Effective Date: December 1, 2024

SiteRx Privacy Policy

This Privacy Policy describes the types of information SiteRx, Inc. (“SiteRx,” “we,” “us,” or “our”) will receive about you in connection with conducting review and analysis to help determine your potential eligibility to participate in current and/or prospective studies (“Studies”) by clinical research sponsors (“Sponsors”), as well as how we use such information and any additional information you authorize us to obtain from you or your healthcare provider(s), what choices are available to you regarding collection, use, and distribution of such information, our efforts to protect such information, and with whom such information may be shared. We also assist Sponsors, their vendors and service providers, and clinical research sites to facilitate the recruitment of individuals to participate in the Studies.

As a general note, SiteRx operates as a data controller of the identifiable information we collect directly from users, and we process such information: (a) to match users with Studies for which they may be a good fit; and/or (b) for the purposes outlined herein where we are not acting on specific instructions from a Sponsor nor processing data on a Sponsor’s behalf.

Information Shared with Us During Review Process

Our information collection is limited to what is necessary and disclosed to users at or before the time of collection. During the review process, we may receive identifiable information about you and your health on behalf of a Sponsor that is limited and necessary to provisionally evaluate your potential eligibility for participation in the Studies. As a reminder, such information may include your:

Name
E-mail address
Phone number
Address
IP address
Identification Number
Location Data (e.g., ZIP or postal codes)
On-line Identifier
Sensitive personal information that may include one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social identity of a natural person, such as your: medical conditions and its severity, medical test results, age, height & weight, lifestyle/habits (e.g., exercise, smoking), prior medical procedures, medical symptoms, ethnicity, existing participation status or willingness to participate in a clinical trial, choice of physician or medical clinic, requested or actual appointment date and time, etc.

Uses and Disclosures of Your Personal Information

To facilitate your screening process for the Studies by clinical research sites, SiteRx will use the identifiable information about you and your health from your medical records provided by you, or if applicable, received by us from your physician(s). If we requested your medical records on your behalf, the Authorization Form/Request for Medical Records that you signed authorizes your physician(s) and/or their agents and representatives to disclose your medical records to us.

SiteRx will use and disclose the identifiable information about you and your health provided to us by a Sponsor or its vendors and service providers, and the identifiable information about you and your health that is included in your medical record (collectively, your “Personal Information”) for a variety of purposes that are limited and necessary to the delivery of services to the Sponsor and the operation of our business.

SiteRx may use and disclose your Personal Information to:

To each applicable Study site to facilitate your eligibility determination, screening and participation as a research subject in the Studies, so the site may conduct screening, informed consent and research enrollment activities;
Provide our services to Sponsors and generally manage and administer our business, including required legal and regulatory compliance, and records retention processes;
Develop and improve our services;
Contact and communicate with you via land line phone, cell phone, email, or text message (with your consent cell and data charges may apply);
Respond to circumstances permitted or required by law, including defending and bringing legal actions; or
Ensure the safety, security and integrity of our services, operations, and business.

SiteRx may also combine your Personal Information with information we obtain from other sources, such as public records or websites, or other third parties. SiteRx reserves the right to remove the identifiers from your Personal Information to create information that does not identify you. This information may be used by SiteRx for data aggregation and data analytics, to improve our products and services, or for other lawful purposes.

SiteRx may disclose your Personal Information to third party service providers, such as IT support services, customer service providers, and other services providers that support us and the Sponsor and facilitate the services we and they provide to you. These companies are authorized to use your Personal Information only as necessary to provide these services to us and the Sponsor.

SiteRx may disclose your Personal Information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified via email and/or a prominent notice on our website, of any change in ownership.

SiteRx may disclose your Personal Information as we believe to be necessary or appropriate, including: (a) as permitted by applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain. We may also disclose your Personal Information to other third parties with your prior consent.

By submitting your contact information, such as your address, phone number, and email to us, you agree to receive communications, including electronic or text messages, from us or clinical trial representatives about Studies for which you may be potentially eligible. You may unsubscribe from phone, electronic, and/or text communications at any time by contacting us at privacy@siterx.com.

Use of SiteRx’s Services by Minors

Use of our services is not generally directed to individuals under the age of 18, and we request that these individuals not provide personal information and/or sensitive data to us through our service providers unless identified as appropriate by a Sponsor in the protocol criteria. However, the Sponsor may be specifically seeking this age group for a Study. In such Studies, parental consent may be required as part of the pre-screening process. If personal information related to individuals under the age of 18 is identified and deemed inappropriate, reasonable steps will be taken to delete the information.

Security

SiteRx uses reasonable measures to protect your Personal Information, such as using physical, technical, and administrative security safeguards to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration. For example, we limit access to your Personal Information to authorized employees, service providers, contractors, and other individuals/entities who need access to perform services as described in this Privacy Policy. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.

Retention Period

We retain your personal information for the period necessary to fulfill the purposes for which it was collected and processed, as outlined in this Privacy Policy, including to satisfy any legal and regulatory obligations, resolve disputes and enforce our terms of service and policies, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation. Upon expiration of the applicable retention period we securely destroy Personal Information in accordance with applicable laws and regulations.

Privacy Rights Applicable to Users in Certain Jurisdictions

The laws of Canada, certain Canadian provinces, and certain US states grant residents certain rights with respect to their Personal Information. Specifically, you may have the following rights:

Right to Access. You may have the right to obtain confirmation from us whether we are processing your Personal Information, as well as the right to obtain a copy of your Personal Information undergoing processing.
Right to Data Portability. You may receive your Personal Information that you have provided to us in a structured, commonly used and machine-readable format.
Right to Rectification. You may have the right to request the rectification of inaccurate Personal Information and to have incomplete data completed.
Right to Objection. You may have the right to object to the processing of your Personal Information in certain cases.
Right to Restrict Processing. You may have the right to request that we restrict the processing of your Personal Information in certain cases.
Right to Erasure. You may have the right to request that we erase your Personal Information in certain cases.
Right to Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority in the jurisdiction where you reside or where the conduct that is the subject of the complaint occurred.
Right to Refuse or Withdraw Consent. In case we ask for your consent to process your Personal Information, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The lawfulness of any processing of your Personal Information that occurred prior to the withdrawal of your consent will not be affected.
Right to Not Be Subject to Automated Decision-making. You may have the right not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.

If you have any questions about whether any of the above-listed rights may apply to you, or if you would like to exercise these rights, please contact us using the contact information below.

Information Specific to California Residents.
If you are a resident of California, please refer to our Privacy Policy for CA Residents.

Information Specific to Canadian Residents.
If you are a resident of Canada, we collect, process, store, and protect the Personal Information of individuals that engage with our Website and online content, or communicate electronically with us in compliance with the Personal Information Protection and Electronic Documents Act, SC 2000, c 5, Act respecting the protection of personal information in the private sector, CQLR c P-39.1, Personal Information Protection Act, SBC 2003, c 63, and any other relevant federal, territory, and provincial laws. We will ensure that the collection of your Personal Information is limited to what is necessary and appropriate. You acknowledge that you understand that your connection will be through and to servers located in the US, and the information you provide will be processed and stored in our web servers and internal systems located within the US. We will protect your information as required by Canadian law.

We may also share Personal Information with trusted third-party service providers for hosting, analytics, or business purposes. Some of the recipients may also be based outside of Canada and may not provide the same standard of legal protection. We will ensure that the recipient country is recognized as having equivalent level of protection of Canada. If not, we will protect your information by using contractual measures to ensure that the third party provides a level of protection of Personal Information comparable to that required in Canada.

Updates to This Privacy Policy

Because of changes in the law and the changing nature of technology, SiteRx’s privacy practices may change from time to time. Accordingly, we reserve the right to update or modify this Privacy Policy at any time without prior notice. If and when we make changes to our privacy practices that are deemed material under applicable legal standards, SiteRx will post the changes on this page to notify you of the changes. We may also choose to notify you of changes to this Privacy Policy in other ways. Such changes to the Privacy Policy will become effective when posted and as dated. We encourage you to check for updates frequently by clicking on this link.

California Privacy Rights

If you are a resident of California, you may be entitled to certain rights with respect to your PII. Specifically, you may have the following rights:

You may have the right to request that we disclose certain information to you about our collection and use of your PII over the past 12 months.
You may have the right to request that we delete any of your PII that we collected from you and retained, subject to certain exceptions.
You may have the right to object to certain uses and disclosures of your PII and sensitive PII.
If you are age 16 or older, you may have the right to direct us to not sell your PII at any time.
You may have the right to correct or amend the PII we maintain about you.
You may have the right not to be discriminated against for exercising any of the above rights granted to you by California law.

Please contact us if you would like more information.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@siterx.com.