Headlands Research, Inc. and its subsidiaries (“Headlands”, “we”, or “us”) knows that you value your privacy. We are a clinical trial site network conducting clinical trials for pharmaceutical companies. This Privacy Policy explains the information we collect through the websites available via www.Headlandsresearch.com and other Headlands managed websites or services that include an authorized link or reference to this Privacy Policy (collectively, the “Services”). By using the Headlands Services, you consent to the data practices described in this statement.

Information We Collect

We collect the following categories of information when you access or use the Services, which may be considered personal information when maintained in identifiable form.

• Information you provide directly to us. We collect information you provide directly to us, such as when you sign-up to receive communications or materials from us, inquire about, or participate in, our clinical trial services, or otherwise submit a form or share your information with us, such as:
  • Contact information, including your name, date of birth, email address, and telephone number;
  • Health information, such as information about clinical trials in which you are interested in participating and information relevant to eligibility for those trials;
  • Geographic information, including your country of residence;
  • Health information, such as information related to a disease or medical condition;
  • Correspondence you send to us; and
  • Other information that you provide through the Services.
• Information we collect automatically. Information about your computer hardware and software may be automatically collected by Headlands when you access or use the Services. This information may include:
  • Your internet protocol (IP) address, browser type, domain names, access times, referring website addresses, and device and other unique personal or online identifiers;
  • Time zone, country, and language settings;
  • Information about the links you click and other information about how you use the Services. For example, if you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the website when the error occurred, and any communications or content provided at the time the error occurred;

We may also collect information from other sources in accordance with applicable law.  For example, we may collect information that you have authorized your health care provider to share with us.  Information that is collected when you use the Services may be combined with other information collected from you or other sources.

We may aggregate or de-identify the information described above.  Aggregated or de-identified data is not subject to this Privacy Policy.

How We Use Your Information

We use and otherwise process each of the categories of information identified above for the following business purposes:

• For clinical trial purposes. We will use your information for, but not limited to, communicating with you in relation to clinical trial participation and determining whether you meet criteria for our clinical trial services. Information submitted to us will be registered into our database, unless otherwise requested by you. Providing information to us does not obligate you to participate in any study.
• Communicate with you. We may use your information to communicate with you, including to send you information about clinical trial participation, send you marketing and promotional communications, and respond to your inquiries.
• Analyze use of the Services. We use the information to analyze the use of our Services, such as to improve the Services and ensure that content is presented in the most relevant and effective manner for you and your browser or device; to administer the Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; and to keep the Services, Company, and users safe and secure.
• Compliance with legal obligations. We may use your information to comply with applicable laws and regulations and to protect or exercise our legal rights or defend against legal claims.
• Any other purposes disclosed to you. We may use your information for other purposes disclosed to you at the time we collect your information or with your consent.

Sharing Information with Third Parties

Headlands generally does not sell, rent or lease its customer lists to third parties.  However, we may share your information with the following third parties:

• Pharmaceutical and clinical research partners. Headlands partners with pharmaceutical companies and clinical research partners to run our clinical trials.  We may share your information with our pharmaceutical partners associated with our clinical trial services.  If you are participating in a study, you can learn more by reviewing the relevant informed consent documentation.
• Authorized third-party vendors and service providers. We may share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third-party vendors and service providers are required to maintain the confidentiality of your information.  We also may store your data on servers provided by third-party hosting vendors with whom we have contracted.
• Corporate affiliates
• Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
• Legal purposes. Headlands may disclose your information, without notice, if required to do so by law or in the good faith belief that such action is necessary to conform to the edicts of the law or respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Headlands, our affiliates, users or the public.
• With your consent. We may share you information for other purposes disclosed to you at the time we collect the information or pursuant to your consent.  For example, we may share your information as described in an applicable pre-screen or study informed consent form.

Cookies and Similar Technologies

When you use the Services, we and our third-party analytics and advertising partners may use cookies, pixel tags, and other similar technologies (collectively, “cookies”) to collect information about your browser and use of the Services.  This helps us, for example, measure and understand how visitors interact with the online Services and our content, deliver customized content, and improve the Services.  By using the Services, you consent to our use of cookies and similar technologies.  Please consult your browser settings and mobile settings for choices that may be available to you to limit cookies.  Depending on your settings, you may not be able to take advantage of all of the features of the Services.

The following types of cookies are used on the Services:

• Essential cookies – These cookies enable you to use the Services. These cookies are essential to enable you to browse the Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep the Services safe and secure.
• Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, the Services may not be able to remember certain choices you've previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
• Performance cookies – These cookies collect information about how you use the Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
• Content / advertising cookies – These cookies gather information about your use of the Services so we may improve your experience and provide you with more relevant content and advertising on the Services and elsewhere online and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you've visited the Services and help us understand usage of the Services. Some of these cookies are from third parties that collect information about your use of the Services in order to provide advertising (on the Services and elsewhere, across your different devices) based on your online activities (so-called "interest-based advertising") on the Services and elsewhere online, across your different devices. We do not control the privacy practices of these third parties, and their practices are not covered by this Privacy Policy.

You may be able to refuse or disable cookies by adjusting your web browser settings.  Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies.  For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page.  If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.

Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies.  To learn more, please click here or here.  For additional information on how Google processes your information and what choices you may have, visit their site here.

Do-Not-Track Signals and Similar Mechanisms.  Some mobile and web browsers transmit "do-not-track" signals.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not take action in response to these signals.

Third-Party Links

The Services may contain links to other third-party websites, which may be able to collect information about you. Please be aware that we are not responsible for the content or privacy practices of such third-party websites. We encourage our users to be aware when they leave our Services and to read the privacy statements of any other website that collects personally identifiable information.

Your Rights and Choices

You may be entitled, in accordance with applicable law, to request access to or deletion of your information or more information about our information practices. To submit a data access or data deletion request, please contact us at Privacy@headlandsresearch.com.

Please note that you must verify your identity and request before Headlands will process your request. You may be required to provide email confirmation or other information in order for us to verify your identity. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.

Under certain circumstances, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, your valid government issued identification, and the authorized agent’s valid government issued identification to allow Headlands to verify that the agent is authorized to make the request on your behalf.

Children Under Thirteen

Headlands does not knowingly collect personally identifiable information from children under the age of thirteen through its online Services. If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

E-mail Communications

From time to time, Headlands may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Headlands or click on a link therein.

You may also opt into marketing or promotional communications through the Services. If you would like to stop receiving marketing or promotional communications via email from Headlands, you may opt out of such communications by clicking an unsubscribe link that is included in emails sent when we use a third party email service, or replying to the email requesting to be removed from our list.

Data Security

We take reasonable steps to protect your information from unauthorized access. You should keep in mind, however, that no internet transmission is ever 100% secure or error free. In particular, email sent to or from this web site or online resource may not be secure, and you should therefore take special care in deciding what information you send to us via email.

Transfer of Information Across International Boundaries

Headlands is a U.S. company, and your communication with us may result in the transfer of information across international boundaries, including to U.S. law enforcement. By using this site, you consent to the collection, storage, and processing of your information outside your jurisdiction of residence.

Changes to this Statement

Headlands reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our website, and/or by updating any privacy information on this page. Your continued use of the Services after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

Headlands welcomes your questions or comments regarding this Privacy Policy. If you believe that Headlands has not adhered to this Privacy Policy, please contact Headlands at:

Email Address:

privacy@headlandsresearch.com

Effective as of December 15, 2020