NextPRO Insights LLC

Privacy Policy

Last updated: May 6, 2022

NextPRO Insights, LLC (“NextPRO,” “we” or “us”) provides patient recruitment services for Phase I clinical trials. We respect your privacy and is committed to protecting your privacy. This privacy policy (“Policy”) describes how we, in our capacity as a “controller” or a “business” under applicable laws, process your personal information.

This Policy is incorporated into and made part of our Terms and Conditions. Please read our Terms and Conditions, and this Policy carefully. It is your choice whether or not to provide personal information to us. If you choose to do so, you are giving us your express consent to use, process, and disclose your personal information as set forth in this Policy. If you choose not to provide your personal information to us, you may not be able to use the full extent of our Websites.

1. Scope of this Policy

This Policy is intended to describe how we process personal information relating to:

· the use our websites that link to this Policy, including www.nextPROinsights.com, (“Websites”),

· when you sign up to receive information about participating in Phase 1 studies, and

· when you communicate with us electronically.

This Policy does not apply to information that:

· we collect offline or through any other means not listed above,

· is collected by any third party, including through any application or content that may link to or be accessible from or on the Websites, and

· we collect from our employee and non-employee workers, job applicants, job candidates, or independent contractors.

In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identified such as a name, an identification number, location data, and online identified or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.

Personal information is required for us to be able to provide certain features of our Websites or services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to service providers that help us to provide those services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use certain features of our Websites or services.

Our Websites may contain links that enable you to share content on social media, links to other websites, and link to third-party apps that do not operate under this Policy. These third-party services, websites, and apps may independently solicit and collect personal information from you. We encourage you to review the privacy statements of all third-party websites you visit to understand their privacy practices.

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review each such third party’s privacy statement and other otherwise understand its privacy practices, before providing personal information directly to it.

2. Personal Information We Collect and How We Collect It

We collect personal information from and about users of our Websites. As described in further detail below, you provide some of this information directly, such as when you complete a online forms or contact us. We also may collect some of your information, such as your IP address, automatically when you visit and use our Websites.

A. Information You Provide to Us

We ask for and may collect personal information about you such as your name, e-mail address, phone number, and your location (city, state, and/or country). The most common of these circumstances where you would provide personal information include the following:

· Signing up to receive information about participating in Phase I studies: We may collect your name, email address(es), phone number(s), and location information (city, state, and/or country).

· Contacting us: When you contact us, we may ask you to provide, or confirm, personal information, such as your email address, so that we can respond to your request.

B. Information that We Collect From You On Our Websites

We may use various technologies to automatically collect information from your computer or device and about your activities on our Websites. This information may include your IP address, location data, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.

The technologies we may use for automatic information collection include:

· Facebook Pixel. We use the Facebook pixel, which is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions people take on the Website. We have a pixel code on the header of the Website. When someone visits the Website and takes an action (like completing a form), the Facebook pixel is triggered and reports this action. By accepting this Policy, you consent to the processing of your data by Facebook.

· Google Analytics. We may use Google Analytics provided by Google Inc. Google Analytics uses cookies to collect the information identified above, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Website. On subsequent repeated visits to the Website, frequently used information is automatically displayed for you. We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Website is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. Google will use this information to evaluate your use of the Websites. Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. By accepting this policy, you consent to the processing of your data by Google. You can learn about how Google Analytics collects and processes data here.

· Cookies. When you visit our Websites, we may assign your device one or more cookies to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Websites. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Websites may not function properly.

3. How We Use Personal Information

While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

We may use information that we collect about you to:

· recruit and connect you with Phase 1 study sponsors, contact you regarding current and future clinical trials, share your contact information with Phase 1 study sponsors (Legal basis: performance of a contract with you and/or your consent)

· deliver the services or information that you have requested (Legal basis: performance of a contract with you, our legitimate interests, and/or your consent)

· perform research and analysis about your use of, or interest in, our Websites (Legal basis: our legitimate interests)

· for service administration where we need to contact you for reasons related to our Websites (for example, contact you in response to your requests, comments, and questions) (Legal basis: performance of a contract with you, our legitimate interests, and/or your consent)

· enforce our terms and conditions (Legal basis: our legitimate business interests and/or compliance with laws)

· manage our business and perform functions as otherwise described to you at the time of collection (Legal basis: performance of a contract with you, our legitimate interests, and/or your consent)

· advertising, marketing and promotional purposes including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate business interests and/or your consent)

· protect against or identify possible fraud (Legal basis: our legitimate business interests and/or compliance with laws)

· for legal compliance purposes (Legal basis: our legitimate business interests and/or compliance with laws)

We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, and for other research, marketing and analytics purposes.

4. Sharing of Personal Information

As discussed more fully below, we share your personal information as necessary to provide the services you request, including sharing information with service providers; when required by law; to protect rights and safety, and with your consent.

We may share personal information with:

· Our service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include customer relationship management software; website hosting; web forms for questionnaires; email marketing vendors; providing customer service; performing business and operations analysis; and supporting our Websites. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

· Phase 1 study sponsors and pharmaceutical companies: We may share your personal information with third parties, such as Phase 1 study sponsors and pharmaceutical companies, that run Phase 1 studies where you have expressed an interest in learning about and/or participating in a Phase I study.

Other situations: We also may disclose your information:

· In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

· When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms and conditions or other agreements or policies.

· In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

· When you provide us with your consent to share your information with third parties.

Third-Party Privacy Policies: Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

5. Your Privacy Rights and Choices

A. How You Can Access, Amend, and Request Deletion of Your Information

You may request to review, update, amend, have deleted, or otherwise access your rights under applicable privacy laws over your personal information that we collected or otherwise maintain subject to certain limitations under applicable privacy laws. You may submit a request to us by using the contact information provided at the end of this Policy.

We will respond to your request as soon as practicable for us and in the timeframes provided under the applicable privacy laws.

B. Your Choices About Collection and Use of Your Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Websites because such information may be required in order for you to participate in a survey, receive a gift card subject to eligibility, or ask us questions.

C. Opt-Out

You may be given a choice as to whether you want to receive marketing or promotional e-mails or newsletters from us. At any time you can choose to no longer receive marketing or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication. You may modify your choice at any time by using the “Opt-Out” link as described above. It may take up to 10 business days for us to process an opt-out request. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

Even if you opt-out of receiving marketing or promotional communications, you may continue to receive other types of transactional and relationship e-mail communications, such as sending you a survey you have elected to participant in.

6. Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law or defined in an agreement. We may retain personal information for longer where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

We will also retain usage data for internal analysis, to strengthen the security, or to improve the functionality of our Websites.

7. Children’s Personal Information

Our Websites are not directed at children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you may not use our Websites or provide your information to us through the Websites or otherwise. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy.

8. Security

The security of your personal information is important to us. We follow generally accepted standards (including by taking physical, administrative, and technical measures) to protect the personal information that we collect and process.

While we are focused on the security of your personal information and follow standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov for information about how to protect yourself against identity theft.

9. International Transfer

The data that we collect from you may be transferred to, accessed, processed or stored in, and subject to requests from law enforcement in, jurisdictions outside of your home jurisdiction, including the United States and other jurisdictions, in which we or our service providers operate. Some of these jurisdictions, including the United States, may not provide equivalent levels of data protection as your home jurisdiction. We have established safeguards to protect personal information that is transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards in place, please contact us as set forth in the Section below entitled “Contact Us.”

10. No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

11. Changes to this Policy

We may modify this Policy from time to time and will notify you of any updates to our Policy by posting the revised Policy on our Websites. The last updated date set forth at the top indicates the last time we revised this Policy. We encourage you to review the Policy each time you visit our Websites to see if this Policy has been updated since your last visit.

12. Additional Information for Residents in Certain Jurisdictions

A. California

In this section, we provide information for California residents as required under California privacy laws, including the California Consumer Privacy Act (the “CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information.

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The Section above entitled “Personal Information We Collect” sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Section above entitled “Personal Information We Collect and How We Collect It,” and for the purposes described in the Section above entitled “How We Use Personal Information.”

If you are a California resident, the CCPA grants you certain rights and imposes restrictions on particular business practices as set forth below:

· Do-Not-Sell: California residents have the right to opt-out of the sale of their personal information.

· Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

· Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Delete are described below.

· Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed and sold about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

o categories of personal information collected;

o categories of sources of personal information;

o business and/or commercial purposes for collecting and selling their personal information;

o categories of third parties with whom we have shared their personal information;

o categories of personal information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and

o categories of personal information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.

· Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

If you are a California resident and would like to make a request to exercise your rights under the CCPA, please contact us as set forth in the Section below entitled “Contact Us.” Please allow forty-five days for a response.

An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, or requests to delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Section below entitled “Contact Us.”

Do Not Track Disclosure

We do not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

B. European Union, European Economic Area, United Kingdom

If you are an individual located in the United Kingdom, European Union or European Economic Area, you have the following rights, under the UK Data Protection Act of 2018 or GDPR, regarding your personal information:

· Right of access. You have the right to request access to your personal data, obtain a copy of the personal data held by us, and receive information regarding the processing of your personal data.

· Right to rectify. You have the right to the rectification of inaccurate or incomplete personal data concerning you.

· Right to erasure. In certain circumstances, you have the right to obtain from us the erasure of your personal data unless the processing is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

· Right to restrict processing. In certain circumstances, you have the right to restrict the processing of your personal data in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except we may process your personal information for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person.

· Right to object to direct marketing. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications.

· Right to withdraw consent. If the lawful basis for processing your personal information is your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

· Right to data portability. In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.

· Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority, in particular in the UK or the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.

If you would like to make such a request, please may contact us as set forth in the Section below entitled “Contact Us.” To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

13. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us by e-mail or postal mail as follows:

NextPro Insights, LLC

Attn: Customer Service

221 N. Broad Street, Suite 3A

Middletown, DE 19709

Email: vlin@nextproinsights.com