HIGH ENROLL PLATFORM PRIVACY POLICY

High Enroll, LLC (“High Enroll,” “We” or “Our”) provides this Privacy Policy to describe the types of personal information we collect, how we use the information, and with whom we share it.

High Enroll supports patient enrollment in various clinical trial research studies (“Studies”) being conducted at various institutions and companies (“High Enroll Customers”) by providing a network (the “Platform”) where High Enroll Customers, through their portal (“Customer Portal”), can post and providers can access information relating to the Studies. This Privacy Policy applies to information we collect on the Platform located at highenroll.org (the “Website”) and the High Enroll branded mobile application (the “App”) and through any communications sent through or in connection with the Platform.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. When you agree to the End User License Agreement, you agree to this Privacy Policy. This Policy may change from time to time (see Updates to the Privacy Policy). Your continued use of our Platform after we revise this Policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 13

The Platform is not directed toward children under 13 years of age, and we do not knowingly collect personal information from children under 13 years of age. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@highenroll.org.

How We Collect Information

We collect personal information from and about users of our Platform directly from you when:

We automatically collect device information, usage patterns and system information when:

We collect personal information from and about High Enroll Customers and their site administrators when:

The Types of Information We Collect and Why We Collect It

When you install the App, you will be issued an Installation ID that grants you access to the App’s features. Under an Installation ID, High Enroll will not know your contact information unless and until you provide it to us. Although the App will automatically collect information, including geolocation data, the information will not be tied to any unique identifiers about you or your device.

The App automatically collects certain information. If you do not want us to collect this information, do not download the App or delete it from your device. The App automatically collects geolocation data to provide you with more relevant Studies based on your location. In addition, the App automatically collects the following information to allow us to assess App analytics and provide technical support services to you:

You may complete your user profile by inputting the following types of information: first and last name, email address, phone number, job title, photo, and time zone. We may also add this information to your profile if and when you contact us for technical support services.

We collect the following types of personal information from and about High Enroll Customers and their site administrators: home or work phone number, home or work email address, organization, and work hours.

Third-Party Collection and Links

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

We may share Installation IDs, source code, push token, compiled assets, and app signing keys with these third parties. Additionally, these third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. We do not control these third parties' tracking technologies or how they may be used.

We use several third parties to support the functionality and your use of the Platform:

Our App may provide links to other websites for your convenience and information. Third-party websites that are accessed through links on our App have separate privacy and data collection practices and security measures. We have no responsibility or liability for the practices, policies, and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies, and security measures before disclosing any personally identifiable information.

Disclosure of Information

High Enroll Customers have access to view the categories of Studies to which a particular user subscribes. In addition, if your profile contains your name, email address, or phone number, the High Enroll Customer will have access to view this information when you subscribe to that High Enroll Customer’s Studies.

In turn, users of the App have access to view the contact information for a particular Study as inputted by the High Enroll Customer’s site administrator. Details about Studies, including contact information, may be shared by App users without restriction. In contrast, site administrator contact information listed on their Customer Portal is not shared with users of the App.

In addition, we may disclose information that we collect or you provide:

Residents of the European Economic Area

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under applicable law regarding the processing of your personal data. The term “personal data” has the meaning given to it by the EU General Data Protection Regulation (“GDPR”). When we process your personal data as described in this Privacy Policy, we will only do so when we have a legitimate interest in processing your personal data, when the processing is necessary for the performance of a contract between you and us, when the processing is necessary for compliance with a legal obligation to which we are subject, or when we have your consent to process your personal data. When processing is based on consent, you have the right to revoke such consent at any time. You also have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http:/ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Residents of California

If you are a resident of California, you may have certain rights and protections under applicable law regarding the processing of your personal information. The term “personal information” has the meaning given to it by the California Consumer Privacy Act (“CCPA”). When we collect, use, or disclose your personal information as described in this Privacy Policy, we will only do so when we have a business purpose in collecting, using, or disclosing your personal information, when the collecting, using, or disclosing is necessary for the performance of a contract between you and us, when the collecting, using, or disclosing is necessary for compliance with a legal obligation to which we are subject, or when we have your consent to collect, use, or disclose your personal information. When the collecting, using, or disclosing is based on consent, you may have the right to revoke such consent at any time. You may also have the right to access personal information we hold about you, ask that your personal information be deleted, or ask that we not sell your personal information. If you would like to exercise any of these rights, you may contact us as indicated below.

Security Safeguards

We recognize the importance of information security, and we are constantly reviewing and enhancing our security procedures. Our App and servers have security measures in place to help protect your personal information against loss, misuse, and alteration while under our control, such as firewalls and SSL technology. However, you should be aware that no transmission of data over the internet is guaranteed to be completely secure, and we cannot guarantee the security of any information you provide to us.

Contact Us

If you have any questions, comments, or concerns about our Privacy Policy, you may contact us at: support@highenroll.org.

Updates to the Privacy Policy

We may amend this Privacy Policy from time to time, without notice to you, in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our users, visitors, properties, strategic marketing partners, and service providers. Updated versions will be posted to our Platform and the “last updated” date at the bottom of this Privacy Policy will be revised so that you are always aware of when the Privacy Policy was last updated.

Last Updated: August 31, 2020