Privacy Policy

1. Sources of Personal Data

We collect Personal Data about you from the following sources:

Directly from you. We may collect Personal Data you provide to us directly, such as when
you contact us through our Digital Properties or communicate with us online or offline.
Data collected automatically and through tracking technologies. We may automatically
collect information or inferences about you, such as through cookies and other tracking
technologies, when you interact with our Digital Properties. This may include information
about how you use and interact with our Digital Properties, information about your device,
and internet usage information.
From third parties. We may collect Personal Data from third parties, such as your treating
healthcare providers who share your Personal Data with us to help determine your eligibility
for one or more research studies that an affiliated research site conducts or may conduct,
service and content providers, our affiliated companies and subsidiaries, business partners,
social media companies or other parties who interact with us.
From publicly available sources. We may collect Personal Data about you from publicly
available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy
Notice, including third party sources, and use or disclose the combined information for the
purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data about you. Except as otherwise specified,
we may collect this Personal Data from both Individuals and Business Contacts:

Identifiers, such as your name, email address, telephone number, and device identifiers
(e.g., cookie IDs and IP address).
Records about you, such as physical characteristics or a description of you; the content,
timing and method of communications you have with us, such as calls and emails; and
information you share with or upload to our Digital Properties.
Demographic information, such as age (including birthdates) and gender.
Internet or other electronic network activity information, such as your browsing history,
search history, preference information (including marketing and purchasing preferences),
account settings (including any default preferences), and other information regarding your
interactions with and use of the Digital Properties. For more information about cookies and
other device data, please see Section 5 (Cookies and Other Tracking Technologies).
Non-precise geolocation data, such as your location as derived from your IP address.
Professional or employment-related information (for Business Contacts), such as job
title; organization; professional licenses, credentials, or affiliations; and other professional
information.
Inferences drawn from any of the information we collect about your preferences or
behavior, including to assess the level of interest in our products and services based on
frequency of visits and contact and determine your preferred frequency for receiving offers.
Sensitive Personal Data, including the following:
o Racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership.
o Driver’s license or photo ID
o Genetic data.
o Information about your health.
o Information concerning your sex life or sexual orientation.
o Citizenship, citizenship status, or immigration status.

3. How We Use Personal Data

We may use Personal Data for the following purposes:

To provide you or your company products and services, such as making our Digital
Properties and other products and services available to you; determining whether you are
potentially eligible for one or more research studies that an affiliated research site conducts
or may conduct; providing and delivering you the goods and services you request, providing
customer service; processing or fulfilling orders and transactions (including processing
payments); verifying customer information; communicating with you (including notifying you
about research opportunities, soliciting feedback or responding to requests, complaints, and
inquiries); hosting informational webinars; and providing similar services or otherwise
facilitating your relationship with us. If we receive Personal Data about you to determine
your eligibility for a specific research study we are conducting, we may retain and use that
Personal Data to determine your potential eligibility for other research studies that an
affiliated research site conducts or may conduct.
For our internal business purposes, such as day-to-day operation of our business;
maintaining internal business records, such as accounting, document management and
similar activities; enforcing our policies and rules; management reporting; auditing; and IT
security and administration.
For our internal research and product improvement purposes, such as verifying or
maintaining the quality or safety of our products or services; improving our products or
services; designing new products and services; developing and improving algorithms,
artificial intelligence or machine learning tools and models; evaluating the effectiveness of
our advertising or marketing efforts; and debugging and repairing errors with our systems,
networks, and equipment.
For legal, safety or security reasons, such as complying with legal, reporting, and similar
requirements; investigating and responding to claims against us, our personnel, and our
customers; for the establishment, exercise or defense of legal claims; protecting our, your,
our customers’, and other third parties’ safety, property or rights; detecting, preventing, and
responding to security incidents and health and safety issues (including managing spread of
communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal
activity.
In connection with a corporate transaction, such as if we acquire assets of another
business, or sell or transfer all or a portion of our business or assets including through a sale
in connection with bankruptcy and other forms of corporate change.
For marketing and targeted advertising, such as marketing our products or services or
those of our affiliates, business partners, or other third parties. For example, we may use
Personal Data we collect to personalize advertising to you (including by developing product,
brand, or services audiences and identifying you across devices/sites); to analyze
interactions with us or our Digital Properties; or to send you newsletters, surveys,
questionnaires, promotions, or information about events or webinars. You can unsubscribe
from our email marketing via the link in the email, opt out of text messages by responding
“STOP” to the text message, or by contacting us using the information in Section 9 (Contact
Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by
law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described
below:

Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries,
business units, and other companies that share common ownership.
Service providers that work on our behalf to provide the products and services you request
or support our relationship with you, such as IT providers, internet service providers, data
and web hosting providers, software service providers, email marketing providers, payment
processing companies, data analytics providers, and companies that provide business
support services, financial administration, or event organization.
Professional consultants, such as accountants, lawyers, financial advisors, and audit
firms.
Vendors necessary to complete transactions you request, such as shipping companies
and logistics providers.
Law enforcement, government agencies, and other recipients for legal, security, or
safety purposes, such as when we share information to comply with law or legal
requirements, to enforce or apply any agreements between us or policies that apply to you,
and to protect our, our customers’, or third parties’ safety, property, or rights.
Other entities in connection with a corporate transaction, such as if we acquire assets
of another entity, or sell or transfer all or a portion of our business or assets including
through a sale in connection with bankruptcy and other forms of corporate change.
Business partners that may use Personal Data for their own purposes, such as:
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o Advertisers, ad platforms and networks, and social media platforms;
o Third parties whose cookies and tracking tools we use as described in Section 5
(Cookies and Other Tracking Technologies).
o Commercial data partners to whom we make information available for their own
marketing purposes; and
o Partners who work with us on promotional opportunities, including co-branded
products and services.

Where required by law, we will obtain your consent prior to disclosing your Personal Data to
our business partners. Where recipients use your Personal Data for their own purposes
independently from us, we are not responsible for their privacy practices or personal data
processing policies. You should consult the privacy notices of those third-party services for
details on their practices.
The public, such as when you have an opportunity to make comments regarding us or our
products that we may share with the public, including comments on our social media posts
and testimonials or reviews on our Digital Properties. Any Personal Data in comments,
reviews, or other content that you share in public areas of our Digital Properties may be
read, collected, or used by other users or the public.
Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

Our Digital Properties and authorized third parties use cookies and other tracking technologies
to collect information about you, your device, and how you interact with our Digital Properties.
This section contains additional information about:

The types of tracking technologies we use and the purposes for which we use them
The types of information we collect using these technologies
How we disclose or make information available to others
Choices you may have regarding these technologies

Types of cookies and tracking technologies we use
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We and the third parties that we authorize may use the following tracking technologies:

Cookies, which are a type of technology that install a small amount of information on a
user’s computer or other device when they visit a website. Some cookies exist only
during a single session and some are persistent over multiple sessions over time.
Pixels, web beacons, and tags, which are types of code or transparent graphics. In
addition to the uses described below, these technologies provide analytical information
about the user experience and help us customize our marketing activities. In contrast to
cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and
tags are embedded invisibly on web pages.
Session replay tools, which record your interactions with our Digital Properties, such as
how you move throughout our Digital Properties and engage with our webforms. In
addition to the uses described below, this information helps us improve our Digital
Properties and identify and fix technical issues visitors may be having with our Digital
Properties.
Embedded scripts and SDKs, which allow us to build and integrate custom apps and
experiences on our Digital Properties

Purposes for using these technologies
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We and authorized third parties use these technologies for purposes including:

Personalization, such as remembering language preferences and pages and products
you have viewed in order to enhance and personalize your experience when you visit
our Digital Properties;
Improving performance, such as maintaining and improving the performance of our
Digital Properties;
Analytics, such as analyzing how our websites are used. For example, we use Google
Analytics to help us improve the user experience. Google Analytics may use cookies and
other tracking technologies to perform their services. To learn how Google Analytics
collects and processes data, please visit: “How Google uses data when you use our
partners’ sites or apps” located at www.google.com/policies/privacy/partners;
Advertising, such as conducting advertising and content personalization on our Digital
Properties and those of third parties; tracking activity over time and across properties to
develop a profile of your interests and advertise to you based on those interests
(“interest-based advertising”); providing you with offers and online content that may be of
interest to you; and measuring the effectiveness of advertising campaigns and our
communications with you, including identifying how and when you engage with one of
our emails; and
Security, such as preventing fraud and malicious behavior

Information collected
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These tracking technologies collect data about you and your device, such as your IP address,
location (both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser
used, browser history, search history, and information about how you interact with our Digital
Properties (such as pages on our Digital Properties that you have viewed).
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Disclosures of your information
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We may disclose information to third parties or allow third parties to directly collect information
using these technologies on our Digital Properties, such as social media companies, advertising
networks, companies that provide analytics including ad tracking and reporting, security
providers, and others that help us operate our business and Digital Properties.
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Your choices
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Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”)
and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt
out of interest-based advertising performed by participating members at
http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.
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You can also refuse or delete cookies using your browser settings. If you refuse or delete
cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your
browser’s Help instructions to learn more about how to manage cookies and the use of other
tracking technologies. If you change computers, devices, or browsers; use multiple computers,
devices, or browsers; or delete your cookies, you may need to repeat this process for each
computer, device, or browser. Opting out of interest-based advertising will not opt you out of all
advertising, but rather only interest-based advertising from us or our agents or representatives.

Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not
honor Do Not Track signals.

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications
over the Internet can be 100% secure, and we cannot guarantee the security of your
information.
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Your Personal Data will be retained as long as necessary to fulfill the purposes we have
outlined above unless we are required to do otherwise by applicable law. This includes retaining
your Personal Data to provide you with the products or services you have requested and
interact with you; maintain our business relationship with you; improve our business over time;
ensure the ongoing legality, safety and security of our services and relationships; or otherwise in
accordance with our internal retention procedures. Once you have terminated your relationship
with us, we may retain your Personal Data in our systems and records in order to ensure
adequate fulfillment of surviving provisions in terminated contracts or for other legitimate
business purposes, such as to enable easier future user onboarding, demonstrate our business
practices and contractual obligations, or provide you with information about our products and
services in case of interest.

7. Children’s Privacy

Our Digital Properties are intended for individuals 18 years of age and older. The Digital
Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As
a general rule, we do not knowingly collect any information, including Personal Data, from
children under 18 years of age. If you believe that we have inadvertently collected Personal
Data from a child under the age of 18, please contact us at the address in Section 9 (Contact
Information) below, and we will take prompt steps to delete the information.

8. External Links

Our Digital Properties may contain links to external sites or other online services that we do not
control, including those embedded in third party advertisements or sponsor information. We are
not responsible for the privacy practices or data collection policies of such third-party services.
You should consult the privacy notices of those third-party services for details on their practices.

9. Contact Information

If you have questions regarding this Privacy Notice, please contact us at:
info@phasewell.com

SCP Clinical Research Intermediate Holdings, LLC, d/b/a PhaseWell Research, together with its
subsidiaries and affiliates (collectively, “Company” “us,” “we,” or “our”) is committed to protecting
the privacy of Personal Data (i.e., information reasonably related to a specific individual). This
Privacy Notice describes how we process Personal Data collected through our websites, social
media accounts, and other online services (collectively, our “Digital Properties”) and other online
and offline interactions. Our affiliated research sites may provide you with a more specific
privacy notice, in which case that more specific privacy notice will apply rather than this Privacy
Notice.
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This Privacy Notice does not apply to data that we handle on behalf of and under the
instructions of our affiliated research sites that we manage, or our business customers. Please
review the privacy policies of our research sites or business customers for more information
about their data handling practices.
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This Privacy Notice also does not apply to information about our current/former employees,
applicants, and other individuals who interact with us for employment-related purposes.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a
friend to us, you must obtain their consent (or have the legal authority without consent) to share
their Personal Data with us.
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Changes to this Privacy Notice
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We may update this Privacy Notice from time to time. Any updated Privacy Notice will be
effective when posted. Please check this Privacy Notice periodically for updates. If required by
law, we will obtain your consent or contact you directly if there are material changes to this
Privacy Notice.