Effective Date: 14 October 2024

This Consumer Health Data Privacy Policy supplements SPLASH CLINICAL LLC’s Privacy Policy available at https://splashclinical.com/privacy-policy/.  To the extent to a conflict between terms in the Privacy Policy available at https://splashclinical.com/privacy-policy/ and the terms in this Consumer Health Data Privacy Policy, the terms in this Consumer Health Data Privacy Policy shall be controlling.

SPLASH CLINICAL LLC acts as a service provider to organizations that sponsor clinical research studies and contract research organizations that support the conduct of clinical research studies (each such organization referred to hereunder as a “Sponsor”). This Consumer Health Data Privacy Policy describes the Consumer Health Data (as defined below) that SPLASH CLINICAL LLC collects, uses, discloses and processes on behalf of Sponsors subject to U.S. state consumer health data privacy laws and explains the rights that may be exercised by individuals pursuant to such laws. As used herein, “Consumer Health Data” means information that is linked or linkable to an identified or identifiable individual who is a resident of a U.S. state having an applicable consumer health data privacy law and that identifies the individual’s past, present or future physical or mental health status (each such individual, a “Consumer”).

Categories of Consumer Health Data Collected

SPLASH CLINICAL LLC collects the following categories of Consumer Health Data:

• Data about individual health conditions, treatment, diseases, or diagnoses;
• Data about medical interventions;
• Data about health-related surgeries or procedures;
• Data about use or purchase of prescribed medication;
• Data about bodily functions, vital signs, symptoms, or measurements of the information described in other bullet points included under this heading;
• Data about diagnoses or diagnostic testing, treatment, or medication;
• Data that identifies a Consumer seeking health care services; and
• Information that SPLASH CLINICAL LLC processes to associate or identify a Consumer with the data described in other bullet points under this heading that is derived or extrapolated from non-health information.

Please be advised that third parties will not collect Consumer Health Data over time across different Internet websites or online services when a Consumer uses SPLASH CLINICAL LLC’s Internet websites or online services.

Categories of Sources from which Consumer Health Data is Collected; Manner in which Consumer Health Data is Collected and Processed

SPLASH CLINICAL LLC collects the categories of Consumer Health Data described above directly from Consumers. Consumer Health Data is collected through clinical trial websites maintained by and on behalf of SPLASH CLINICAL LLC and through call centers operated by and on behalf of SPLASH CLINICAL LLC. Consumer Health Data is otherwise processed as follows:

• Consumer Health Data is transmitted through secure transmission channels, such as portals and other secure platforms;
• Consumer Health Data is maintained securely by web hosting companies on SPLASH CLINICAL LLC’s behalf.

Categories of Consumer Health Data Shared

SPLASH CLINICAL LLC shares each of the categories of Consumer Health Data it collects (as noted above) with the categories of third parties identified under the heading below titled “Categories of Third Parties with which Consumer Health Data is Shared”.

Categories of Third Parties with which Consumer Health Data is Shared

SPLASH CLINICAL LLC shares Consumer Health Data with the following categories of third parties:

• Clinical trial sites involved in conducting clinical trials for which SPLASH CLINICAL LLC recruits trial participants;
• Web hosting companies that maintain clinical trial websites on SPLASH CLINICAL LLC’s behalf; and
• Call centers that assist SPLASH CLINICAL LLC with trial participant recruitment efforts.

Purposes of Processing Consumer Health Data

Consumer Health Data is collected, used and shared (“processed”) for the following purposes:

• SPLASH CLINICAL LLC collects Consumer Health Data from Consumers to perform clinical trial recruitment services;
• SPLASH CLINICAL LLC collects Consumer Health Data from Consumers who complete surveys on its clinical research study websites; these surveys solicit Consumers’ concerns and opinions about their clinical research experience (such surveys referred to herein as “Research Feedback Surveys”). SPLASH CLINICAL LLC uses Consumer Health Data included in the Research Feedback Surveys to assist Sponsors in creating a more patient-focused research experience. SPLASH CLINICAL LLC discloses to Sponsors information from Research Feedback Surveys in summary analytics form (i.e., in a form which does not identify Consumers) for the same purpose;
• SPLASH CLINICAL LLC discloses Consumer Health Data to clinical trial sites so that they may determine Consumers’ eligibility to participate in clinical trials, communicate with Consumers about clinical trial participation and otherwise perform functions related to qualifying and enrolling Consumers in clinical trials;
• SPLASH CLINICAL LLC discloses Consumer Health Data to web hosting companies so that they may assist SPLASH CLINICAL LLC in maintaining clinical trial websites and the Consumer Health Data collected through such websites; and
• SPLASH CLINICAL LLC discloses Consumer Health Data to third parties that operate call centers on SPLASH CLINICAL LLC’s behalf so that such third parties may assist SPLASH CLINICAL LLC with clinical trial participant recruitment efforts.

Consumer Rights

Consumers have certain rights under U.S. state consumer health data privacy laws, which may include any of the following:

• A Consumer may request confirmation of whether SPLASH CLINICAL LLC is collecting, sharing or selling Consumer Health Data concerning the Consumer and to access such Consumer Health Data;
• A Consumer may request a list of all third parties with whom SPLASH CLINICAL LLC has shared Consumer Health Data concerning the Consumer or to whom SPLASH CLINICAL LLC has sold Consumer Health Data concerning the Consumer and request an active email address or other online mechanism that the Consumer may use to contact these third parties;
• A Consumer may withdraw consent for SPLASH CLINICAL LLC’s collection and sharing of Consumer Health Data concerning the Consumer;
• A Consumer may request deletion of Consumer Health Data concerning the Consumer; and
• A Consumer may request that SPLASH CLINICAL LLC to cease collecting, sharing or selling Consumer Health Data concerning the Consumer.

If you are a Consumer who wishes to exercise any of the rights noted above, you may submit a request to SPLASH CLINICAL LLC at privacy@splashclinical.com.

If you submit any of the requests noted above and your request is denied in whole or in part, you have the right to appeal that denial. If you would like to appeal any such denial, please contact SPLASH CLINICAL LLC at privacy@splashclinical.com. To help SPLASH CLINICAL LLC ensure that it considers information pertinent to your appeal, please include in your appeal request the detailed reasons why you believe your request should be approved. Not later than 45 days after SPLASH CLINICAL LLC’s receipt of your appeal, you will receive a response in writing describing any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you will be notified of a method through which you may contact the attorney general to submit a complaint.

Changes to this Consumer Health Data Privacy Policy

As privacy laws and regulations change or in other circumstances as deemed necessary in our discretion, SPLASH CLINICAL LLC may update this Consumer Health Data Privacy Policy. You can determine if this Consumer Health Data Privacy Policy has been revised since your last visit by referring to the “Effective Date” herein. We encourage you to review this Consumer Health Data Privacy Policy regularly to ensure that you are aware of its most up-to-date terms.