websites according to your interests.
• Enhance search speed and efficiency.
• Recognize you when you return to our Websites.

The technologies we use for automatic data collection include:

• Cookies: These small files are placed on your computer's hard drive. Unless you adjust your browser settings to refuse cookies, our system will issue cookies when you visit our Websites. You can manage your cookie preferences through your browser settings.
• CliniContact ensures that cookies and similar tracking technologies comply with applicable data protection regulations. Users can opt out of cookies via browser settings or through designated opt-out mechanisms provided by [Google, Facebook, etc.].
• Flash Cookies: Certain features on our Websites may utilize local stored objects, also known as Flash cookies, to collect and store information about your preferences and navigation.
• Web Beacons: Our web pages may contain small electronic files called web beacons, which assist in counting users who visit those pages and provide related website statistics, such as content popularity and server integrity verification.

Additionally, we use the following technologies:

• Google Analytics: We employ Google Analytics, a web analytics service provided by Google, Inc., to collect information regarding your website usage. Google Analytics uses cookies to analyze user behavior. You can find more information about how Google uses data collected through our Site on their website.
• Google Adwords and Facebook Ads: We utilize remarketing services through Google Adwords and Facebook Ads to improve our audience targeting and promote our services across the Internet. These services may display tailored banner ads based on your previous interactions with our Sites. You can opt out of Google Remarketing Ads and Facebook Ads through their respective websites.
• Blog/Forum: Our website features publicly accessible blogs and community forums. Please be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@clinicontact.com.
• Links to Third-Party Websites: Our website includes links to other websites with different privacy practices. When you submit personal information to these websites, their privacy statement governs your information. We encourage you to review the privacy policies of any website you visit.

Third-Party Use of Cookies and Tracking Technologies:

Certain content or applications on our website may be provided by third parties, such as advertisers, ad networks, servers, content providers, or application providers. These third parties may use cookies or other tracking technologies in conjunction with web beacons to collect information about your online activities and offer interest-based (behavioral) advertising or targeted content. We do not control these third parties' tracking technologies or their usage. If you have questions about any advertisements or targeted content, please contact the responsible provider directly.

5. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We have lawful reasons for processing your Personal Data, which include processing based on our legitimate interests (taking into account your rights and freedoms), fulfilling contractual obligations, complying with the law, and obtaining your consent.

If you are located in the European Union, the processing of your Personal Data is only lawful if it complies with the applicable data protection laws. We have a lawful basis for each processing activity, except when an exception applies, as explained below:

• Consent: By using our Websites, you give your consent to the collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please refrain from using the Websites.
• Legitimate Interests: We process your Personal Data when necessary for our legitimate interests. We balance our legitimate interests with your rights and freedoms, and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests include facilitating communication between CliniContact and you, facilitating communication between you and third parties, improving our Websites, protecting our IT infrastructure and intellectual property, detecting and preventing fraud and other unlawful activities, and promoting our business.
• Fulfillment of Contractual Obligations: We process your Personal Data to fulfill our contractual obligations to deliver goods and services to you.
• Compliance with Legal Obligations: We may process your Personal Data when required or permitted by law, such as to comply with government inspections, audits, and requests, respond to legal processes, protect our interests, and pursue our legal rights and remedies.

6. SPECIAL CATEGORIES OF INFORMATION

We may process sensitive Personal Data with your explicit consent or when necessary to fulfill our legal obligations or protect our legitimate interests.

Certain Personal Data processed by CliniContact may be considered sensitive, such as information revealing your racial or ethnic origin or health-related data. We process this information only with your explicit consent, or when necessary to fulfill our legal obligations or protect our legitimate interests.

7. HOW WE USE YOUR INFORMATION

We use your Personal Data for various purposes, including providing our Websites to you, fulfilling your information requests, enforcing contractual rights, and notifying you about changes.

We use the information we collect about you or that you provide to us, including Personal Data, for the following purposes:

• Providing our Websites and presenting their contents to you.
• Offering you information, products, or services that you request from us.
• Carrying out our contractual obligations and enforcing our rights under contracts.
• Notifying you about changes to our Websites or any products or services we offer.
• Fulfilling any other purposes described at the time you provide the information.
• Fulfilling any other purpose with your consent.

CliniContact processes personal data only for purposes consistent with the purposes for which it was collected, as outlined in this Privacy Policy, unless you provide explicit consent for additional uses.

8. DISCLOSURE OF YOUR INFORMATION

We do not share, sell, or disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may share your Personal Data with specific third parties under certain circumstances.

We disclose your Personal Data to the following parties:

• Our subsidiaries, affiliates, and third-party service providers who support our business operations.
• Our clinical research partners if you have consented to be contacted about our programs and services, including patient referrals for clinical trials.
• Companies that merge with us, acquire us, or are involved in a change in our company's structure.
• When required to comply with our legal obligations or enforce our rights.
• With your consent.

We do not share, sell, or disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may share aggregated information about our users without any restrictions.

We may disclose your Personal Data:

• To our subsidiaries, affiliates, and contractors who provide support services, including IT and infrastructure.
• To our clinical research partners if you have opted in to be contacted about our programs and services, including our patient referrals program for clinical trials.
• To potential or actual buyers or successors in the event of a merger, acquisition, or similar transaction involving CliniContact's assets.
• To third parties with your consent for marketing purposes. We require these third parties to keep your Personal Data confidential and use it only for the purposes we disclose to them.
• To fulfill the purpose for which you provided the information.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Data:

• To comply with court orders, laws, or legal processes.
• To enforce our terms of use and other agreements.
• When we believe disclosure is necessary to protect the rights, property, or safety of CliniContact, our customers, or others.

CliniContact ensures that any third parties processing personal data on our behalf adhere to the Data Privacy Framework principles or other legally recognized data protection measures. Contracts with such parties include provisions that require them to use personal data solely for the intended purposes and to protect it adequately.

9. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We provide options for you to opt out of certain activities, such as the use of tracking technology, disclosure of your Personal Data for third-party advertising, and receiving our promotional offers.

We do not control the collection and use of your information by third parties as described in the "Disclosure of Your Information" section. However, these organizations are contractually obligated to use the data solely for providing services to us and maintain its confidentiality. These third parties may aggregate the collected information with data from other customers for their own purposes.

Additionally, we strive to give you control over your Personal Data by offering the following mechanisms:

• Tracking Technologies and Advertising: You can configure your browser to refuse cookies or receive alerts when cookies are being sent. Please note that disabling or refusing cookies may limit access to certain parts of our Websites.
• Disclosure of Your Information for Third-Party Advertising: We only share your Personal Data with unaffiliated third parties for promotional purposes with your explicit consent. If you wish to change your consent choice, you can contact us using the information provided in the "Contact Information" section below.
• Promotional Offers from CliniContact: We only use your contact information to promote our own or third parties' products and services with your explicit consent. If you do not want us to use your contact information for promotional purposes, you can update your email preferences using the "unsubscribe" link in the emails we send or by contacting us using the information in the "Contact Information" section below. If you have received a promotional email, you can request to be excluded from future email distributions by replying to that email.

California residents may have additional rights and choices regarding their personal information. Please refer to the "Your California Privacy Rights" section for more details.

10. YOUR RIGHTS AND ACCESS TO YOUR INFORMATION

You have certain rights under data protection laws, including the right to access and update your Personal Data, restrict its use, transfer it to another controller, withdraw your consent, and request the erasure of certain Personal Data. You also have the right to lodge a complaint with a supervisory authority regarding our handling of your Personal Data.

To exercise your rights, you can review and modify your Personal Data by contacting us using the provided Contact Information. If you notice any errors or changes in your Personal Data, you can inform us to ensure its accuracy and completeness. However, we may be unable to accommodate your request if it violates any legal requirements or results in incorrect information.

You have the right to restrict our processing of your Personal Data under certain circumstances, such as contesting its accuracy, if the processing is unlawful, or if we no longer need it but are permitted to retain it by law.

If you have provided your consent and your Personal Data is processed based on that consent, you can withdraw it at any time by closing your account. Please note that withdrawing your consent does not affect the lawfulness of processing based on your consent prior to its withdrawal, or processing based on other lawful bases.

You have the right to request the deletion of all your Personal Data. However, we can only delete your Personal Data by also deleting your user account, and we will do so when we no longer have a legal basis for processing your Personal Data or when it is determined to have been unlawfully processed. We may not delete information if it would violate any legal requirements or result in incorrect information. In some cases, certain data may remain in backups as per our disaster recovery policies.

You can also provide us with instructions regarding the storage, erasure, and sharing of your Personal Data after your death.

If you have concerns about your privacy, we encourage you to contact us directly before lodging a complaint with the supervisory authority. We will work with you to address your concerns.

If you exercise any of these rights, we may ask for additional information to verify your identity. We reserve the right to limit or deny your request if you fail to provide sufficient information or if it conflicts with legal or business requirements. Please note that making unfounded, repetitive, or excessive requests may result in a fee, as permitted by applicable law.

Under the Data Privacy Framework, individuals have the right to:

• Access their personal data processed by CliniContact.
• Correct inaccuracies in their personal data.
• Limit the processing of their personal data under certain circumstances.

To exercise these rights, please contact us using the information provided in the 'Contact Information' section.

11. STATE-SPECIFIC PRIVACY RIGHTS

Residents of certain states may have additional rights regarding the use of their Personal Information. To learn about any additional rights applicable to you as a resident of your state, please refer to the privacy addendum attached to this Privacy Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have additional rights under the California Privacy Notice. California Civil Code Section 1798.83 (California's "Shine the Light" law) permits you to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the provided Contact Information.

12. DO NOT TRACK SIGNALS

We do not track your online activities across third-party websites or services, and we do not honor "do not track" signals sent by some browsers.

13. DATA SECURITY

While we implement security measures to protect your Personal Data, transmitting information over the Internet is not completely secure. You can help protect your information by keeping your password confidential. We are not responsible for the circumvention of privacy settings or security measures on our Websites.

14. CONSENT TO PROCESSING OF PERSONAL DATA IN OTHER COUNTRIES

Your Personal Data may be processed and stored outside your home country, including in the United States. We only do this when permitted by law and when appropriate safeguards are in place to protect your Personal Data.

If you are a resident of the European Economic Area (EEA), we may transfer and store your Personal Data outside the EEA, including in the United States. By using our Websites, you consent to the storage and processing of your Personal Data, acknowledging that it may be transferred to countries that may not provide an equivalent level of protection. We use Data Protection Agreements and, where applicable, Standard Contractual Clauses to ensure the protection of your Personal Data. You have the same rights under these Standard Contractual Clauses as if your data was not transferred. You can request a copy of the Data Protection Agreement by contacting us through the provided Contact Information.

15. DATA RETENTION PERIODS

We retain your Personal Data as long as your account remains open. Even after account closure, we may retain your Personal Data for legal purposes, on our backup systems, and to protect our rights.

After closing your account, we may retain your Personal Data to comply with legal requirements, store it in our backup systems, protect our legal interests, pursue legal rights and remedies, and retain anonymized or aggregated data indefinitely.

16. CHANGES TO OUR PRIVACY POLICY

We will notify you of any material changes to our Privacy Policy and invite you to review and accept the changes. It is your responsibility to keep your contact information up to date and regularly check our Websites and Privacy Policy for any updates.

CliniContact conducts annual reviews to verify its ongoing compliance with the Data Privacy Framework principles and renews its self-certification with the U.S. Department of Commerce.

17. CONTACT INFORMATION

For any questions, concerns, complaints, or requests related to your Personal Data, please contact us through the provided Contact Information or the "Contact Us" page on our Websites.

For unresolved privacy complaints under the Data Privacy Framework, individuals may contact their local EU Data Protection Authority.
This service is provided free of charge.

To find the contact details for your local EU Data Protection Authority, please visit:
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

18. Independent Dispute Resolution

If an unresolved complaint cannot be addressed through the designated independent recourse mechanism, individuals may invoke binding arbitration under the Data Privacy Framework as a final resort. Details on this process are available at EU-U.S. and UK Extension DPF Program Binding Arbitration Mechanism | ICDR.org.

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