Privacy Policy

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

3. Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically

• Through Cookies (defined in the “Tracking Tools and Your Choices” section below).
• If you use a location-enabled browser, we may receive information about your location.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Public Records

• From the government or other sources
• From Medicare providers

Third Parties

Vendors

• We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• We may use vendors to obtain information to generate leads and create user profiles.

Social Networks

• If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

4. Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• Providing you with the products, services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing the Services

• Marketing and selling the Services

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Trial Library or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Trial Library or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

5. How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below:

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.

Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners. These parties partner with us in offering various services. They include:

• Study sponsors for clinical trials.

Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Social networking services.
• Other users

Mobile Information and SMS Consent

• Trial Library may send SMS text messages to users who have provided consent, including healthcare providers, authorized staff, and patients. These messages are transactional and service-related, and may include:
  1. Notifications regarding clinical trial coordination and patient referrals
  2. Follow-up requests for information needed to complete a referral
  3. Scheduling coordination for patients being referred to clinical trial sites
  4. Status updates when a referral has been accepted or closed
  5. Notifications about new clinical trial opportunities in a provider’s area
  6. Reminders related to trials a provider is actively pre-screening for
• How We Obtain Consent. We obtain consent to send SMS messages through: (1) verbal consent provided during a phone call with our team, or (2) submission of a telephone number through our website form(s). For patients, when applicable, we obtain written consent (which includes electronic consent) before sending any messages that may contain medical information.
• Consent is Voluntary. Your consent to receive SMS messages is voluntary and is not required to use Trial Library’s services.
• Security and Privacy. We use secure, encrypted platforms to protect the confidentiality of your information. However, SMS messaging carries inherent risks, including the possibility of unauthorized access if your device is lost, stolen, or accessed by others. By consenting to SMS communications, you acknowledge these risks. If you prefer an alternative method of communication, please contact us at info@triallibrary.com.
• Message Frequency and Rates. Message frequency varies based on your interactions with our Services. Message and data rates may apply.
• Opting Out. You may opt out of receiving SMS messages at any time by replying with STOP, QUIT, END, REVOKE, OPT-OUT, CANCEL, or UNSUBSCRIBE to any message, by contacting us at info@triallibrary.com, or by any other reasonable method. Upon receipt of your opt-out request, we will cease sending you all SMS messages and you will receive a confirmation message. You will no longer receive SMS messages from us unless you re-subscribe. We will process your opt-out request within 10 business days.
• Help. For assistance, reply HELP to any message or contact us at info@triallibrary.com‍
• No Advertising or Marketing. Trial Library does not use SMS for advertising or promotional marketing purposes. All SMS messages are transactional and service-related, sent solely to support clinical trial coordination and patient navigation services.
• No Sharing of Mobile Opt-In Data. Trial Library does not share, sell, rent, or exchange mobile opt-in data, consent, or phone numbers with third parties for marketing or promotional purposes. Any SMS messaging consent you provide is used solely to communicate with you regarding Trial Library’s services and is governed by this Privacy Policy.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. These Cookies are necessary for the Services to function and do not require your consent. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region). These Cookies are only placed with your consent.
• Analytics & Advertising Cookies. Analytics & Advertising Cookies allow us to understand how visitors use our Services and to deliver advertisements that are more relevant to you and your interests. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. These Cookies also help us measure the performance of our advertising campaigns. These Cookies are only placed with your consent. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You may learn more about Google Analytics privacy practices at the opt-out page at https://support.google.com/analytics/answer/6004245. You may also download the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/

Do Not Track and Opt-Out Preference Signals

The Services do not currently respond to “Do Not Track” (DNT) or Global Privacy Control (GPC) or other opt-out preference signals sent from a browser at this time. You can control non-essential tracking, including analytics and advertising cookies, at any time through our consent banner and the “Consent Preferences” tool described above.

Additional Browser Controls

In addition to our consent mechanism, you can manage Cookies through your internet browser’s settings. Most browsers allow you to turn off the Cookie feature, or decide on acceptance of each new Cookie. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/

7. Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

8. Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at info@triallibrary.com.

9. California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@triallibrary.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct inaccurate Personal Data that we maintain about you. If your correction request is subject to an exception under applicable law, we may deny your correction request.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of your Sensitive Personal Information as defined under Cal. Civ. Code § 1798.140(ae) to uses necessary to provide the Services. To submit a request to limit, please contact us using the methods described in the “Exercising Your Rights” section below.

Non-Discrimination

We will not discriminate against you for exercising any of the rights described in this section. We will not deny you goods or services, charge different prices or rates, provide a different level or quality of goods or services, or suggest that you will receive a different price or level of quality as a result of exercising your privacy rights.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data which includes First Name, Last Name, e-mail, and phone number, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request”. We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: info@triallibrary.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

10. Other State Law Privacy Rights

Additional State Privacy Rights

Residents of states with applicable comprehensive privacy laws may have additional rights under those laws. These may include the right to access, correct, or delete your Personal Data, the right to opt out of targeted advertising or the sale of your Personal Data, and the right to appeal a denial of your privacy request. To exercise any applicable state privacy rights, please contact us at info@triallibrary.com

California Shine the Light Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@triallibrary.com

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@triallibrary.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

11. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Trial Library website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

12. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• 415-683-1760
• triallibrary.com
• info@triallibrary.com
• 2021 Fillmore Street Suite #1230 San Francisco, CA 94115-2708