All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our web site prior to the change becoming effective and update the ‘effective date’ at the top of this page.

Privacy Matters ClinicalTrialIQ understands that health is a very personal, private subject, and we want you to feel as comfortable as possible visiting our website and using its services. This statement sets forth our Privacy Policy and advises you about the information we collect, how we collect it, how we secure and protect it, and what choices you have about how that information is used.

ClinicalTrialIQ knows that privacy and security are important to you and to all of our users. Earning and keeping your trust and respect is of primary importance to us. We pledge to protect your privacy and keep your personal information secure and confidential. We will not give, sell or distribute your information to any other organization for promotional purposes. Be assured that the personal information you share with ClinicalTrialIQ is kept strictly confidential and fully secure unless you, the user, specifically request otherwise.

The personal information we collect helps us to provide the best possible information on clinical trial options.

Privacy Officer If you have questions about this privacy policy or wish to register an inquiry or complaint, please contact the ClinicalTrialIQ Corporate Privacy Officer via email at [email protected]

Note that for purposes of compliance with the requirements of the General Data Protection Regulation (GDPR), the ClinicalTrialIQ Corporate Privacy Officer also serves as the Data Protection Officer.

Information We Collect We collect information from you in five distinct areas, as outlined below:

Non-Personally Identifying Information about visitors to our Sites and Applications Personally Identifying Information Information you supply when you create an account with user name and password Responses to questions you answer in Patient Profiles Your requests to be contacted by us and your interaction with our Clinical Trial Navigators Only at your request, we will share your referral information with a trial site so they can contact you about a trial you’ve matched ClinicalTrialIQ is solely responsible for collecting and storing all personally identifiable information provided by visitors to our trial information, matching and referral services, either through www.ClinicalTrialIQ.com or through one of our partner web sites, mobile applications, or services (our “Sites and Applications”).

Please be aware that websites to which ClinicalTrialIQ links may collect personally identifiable information about you and may have different practices and policies concerning privacy issues. This Privacy Policy does not cover the information practices of other websites.

How We Protect Your Information ClinicalTrialIQ keeps all your personal information confidential in our secure system. No other user can view or change your information without your Username and Password. ClinicalTrialIQ puts you, the user, in control of your personal information. You can edit, update or delete information that you have provided by sending an email to [email protected]

Only authorized ClinicalTrialIQ employees (with special system access controls and passwords) are permitted or able to access your personal information. All ClinicalTrialIQ employees must abide by our code of conduct, security and privacy policies and those who violate this policy are subject to disciplinary action, up to and including termination.

ClinicalTrialIQ wants your personal information to remain as secure as reasonably possible. That is why we have a system at ClinicalTrialIQ that combines leading technical safeguards and security policies. You can request more information about the technical and policy elements we use to protect your data by writing to us at [email protected]

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your information. If a breach of your personal information occurs, we will provide notifications as per regulatory requirements. In that event, ClinicalTrialIQ would no longer have the ability to protect your information. By using our Site and Applications you acknowledge that there is risk that the information you share with us may be compromised, despite our efforts to protect it.

How to Request, Update or Delete Your Information By default, personally identifying information is maintained in our system for three years from your last interaction with our Sites and Applications or our services.

You may Delete your account at any time by sending an email to [email protected] with the subject “Delete My Account”. This will remove your personally identifying information from our database. It will also remove or detach any Patient Profiles you created from identifying information that was in your account.

You may update your information via features of our Sites and Applications. Existing users can log into their account to review, correct, update or delete inaccuracies to the information in their user account (including updating email address and changing password) and in any saved Patient Profiles. If you are unsure of how to update any of your previously provided information, write to [email protected] for assistance.

You may also write to [email protected] to request a copy of all personally identifiable and/or confidential data that we collected from you.

How We Use Your Information The section above entitled “Information We Collect” includes references to how we use the information that we collect in each of the areas described. Some of that information is repeated in this section along with additional explanations of how we use the information that we collect.

Non-Personally Identifying Information We use non-personally identifying information to administer our Sites and Applications, analyze usage, and improve user experience. We may combine this information with personally identifying information to further the analysis we do. We may provide this information to third party data processors, such as Google Analytics to assist us in interpreting this data as a whole or in parts. You may use the Google Analytics Opt-Out Browser Add-On available by clicking here. We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for our Sites and Applications.

Personally Identifying Information We use personally identifying information to support the features and services that you choose to use which explicitly call for you to provide personally identifying information – as detailed below.

In accordance with the provisions of this Privacy Policy we will not give, sell, or distribute any of your personal information as outlined in this section, without your explicit permission.

Account Email Address and Name We use your email address to enable communication with you for features such as forgetting a password. For your security, we will attempt to verify your ownership of your email address by sending you via email a link to click and this verification will be required for some features. We will use the first and last name information that you provide to address you in relevant contexts and correspondence.

When creating your account, you are explicitly asked if we may reach out to you via email to provide additional information in the future that may be relevant to your clinical trial search. Note that this only authorizes ClinicalTrialIQ, not any partners or third parties, to do this. In accordance with the provisions of this Privacy Policy we will not give, sell, or distribute your personal information – including your email address or name - without your explicit permission.

We do not use your email alone or in conjunction with any other data to identify you in any other way.

You may delete your account at any time by writing to us at [email protected]

Contact Information When you use our Request a Contact or Contact Us features or otherwise share contact information with us via phone or email, we use that information to facilitate the communication channel between you and our Clinical Trial Navigators. Such communication may include both phone calls and emails. We will do our reasonable best to respect your expressed preferences for phone and/or email communication, preferred times to call, time zone information, etc.

With your explicit permission, we will share contact information that you provide with a Trial Site to facilitate the introduction of the two of you. In accordance with the provisions of this Privacy Policy we will not give, sell, or distribute your personal information without your explicit permission.

You may delete all contact information associated with you from our systems at any time by writing to us at [email protected]

Profile / Questionnaire Information We use the Patient Profile / Questionnaire information that you provide to help you identify potentially relevant clinical trials.

We may use your questionnaire responses in a non-personally identifying manner, in aggregate for analysis about patient populations and their activity on our Site and Applications and with our services. We may share this aggregate, non-personally identifying information with third parties.

You may delete individual Patient Profiles at any time using the “delete” feature in the page that displays your Patient Profiles. If you delete your account (which you can do at any time by writing to us at [email protected]), that deletes all of your Patient Profiles as well. Deleted Patient Profiles may still be accumulated in aggregate data analysis.

Disclosure to Third Parties Except as set forth in this Privacy Policy, we will not disclose to unrelated persons or entities any information you provide to ClinicalTrialIQ that could be used to identify or contact you ("personal information"), without your explicit permission. Any personal information provided to persons or entities affiliated with ClinicalTrialIQ will be treated in accordance with the terms of this Privacy Policy, unless you are otherwise notified. In the following limited circumstances we will consider, and may release, personal information to third parties: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or (3) if ClinicalTrialIQ is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

With your specific consent, ClinicalTrialIQ may provide your personal information to third parties in order to assist you in finding a clinical trial that may be appropriate for you. Personal information will only be shared with third parties with your specific consent, and will be transmitted to those third parties using specialized encryption software. ClinicalTrialIQ may also enclose personal information in a message sent to you through email or regular mail at your request. These messages -- which may take the form of a general update or a specific response to your questions -- will be sent to the email address or physical location you specify.

ClinicalTrialIQ may provide non-identifying (aggregate) information about our users to third parties. For example, we might inform third parties about the number of users of our site who are interested in information about a particular disease category, or information about the number of users who live in a particular geographic region. We may also provide aggregate information to entities for the purpose of determining whether additional clinical trials are needed in a particular disease area. Depending on the circumstances, we may or may not charge third parties for the right to access this aggregate information.

Except as provided in this section, ClinicalTrialIQ will not disclose to unrelated persons or entities any personal information that you provide to us. Please note that you are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to your username and password or Patient Profile. It is your sole responsibility to: (1) control the dissemination and use of usernames and passwords; (2) authorize, monitor, and control access to and use of your usernames and passwords; and (3) promptly inform ClinicalTrialIQ of any need to deactivate a username or password. You grant ClinicalTrialIQ the right to receive, transmit, monitor, retrieve, store, and use your personal information, including information that may be privileged and confidential under applicable state and federal laws, in connection with the operation of or maintenance of your Patient Profile and account. ClinicalTrialIQ cannot and does not assume any responsibility or liability related to the accuracy or inaccuracy of the information you provide to us. ClinicalTrialIQ also cannot and does not assume any responsibility or liability related to your or third parties' use or misuse of information transmitted or received using ClinicalTrialIQ.

Privacy of Children ClinicalTrialIQ does not collect, maintain, store, or disclose personal information about children under the age of 13.

Your Consent By creating a username and password (registering) and filling out a Patient Profile, you grant ClinicalTrialIQ the right to receive, transmit, monitor, retrieve, store and use your personal information, including information that may be privileged and confidential under applicable state and federal laws, in connection with the operation or maintenance of these features.

ClinicalTrialIQ cannot and does not assume any responsibility or liability related to the accuracy or inaccuracy of the information you provide to us. ClinicalTrialIQ also cannot and does not assume any responsibility or liability related to your use or misuse of information transmitted or received on the site.

ClinicalTrialIQ has the right to suspend or eliminate your right to use this site and to remove any information that you have placed on our site. ClinicalTrialIQ may also change this Privacy Policy at any time by posting revisions on our website. Your use of the site constitutes acceptance of the provisions of this Privacy Policy and your continued use of the site after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised policy, please exit this site immediately.

If ClinicalTrialIQ decides to materially change how we use personal information or your personal health information, we will notify you by posting a notice on the website, homepage or by sending you an email if you consented to receive email communications from us prior to the changes taking effect.

EU-U.S. Privacy Shield / Swiss-U.S. Privacy Shield ClinicalTrialIQ complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States. The parent company of ClinicalTrialIQ, Carebox Healthcare Solutions Inc., has certified (in a process that explicitly and fully includes ClinicalTrialIQ) to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Policies related to our participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework can be found on our Privacy Shield Policy page.

GDPR This Privacy Policy was updated in advance of the enforcement deadline of the General Data Protection Regulation (GDPR) as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. ClinicalTrialIQ is a Data Controller as defined in the GDPR and is responsible for ensuring that appropriate GDPR-compliant agreements are in place with all Data Processors that we engage. ClinicalTrialIQ has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

Tell Us What You Think If you have any questions about this privacy policy or wish to register an inquiry or complaint, please contact the ClinicalTrialIQ Corporate Privacy Officer via email at [email protected]

Revised: February 4, 2019