Privacy Policy

ObvioHealth takes the privacy and protection of personal data seriously. This privacy policy addresses how we collect, maintain, use, disclose and otherwise process personal data.This policy applies to ObvioHealth.com, our mobile and cloud basedclinical trial applications,and any other ObvioHealth website or application that links to this policy.

Please note that if you are selected for and choose to participate in aparticular clinical trial or research project, the personal data that you provide in the course of participating in that clinical trial or research projectmay also be subject to the privacy safeguards instituted by the sponsor of that trial or project, which may vary from this Policy. When signing up to potentially participate in clinical trials or research projects, you become a member of the ObvioHealth Community. When you consent to participate in a particular trial or study, you are, for that study, choosing to share information for the conduct of that study with the study sponsor and its agents.

What types of information are collected through this site or mobile application?

We may collect a range of information from you if you visit our site or mobile application depending upon the features you use.

The range of information that we may collect also depends on whether you are registering for our site, participating in a clinical trial or research project, or you are staff for a clinical trial site or project sponsor.

• When you register to join the ObvioHealth community, we collect identifying information, such as your name, address, date of birth, telephone number, email address,username. We also may collect this type of information as well as other information you choose to provide if you use contact us features on our website or application or if you email us or otherwise engage in a transaction with us.
• When you participate in an ObvioHealth screening questionnaire to assess whether you are eligible to participate trials or studies, we collect additional information. The specific data elements collected vary, but the survey will typically request health information (such as medical conditions or medication usage) and may request information regarding gender, race or ethnicity or other information about the subject.
• When you participate in a clinical trial or research project, we collect additional information requested by the sponsor of that clinical trial or project. This may include additional health information, demographic information, photographs, audio or other information for that particular study.
• For staff of sponsors, trial sites or other partners that require access to clinical trial or research project information, we may collect name, username, employer name, email, phone, and other data required to operate the trial either directly or through the sponsor, trial, site or sponsor.

We may collect information about the browser and/or device that you are using to access our website or mobile application (such as the type of browser or device you are using, browser settings, and the device identification number). Device information may or may not be personally identifiable depending upon whether it is linked to the identity of the user.

We may automatically log information, such as a user's IP address, domain name, browser type, date and time of access, and other log file data. This information may be used to analyze trends or administer our websites and mobile applications. We may collect statistical or non-personally-identifiable information about our users, such as which pages are visited, how long a visitor stays on a particular page, the website from which a user came to our site, or similar such information. We also may collect aggregate information such as the total number of unique or return visitors to our site, using our application, or visiting a particular page in a given timeframe. We may use this information to measure the use of our sites and applications and to improve our content.

We may use third party analytics firms including Google Analyticsto analyze information about visits to our website. For information about opting out of Google Analytics pleasevisit: https://tools.google.com/dlpage/gaoptout.

Does your website or mobile application use cookies or similar technologies?

Yes, we may utilize "cookies," web beacons and other similar technologies on our website and mobile application. We may use first and/or third party "browser" or "HTTP" cookies, which are unique text files that may be used for data analysis and enable our website to tailor information for the visitor. We may use browser cookies for purposes such as to personalize the user's experience on our site, to remember a user when the user registers for products or services, to maintain the integrity of our programs, or to track visits to our websites. We also may use "web beacons" (also referred to as pixel tags, clear gifs or other terms) or similar technologies to collect information such as how long a visitor remains on a particular page. If you do not want us to deploy browser cookies to your device when you visit our websites, you may set the browser to reject cookies or to notify the user when a web site tries to place cookies in the browser program (see below). Rejecting cookies may affect your ability to use some of features offered by the website. If you use our website without setting your browser to block cookies, you consent to the placement of cookies on your device.

Third parties, including our service providers may collect information about a visitor to our site over time and/or across different websites when the visitor uses our website. This information often is aggregate data or individual information that is tied to a browser or device rather than specific identifiers such as the visitor's name and address, but some of this information might be considered to be personally identifiable under some laws.

What choices do I have about online tracking and the placement of cookies on my device?

Some Internet browsers offer what often arereferred to as "do not track" mechanisms for browser users to automatically signal privacy preferences to websites that they visit.Our site does not recognize “do not track” signals. You can, however, exercise other choices available to you, including limiting the placement of browser cookies on your device using your browser's cookie control features and other choices described in this Policy.

How is my information used?

We may use the information we collect through our site or mobile application for the following purposes:

• To screen and recruit individuals for participation in clinical trials and research studies;
• To enroll individuals in clinical trials and research studies;
• To conduct clinical trials and research studies and assist Sponsors in their conduct of these activities;
• To provide support services to members of the ObvioHealth community and the staff of sponsors, trial sites or other partners that useour website or mobile application;
• To communicate with members of the ObvioHealth community and other users of our Websites and mobile applications;
• To carry out our obligations under our contracts with sponsors, trial sites or other partners;
• For payment purposes, including billing and participant financial compensation when applicable;
• To improve and administer our websites, mobile applications and clinical trial services andcapabilities;
• To better understand the needs of the users of our sites and mobile applications and create content that is relevant to the user;
• For marketing and market research purposes;
• For analytics purposes and to generate statistics, aggregate data, and de-identified data;
• For individuals that submit a resume or otherwise provide information as part of a job application through our site, that information will be used for employment-related purposes;
• To prevent fraud and investigate potential misconduct; or
• To comply with law and legal process.

What types of choices do I have about your collection and use of personal data about me?

You have a number of choices regarding our collection and use of information through our websites and mobile devices.

In cases where you are requested to affirmatively provide information, such as to complete a form, or an application, or a survey on our website, you may decline to do so. Please understand, however, that in some cases certain information is required to complete an application, form or survey, and if you decline to provide the information requested you may not be able to submit the application or request or to use certain functionalities of our websites or mobile applications. For example, if you decline to provide information requested on a screening questionnaire you may not be able to participate in clinical trials or research projects for which that information is a necessary consideration. Similarly, if you are participating in a clinical trial or research project and you decline to provide requested information, you may not be able to continue to participate in the clinical trial or research project.

If you would like to restrict our placement of cookies on your device, please see the FAQ "What Choices Do I Have About the Placement of Cookies on My Device?" above.

If you would prefer not to receive e-mail marketing messages from us, please use the opt-out instructions included in the email message to opt-out of additional communications.

You may be given additional choices in the context of particular preferences tools or functions that we make available through our website or mobile applications.

How do request access to, correction, or deletion of my personal data or exercise other rights regarding my personal data?

We take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data.

Undercertain circumstances, you have the right:

• To access and receive a copy of the personal data we hold about you;
• To rectify any personal data held about you that is inaccurate;
• To request the deletion of personal data held about you;
• To object to our processing of your personal data; and
• To request to obtain a copy of your personal data in a commonly used electronic format so that you can manage and move it.

These rights are not necessarily absolute and may be limited in some jurisdictions by applicable law. In addition, if you are participating in a clinical trial or research project, while you can choose to stop participating at any time, information collected prior to your withdrawal may not be subject to deletion or objections to continued processing.

If you would like to exercise any of these rights, please contact us at: my-privacy@obviohealth.com.

Please note, if you are participating in a clinical trial or research study supported on the ObvioHealth application or website, it may be necessary for the Sponsor to address your requests with respect to clinical trial or research project data that they control.

How may personal data collected through this website or mobile application be disclosed?

We do not share, sell or lease personal data about you except as set forth in this Policy.

We may disclose personal data with your consent or as otherwise necessary or appropriate to process a transaction that you may request. For example: we may disclose personal data to facilitate shipping products or devices to you if necessary for a clinical trial or research project in which you are participating; we may disclose information about you to schedule lab or site visits for participants in clinical trials or research projects; or we may disclose information to facilitate payment or reimbursement for participation in clinical trials or research projects, if applicable.

We may disclose personal data that we collect through our websites or mobile applications with agents, affiliated businesses, clinical trial and research study sponsors, and service providers providing services on our behalf.

In the case of sponsor, trial site, or other partner staff accessing our website or platform, we may share the personal data that we collect and process with the relevant sponsor(s), site(s) or partner(s).

We also may disclose personal data to the Food and Drug Administration, the European Medical Agency, institutional review boards, ethics boards, or other regulators when required to do so in connection with clinical trials or research studies in which youchoose to participate.

In the event that our company or some of our assets are sold or transferred as part of a merger, acquisition or other corporate transaction, or used as security or to the extent we engage in business negotiations with our business partners, the personal data collected on our websites or mobile applications, including this site, may be transferred or shared with third parties as part of that transaction or negotiation.

If we receive a request from law enforcement officials or judicial authorities to provide personal data about individuals, we may provide such information. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose information about you without a court order.

Please note, in the case of personal data collected during your participation in a clinical trial or research study supported by our website or mobile application, our ability to disclose your personal information is governed by our agreement with the Sponsor and we may disclose information to additional parties as the Sponsor may direct. For example, we may share information with clinical trial or research sites, clinical research organizations working with the Sponsor or shipping or other partners working with the sponsor.

Do you take steps to safeguard personal data I provide through the site or mobile application?

ObvioHealthtakes reasonable measures that we believe are appropriate to protect your personal data from loss, misuse, alteration or destruction. We require service providers to whom we may transfer your information take comparable steps to safeguard personal data.

We retain personal data as long as reasonably necessary to carry out the purposes for which it was collected and to meet our legal obligations and if, applicable, our contractual obligations to Sponsors or clinical trials or research studies. Please note that data collected during your participation in a clinical trial or research study supported by ObvioHealth through our website or mobile application will be subject to retention by the sponsor of that clinical trial or research project for the period described in the informed consent for that clinical trial or project, which may differ.

If you use this site or mobile application, you are responsible for maintaining the confidentiality of any user ID and password or other access credentials that you may be provided. You should notify us immediately if any user ID and password or other access credentials we may issue you are compromised.

What additional information do I need if I am located inthe European Economic Area (EEA), Switzerland or the United Kingdom?

In addition to the disclosures made elsewhere in this Privacy Policy with respect to our privacy practices, our legal basis for processing personal data we collect in the EEA, Switzerland and the UK, can vary depending on the nature of the information and the purpose for which we collect it.

Our legal basis for processing information about you that we collect about you through our website or mobile application with respect to your participation in the ObvioHealth community—other than special categories of personal data--is our legitimate interest as a data controller to administer our website. In the case of special categories of personal data, such as health information, religious or philosophical beliefs, genetic data, biometric data, or information about racial or ethnic origin, your consent is our lawful basis for processing. In cases where you are asked to provide your consent, you can withdraw your consent at any time, although this will not affect the lawfulness of our processing prior to your withdrawal of consent. Unless otherwise indicated for a particular clinical trial or research study, the processing of personal data for research purposes is done on the basis of the legitimate interests of the controller and, in the case of the processing of health information and other special categories of personal information, for public health purposes. Unless otherwise indicated for a particular clinical trial or research study, the processing of personal data for safety reporting, archiving requirements, and regulatory reporting and inspection requirements is to meet the legal obligations Obviohealth, the Sponsor and their representatives, and, in the case of the processing of health information and other special categories of personal data for these purposes, the basis for processing is for public health purposes.

In the case of processing involving passive data collection and other processing for the administration of our website and mobile application, such processing is undertaken pursuant to our legitimate interests as a data controller. We may process personal data where necessary for our compliance with a legal obligation to which we are subject. We also reserve the right to process personal data in the event we believe doing so is necessary to protect the rights of the data subject or another person.

Please note that ObvioHealth is based in the United States and personal data provided by individuals in the EU, EEA, UK and Switzerland may be transferred to the United States and, possibly to other countries depending on the location of the Sponsor of a clinical trial or research study and its agents. These jurisdictions may provide a lesser level of data protection that the law in your country. By providing personal data to ObvioHealthyou consent to the transfer of the personal data you provide to the United States and other third countries relevant to the particular clinical trial or research study in which you choose to participate.

You have rights to data access, rectification, erasure, to restrict or object to processing, and data portability to the extent these rights are required by law.

If you have any questions about our privacy practices, please contact us at: my-privacy@obviohealth.com . You also have the right to file a complaint with your data protection authority if you have concern about the manner in which we are processing your personal data.

What additional information do I need if I am located inAustralia?

You have the choice not to submit personal data to us (other than as may be required by law) although this may reduce your ability to fully participate in all aspects of the ObvioHealth Community, our web sites and mobile applications, or clinical trials or research studies supported by Obviohealth. It is not possible to register for participation in the Obviohealth community or particular clinical trial or research study on an anonymous basis (although your identity may not be shared with the Sponsor). We will inform you if it is possible in other cases for an interaction to occur on an anonymous basis (for example through required/optional data field designations) and, where it is, it will be optional for you to provide personal information.

ObvioHealthmay transfer personal data to the United States for processing. If you choose to participate in a clinical trial or research study as part of the Obviohealth community, informationalso may be transferred tothe Sponsor and its agents if they engage in processing in other countries. If you have any questions about our privacy practices or concerns about our compliance with the Australian Privacy Principles, please contact us at: my-privacy@obviohealth.com so that we can respond to your concerns. You also have the right to file a complaint with the Office of the Australian Information Commissioner if you have concern about the manner in which we are processing your personal data.

Does your site contain links to other websites or social media platforms?

Yes, our website may include links to other websites or links that facilitate your ability to post content to social media platforms. Please be aware that sites we link to may collect information about you and operate according to their own privacy practices thatmay differ from this Policy. Similarly, if you post content to social media platforms, such as Facebook or Twitter, whether you do so manually or using a widget offered on our site, please remember that your social media postings will be made available in accordance with the social media site where you are posting the information and that you may be limited in your ability to control information once you have made it available to third parties by posting it. Remember to consult the privacy policy of any websites you may visit regarding their privacy practices.

If I followed a link to your site from another website, whose privacy policy controls?

The privacy policy posted on the website you were visiting, if any, would apply to any information collection that occurred on that site. Our privacy policy applies to your activity on our site.

How will changes to this Policy be communicated?

We may update our Privacy Policy from time to time. If we make any material changes to this privacy policy we will change the "last updated" date so that you can quickly determine whether there were material changes since the last time you reviewed the policy.You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Who can I contact with questions regarding this Policy?

If you have questions concerning our privacy practices, contact us at: my-privacy@obviohealth.com