Effective 18 January, 2015

Trialsphere (the “Site”) is a networking web site. Our goal is to provide a platform for individuals who have expressed interest in a clinical trial participation to connect with research professionals conducting clinical trials (the “Service”). Trialsphere defines a ‘clinical trial’ as “Any research study that prospectively assigns human participants or groups of humans to one or more health-related interventions to evaluate the effects on health”. Trialsphere defines “Research Professional” as ”Any individual who is gainfully employed by a clinical research site, academic university, hospital, physician’s office, clinical research organization (CRO), or a pharmaceutical company. Users of this Service may provide personal information relating to health conditions, demographics, and contact information. This Policy informs you of how Trialsphere collects and uses personal information by means of this Service. This policy also states our policy regarding the disclosure of personal information. We reserve the right to change, modify, add, or remove provisions of this Privacy Policy, and any changes to this Privacy Policy will be posted here. Please refer back to this Privacy Policy regularly because your use of this Site signifies that you agree to be bound by this Privacy Policy, as might be amended periodically. Registering as a Member on Trialsphere requires a valid email address. By registering as a Trialsphere Member, you assume control over which information, including personally identifiable information is shared with other site users.

What Information Do We Collect?

Shared Data

Some of the information that Members provide about themselves may be shared with the Trialsphere community and may be viewable by the general public. Examples of Shared Data include: Biographical information, e.g. photograph, biography, age, location, general notes,Study of Interest,Treatment information, e.g. type of treatment or name of medication,Information shared via free text fields, e.g. forums, chat rooms, instant messages, emails, Connections to other site members, e.g. invited connections, Research Professional connections, activity feeds, subscriptions, group memberships. Some shared information could be used to reasonably identify Members (“Personal Information”), including date of birth, photograph, and user name. Information shared through a free text field, such as, forums, chat rooms, instant messages, email messages and photos or images, shall be treated as Shared Data and is voluntarily provided by that user to be seen by other Trialsphere members and the general public.Public profiles may be indexed or stored by Internet search engines (e.g. Google) or other independent sites, which means a Member’s Shared Data, including any Personal Information shared, may come up in the search results by anyone on the Internet.Members should expect that every piece of information they submit (even if it is not currently displayed), except for Restricted Data, may be shared with the other Trialsphere Members and the general public.Restricted DataWhen a member enters Personal Information, including a valid email address and date of birth, as part of registering to use Trialsphere, that Personal Information is treated as Restricted Data. Trialsphere does not display the user’s email address by default. Although Trialsphere considers this data restricted, a members email address may become public in the following ways:(a) the user unknowingly publishes their email address,(b) Trialsphere or its hosting company’s database is breached by an unauthorized individual or program, (ie. hacking),(c) Trialsphere experiences a technical malfunction,(d) Trialsphere inadvertently publishes a user’s email address during the course of website maintenance and development,(e) if a user provides their email address to another user,(f) Trialsphere shares or discloses a Member’s data where required by law or to comply with legal process, or (g) In the event Trialsphere goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, the Shared Data and Restricted Data, including Personal Information, might be among the assets transferred. Members will be notified via this Site of any such change in ownership or control of Personal Information.

Cookies

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, improve your browsing experience and help ensure marketing you see online is more relevant to you and your interests. Two types of cookies are used on Trialsphere.

Session Cookies:

Temporary cookies that persist until you log out of the website or close your web browser. Session Cookies do not store any Personal Information, only a unique visitor ID number that may be used to ensure Members are properly authenticated and can view site information.

Persistent Cookies:

These cookies are stored in your browser for much longer, even after you leave the Site. Persistent Cookies also do not store Personal Information. Persistent Cookies store preferences that should persist from visit to visit. They also enable the site administrator to understand how Members use the Site.

How do we use your data?

How Shared Data is Used Trialsphere allows verified Research Professionals to utilize the features which enable them to search member profiles and communicate with Research Volunteer Members. Research Professionals may contact Research Volunteer Members through instant messages, private messages, forums and chat rooms. Though Research professionals may contact you through one of these methods, your email address provided at registration will not be intentionally shared by Trialsphere. Otherwise, we do not share, sell, or otherwise disclose personal information that is individually identifiable (including your e-mail or your personal information) to any other company without your prior consent, except as required by law (see Legal Process, below). For example, we do not rent our Member list to other companies. How Restricted Data is Used Restricted Data is not automatically shared with, sold to, or displayed for other Members or Partners. Specific instances where Restricted Data may be used include the following: If a Member registers with, or upgrades to, a Research Professional account, the Member’s full name, affiliation and contact information may be viewable via My Profile;If a Member makes a request, Trialsphere may use Restricted Data, including sharing the Member’s Restricted Data with software/service vendors, for the purpose of fulfilling the request. Examples include requesting to receive the Trialsphere newsletter via email, requesting an email response from the Trialsphere support team etc. Security Trialsphere requests “Research Professional” members to submit a “Site Verification” form, in order to obtain a “Verified Researcher” badge. This badge is displayed on the members profile and is located on the members profile image, e.g avatar. Trialsphere makes reasonable efforts to verify that the member is affiliated with a legitimate business in the clinical research industry. The “Verified Researcher” badge is a precautionary measure taken by Trialsphere to prevent Members from misrepresenting themselves and misleading other users. Although this measure is in place, Trialsphere cannot guarantee the identity of any Members with whom a Member may interact in the course of using the Site or who may have access to a Member’s Shared Data. Additionally, we cannot guarantee the authenticity of any data that Members may provide about themselves. Trialsphere employs commercially reasonable security measures consistent with standard industry practice, to safeguard personal and other information collected through this Site. We believe these commercially reasonable practices provide adequate security to protect against the loss, misuse, or alteration of the information we collect on our Site.

Risks and Benefits

It is possible that a Member could be identified using information shared on Trialsphere (and/or in conjunction with other data sources). A Member could be discriminated against or experience repercussions as a result of the information shared. For example, it is possible that employers, insurance companies, or others may discriminate based on health information. Members should understand that anyone can register at Trialsphere and view all Shared Data. Please protect the privacy of other Trialsphere members. Members are free to skip any non-required questions or data fields contained during registration or elsewhere on the Site. You are not required to upload a profile photo. Members are also free to stop using this service at any time. If a Member chooses to deactivate his/her account, Trialsphere will not sell the data in that account.

Access

You may access and change personal information on your profile at any time by accessing your password-protected registered user information.

Children’s Personal Information

Consistent with the Children’s Online Privacy Protection Act: We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act). We do not collect any information from anyone under 18 years of age. The Site and the Service is directed to people who are at least 18 years old. In the event that a child under the age of 18 posts personal information in a public forum such as a message board, we will attempt to delete that information as soon as possible.

IP Address and Log Files

We may use your IP address to administer the Service, identify problems with our server, analyze trends, or improve usability.

Sale or Merger

If Trialsphere is sold to or merges with another company not owned by Trialsphere, some or all of the personal information collected from this Site may be transferred to the acquiring company. Trialsphere will seek to require the acquiring company to use any personal information reassigned by this Site in a manner which is consistent with this Privacy Policy. Trialsphere cannot guarantee that it will be able to impose that requirement, or that the acquiring company will abide by the current policy. If you do not wish the personal information you provide to be subject to this possibility, you should terminate your membership by notifying admin@trialsphere.com. Please include the word “Terminate” in the subject line.

Legal Process

Trialsphere may be required to disclose your personal information to the government or other entities connected with a legal process, such as in response to a valid subpoena, court order in judicial or regulatory proceedings, or pursuant to a valid law enforcement investigative requirement. Questions about the Privacy Policy If you have questions or comments about our Privacy Policy, please contact us at: Trialsphere Attn: Privacy Issues admin@trialsphere.com Update 7/22/2015: “How Shared Data is Used” – Changed to reflect that Research Professional users are no longer charged a fee to search TrialSphere users.