Privacy Policy

Effective Date: 01/June/2024

Privacy Commitment

This Privacy Policy applies to websites, online platforms and related services (each and collectively referred to herein as the “Site") developed, maintained and operated by SPLASH CLINICAL LLC (referred to herein as “SPLASH CLINICAL LLC”, “we” or “us”). SPLASH CLINICAL LLC is an innovative patient recruitment firm that uses digital & social media to recruit patients for clinical trials. Users of and visitors to our Site (referred to herein as “users” or “you”) are responsible for carefully reading this Privacy Policy in its entirety. This Privacy Policy describes the information we collect about you and how we keep your personal information safe and confidential. Please be advised that SPLASH CLINICAL LLC may maintain and/or operate other websites or digital properties (apart from the Site) which are governed by different privacy policies or notices that are made accessible to you on those other websites or digital properties, and we encourage you to review the applicable privacy policy or notice on the website or digital property that you utilize.

SPLASH CLINICAL LLC understands that privacy is important to you. The information that we collect about you from our Site will be maintained and used in accordance with this Privacy Policy and applicable laws, rules and regulations. By accessing our Site, you agree to the terms and conditions set forth herein. If you do not agree to any of the terms or conditions in this Privacy Policy or other applicable privacy policies or notices, please do not access or use any part of our Site.

By providing us with your Personally Identifiable Information (as defined below), including Personal Health Information (as defined below), you consent to the collection and use of any information you provide in accordance with this Privacy Policy.

SPLASH CLINICAL LLC may share information among its subsidiaries and third parties working with or on behalf of SPLASH CLINICAL LLC, and SPLASH CLINICAL LLC makes commercially reasonable efforts to ensure such information is protected in accordance with the terms of this Privacy Policy.

SPLASH CLINICAL LLC is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Information We Collect

We will collect information through the use of Cookies (as defined below), Web Logs (as defined below), or IP Address (as defined below). We will only collect Personally Identifiable Information (as defined below) including Personal Health Information (as defined below) if you voluntarily provide such information to us, as described in further detail below.

Cookies

We collect non-identifiable web usage data about your use of our Site through the use of Cookies. A Cookie is a small piece of information that our server sends to your web browser when you access our Site. Every computer that accesses our Site is assigned a different Cookie by SPLASH CLINICAL LLC. Cookies are capable of storing many types of non-identifiable data. Cookies may be used to help us analyze usage of our Site or to restrict underage use of the Site. We do not link basic data from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store Personal Health Information about you.

Most browser software can be set to reject all Cookies. Note, however, that some portions of our Site may not work properly if you reject Cookies.

IP Addresses

We may also receive IP addresses in the normal course of the operation of our Site. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

Web Logs

SPLASH CLINICAL LLC uses standard Web Logs that record basic data about your visit to our Site, such as the date and time of the visit, the pages viewed during the visit and the domain name of your Internet service provider.

We do not normally seek to identify individuals from Web Logs. However, we may use Web Logs to identify an individual whom we suspect tried to damage our Site or use them in an unauthorized way. We may share our Web Logs with law enforcement agencies if we believe there has been a violation of computer security or related laws or as otherwise required in order to comply with applicable law or legal process. In addition, we may share our Web Logs (which do not contain any Personally Identifiable Information) with our partners to assist them in better designing their websites for clinical research studies.

Google Analytics

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) which uses cookies to help analyze how users use the Sites. The information generated by the cookies about your use of the websites (including your IP address) will be transmitted to and stored by Google [on SPLASH CLINICAL LLC’s behalf] under Google’s privacy policy, which you can access here: https://support.google.com/analytics/answer/6004245?p=privpol_data&hl=en&visit_id=637713885417185895-846539400&rd=1#zippy=%2Cour-privacy-policy

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our Site. By using our Site, you consent to the processing of your information by Google in the manner and for the purposes set out above.

Collection, Use and Disclosure of Personally Identifiable Information and Personal Health Information

Personally Identifiable Information that may be collected via a clinical research study survey is information that can be traced back to an individual. Personal Health Information is a combination of your Personally Identifiable Information with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your name, it becomes Personal Health Information. Examples of Personally Identifiable Information include your name, home address, telephone number, email address, date of birth, and any other information that may be used to identify you.

You may voluntarily provide Personally Identifiable Information and/or Personal Health Information in a variety of circumstances, and if you choose to do so, you consent to our collection and use of such information as described in this Privacy Policy. For example, we may collect Personally Identifiable Information, including your name, company affiliation and email address, when you provide such information to submit an inquiry to us on the “Contact Us" portion of our Site. We will use such information to respond to your inquiry. We may also collect Personally Identifiable Information and/or Personal Health Information when you provide such information to us in a survey or questionnaire on our clinical research study Sites and we will use such information to determine if you may be eligible for research study participation (such surveys/questionnaires referred to herein as “Study Eligibility Surveys"). We also operate call centers for the purpose of communicating with you to verify that information you've provided in Study Eligibility Surveys is accurate and to collect additional Personally Identifiable Information and/or Personal Health Information as needed to determine your eligibility to participate in clinical research studies. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SPLASH CLINICAL LLC. Inaccurate information will affect our ability to properly determine if you may qualify to participate in a research study.

While you may view some of our study Sites without providing Personally Identifiable Information, submitting Personally Identifiable Information to us will be required to be considered for participation in a research study.

We may also collect Personally Identifiable Information and/or Personal Health Information when you provide such information to us in surveys on our clinical research study Sites which solicit patients' concerns and opinions about their clinical research experience (such surveys referred to herein as “Research Feedback Surveys"). We use information included in your responses in the Research Feedback Surveys to assist sponsors and contract research organizations with whom we work to create a more patient-focused research experience, and we disclose such information to those sponsors and contract research organizations in summary analytics form (i.e., in a form which does not identify you) for the same purpose.

We will not use or disclose Personally Identifiable Information or Personal Health Information of users of our clinical research study Sites for any purpose other than those described in this Privacy Policy or in other applicable privacy policies or notices that that are made accessible to you on such study websites. If purposes for using Personally Identifiable Information or Personal Health Information change at any time, we will update applicable privacy policies and/or notices. In addition to the uses of Personally Identifiable Information and Personal Health Information described above, we also use and disclose Personally Identifiable Information and Personal Health Information obtained from users in the following ways:

COMMUNICATION WITH REGARD TO STUDY REFERRAL PRE-QUALIFICATION AND/OR OTHER STUDY-RELATED PURPOSES
Personally Identifiable Information will be used by SPLASH CLINICAL LLC to follow-up with the clinical study site about your pre-qualification for and participation in the study and may be shared with the clinical study site for its assessment of your qualification for and participation in a study.
AGENTS AND SERVICE PROVIDERS SUPPORTING STUDY RECRUITMENT EFFORTS
We sometimes employ web hosting companies to maintain our clinical study Sites and data collected through those Sites on our behalf in support of our study recruitment efforts. We may share your personal information, such as your name, disease or condition, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information, with these hosting companies so that they may perform such web hosting services for us. We also engage service providers that assist with operating call centers in order to verify and/or collect information needed to determine study eligibility. Your Personally Identifiable Information and/or Personal Health Information may be shared with those service providers assisting with call center operation. With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.

We may also be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, in response to a search warrant, subpoena, court order, or other valid legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or be inconsistent with our legal obligations.

SPLASH CLINICAL LLC’s accountability for personal data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, SPLASH CLINICAL LLC remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless SPLASH CLINICAL LLC proves that it is not responsible for the event giving rise to the damage.

We may also disclose Personally Identifiable Information or Personal Health Information in any of the following circumstances, in each case as permitted by applicable laws and regulations: (a) to protect our legal rights or the rights of users of our Site, (b) to protect the security or integrity of our Site, (c) to take precautions against liability, (d) to enforce this Privacy Policy, (e) if SPLASH CLINICAL LLC undergoes any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, (f) to detect, prevent, or otherwise address fraud, (g) pursuant to your explicit approval, or (h) during emergencies if physical safety is believed to be at risk.

Aggregate Data

We will combine the information you provide with information from other visitors to our Site to create Aggregate Data which does not contain any uniquely identifying information. We will share this Aggregate Data with the sponsors of our Site, and/or their consultants. We will periodically analyze this Aggregate Data and use what we learn to make improvements to our Site. We may also share this Aggregate Data with our partners to assist them in better designing their websites.

Children’s Privacy

We are committed to protecting the privacy of children. Neither SPLASH CLINICAL LLC, nor any of its Sites or services, are designed or intended to attract children under the age of 13. We do not collect, solicit, or use Personally Identifiable Information from any person we actually know is under the age of 13. If we learn that we collected Personally Identifiable Information from any child under the age of 13, we will endeavor to delete that information as soon as possible. Please contact SPLASH CLINICAL LLC at privacy@splashclinical.com or phone number (414)-443-3280 if you have reason to suspect that we have collected Personally Identifiable Information of any child under the age of 13.

Data Security

We maintain generally accepted industry standard technical, physical, and organizational procedures to safeguard Personally Identifiable Information and Personal Health Information against unauthorized or unlawful processing and against accidental loss, alteration, disclosure and access. Please note, however, that there are inherent risks in transmission of information over the Internet and electronic storage of information, and we cannot guarantee that unauthorized access or use of your Personally Identifiable Information or Personal Health Information will never occur.

Links to Other Websites

Our Site may contain links to other websites which are not operated or controlled by SPLASH CLINICAL LLC. Please keep in mind when you access websites operated by other parties, whether through links on our Site or otherwise, that we do not control what happens on those websites. You should always check the privacy policy of the website you are visiting in order to be sure you know how the operator of that website will collect information from you and what the operator of that website will do with the information.

Internet Transmission Risks

We acknowledge that no internet transmission is ever 100% secure or error free. It is your responsibility to ensure that the computer or device you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer or other device, there is a risk that the information you provide could be disclosed to unauthorized third parties. Similarly, despite SPLASH CLINICAL LLC’s efforts to protect your Personally Identifiable Information and Personal Health Information, as noted above, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.

Rights to Access, Amend, and Delete Information

SPLASH CLINICAL LLC acknowledges under certain laws and regulations, individuals have rights to access, amend and/or delete their personal data. To the extent such laws or regulations apply to SPLASH CLINICAL LLC, you may request that we provide you with access to, amendment of, or deletion of your personal data. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe and as required by applicable laws and regulations.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@splashclinical.com

Changes to this Privacy Policy

As privacy laws and regulations evolve or in other circumstances as deemed necessary in our discretion, we may revise or update our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date” of this policy. Your use of our Site constitutes your acceptance of the terms of the revised Privacy Policy, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms.

Retention of Personally Identifiable Information and Personal Health Information

We will only maintain Personally Identifiable Information and Personal Health Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it was collected or processed. We will delete Personally Identifiable Information and Personal Health Information when such time period has ended.

International Transfers

We may transfer Personally Identifiable Information and/or Personal Health Information about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws and regulations. Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country. Accordingly, with respect to an international transfer, your Personally Identifiable Information or Personal Health Information may be subject to different protections depending on the laws and regulations of the country to which such information is transferred. In all cases, we will seek to apply reasonable safeguards to protect Personally Identifiable Information and Personal Health Information which we transfer internationally.

The EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF)

SPLASH CLINICAL, LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SPLASH CLINICAL, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SPLASH CLINICAL, LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the DPF Principles, SPLASH CLINICAL, LLC attests to the following:

We are subject to the oversight and enforcement authority of the United States Federal Trade Commission.
We acknowledge the right of EU, UK, and Swiss individuals to access their personal data that has been transferred to the United States and to amend or correct outdated or inaccurate information. Furthermore, said individuals have the right to erasure of personal data that has been handled in violation of the DPF Principles. Individuals wishing to exercise any of these rights may do so by contacting SPLASH CLINICAL, LLC by utilizing the contact information below.
We may be required to release personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
We remain liable for the transfer of EU, UK, and/or Swiss personal data to third parties acting as our agents unless we can prove we were not a party to the event giving rise to the damages.

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), SPLASH CLINICAL, LLC commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact SPLASH CLINICAL, LLC at:

SPLASH CLINICAL LLC
Attn: Privacy Officer
12200 W. Wirth Street
Wauwatosa, WI 53222
USA
privacy@splashclinical.com

SPLASH CLINICAL, LLC has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

For Individuals in the European Economic Area and United Kingdom

In some situations, SPLASH CLINICAL LLC acts as a data “processor” that processes personal data on behalf of clinical trial sponsors. Pursuant to the European Union’s General Data Protection Regulation and United Kingdom’s General Data Protection Regulation (collectively, the “GDPR”), if you are interested in participating in a study that appears on our clinical research study Sites, we may (on behalf of clinical trial sponsors) request that you opt-in/consent to our collection and processing of your personal data for purposes of recruitment for the relevant research study. These opt-in requests will be presented as check boxes under which you will have the opportunity to affirmatively indicate your consent to the processing of your personal data as described on our clinical research study Site(s).

Under the GDPR your rights are as follows:

the right to be informed;
the right of access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to data portability;
the right to object; and
the right not to be subject to automated decision-making including profiling.

These rights are described further, as required by the GDPR, on our clinical research study Sites.

You also have the right to complain to a supervisory authority in the EU Member State in which you are located if you feel there is a problem with the way your personal data is handled. You can find a list of supervisory authorities here: http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm. If you are located in the UK, you may complain to the Information Commissioner's Office using the following link: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/

For Individuals in the European Economic Area:

VeraSafe has been appointed as SPLASH CLINICAL LLC's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to SPLASH CLINICAL LLC, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.

For Individuals in the UK:

VeraSafe has been appointed as SPLASH CLINICAL LLC's representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom VeraSafe, can be contacted in addition to or instead of SPLASH CLINICAL LLC, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003. Alternatively, VeraSafe can be contacted at: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.
You may also contact our data protection officer, VeraSafe, LLC, using the following contact information:

VeraSafe, LLC
100 M Street S.E., Suite 600
Washington, D.C. 20003 USA
+1 (617) 398-7067
experts@verasafe.com

U.S. State Consumer Privacy Laws Notice

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"). The notice below describes the Consumer Personal Data (as defined below) that SPLASH CLINICAL LLC collects, uses, discloses and processes on behalf of Sponsors subject to U.S. state consumer privacy laws and explains the rights that my be exercised by individuals pursuant to such laws. As used herein, “Consumer Personal 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 privacy law. Such laws include, without limitation, the California Consumer Privacy Act, as amended by the California Privacy Right Act (“CCPA"), the Colorado Privacy Act (“CPA"), the Virginia Consumer Data Protection Act (“VCDPA") and the Connecticut Data Privacy Act (“CTDPA").

Categories of Consumer Personal Data Processed; Recipients of Consumer Personal Data; Purposes of Processing

SPLASH CLINICAL LLC collects, uses and discloses (collectively, “processes") Consumer Personal Data on behalf of the Sponsors as follows:

Categories of Consumer Personal Data Collected: SPLASH CLINICAL LLC collects individuals' names, postal addresses, email addresses, phone numbers, month and year of birth, and health-related information (including without limitation, information relating to individuals' health diagnoses, conditions and treatment).
- Source from which such Consumer Personal Data is Collected: The categories of Consumer Personal Data listed in the bullet point above are collected by SPLASH CLINICAL LLC directly from individuals who are the subjects of the Consumer Personal Data (each, a “Consumer").
- Third Parties to which SPLASH CLINICAL LLC Discloses such Consumer Personal Data:
  SPLASH CLINICAL LLC discloses the categories of Consumer Personal Data listed in the bullet point above to the following 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 such Consumer Personal Data: SPLASH CLINICAL LLC processes the categories of Consumer Personal Data listed in the bullet point above for the following purposes:
  - SPLASH CLINICAL LLC collects such Consumer Personal Data from Consumers and uses such Consumer Personal Data to perform clinical trial recruitment services and gain insight about Consumers' clinical research experiences to create a more patient-focused experience;
  - SPLASH CLINICAL LLC discloses such Consumer Personal 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 such Consumer Personal Data to web hosting companies so that they may assist SPLASH CLINICAL LLC in maintaining clinical trial websites and Consumer Personal Data collected through such websites in furtherance of SPLASH CLINICAL LLC'S clinical trial recruitment services and its services related to creating a more patient-focused research experience; and
  - SPLASH CLINICAL LLC discloses such Consumer Personal 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
Categories of Consumer Personal Data Collected: SPLASH CLINICAL LLC collects professional and employment-related information, including information which may be included on Consumers' curriculum vitae (CV), such as names, postal addresses, email addresses and phone numbers.
- Sources from which such Consumer Personal Data are Collected: The categories of Consumer Personal Data listed in the bullet point above are collected by SPLASH CLINICAL LLC directly from Consumers and from Sponsors with which SPLASH CLINICAL LLC works.
- Third Parties to which SPLASH CLINICAL LLC Discloses such Consumer Personal Data:
  SPLASH CLINICAL LLC discloses the categories of Consumer Personal Data listed in the bullet point above to the web hosting companies that maintain clinical trial websites of SPLASH CLINICAL LLC's behalf.
- Purposes of Processing such Consumer Personal Data: SPLASH CLINICAL LLC processes the categories of Consumer Personal Data listed in the bullet points above for the following purposes:
  - SPLASH CLINICAL LLC collects such Consumer Personal Data from Consumers and Sponsors to perform clinical trial recruitment services;
  - SPLASH CLINICAL LLC collects and maintains such Consumer Personal Data to enable Consumers who are healthcare providers and other personnel employed by or affiliated with clinical trial sites to register on and use SPLASH CLINICAL LLC's clinical trial websites; and
  - SPLASH CLINICAL LLC discloses such Consumer Personal Data to web hosting companies so that they may assist SPLASH CLINICAL LLC in maintaining clinical trial websites and Consumer Personal Data collected through such websites in furtherance of SPLASH CLINICAL LLC's clinical trial recruitment services

Please be advised that SPLASH CLINICAL LLC does not sell any Consumer Personal Data nor does it share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, any Consumer Personal Data to any third party for cross-context behavioral advertising. Please also be advised that SPLASH CLINICAL LLC does not use or disclose sensitive Consumer Personal Data (such as health data) other than to perform the services reasonably expected by an average Consumer who requests those services.

Consumer Rights

Under U.S. state consumer privacy laws, Consumers have certain rights with regard to their Consumer Personal Data. Consumers may:

confirm whether their Consumer Personal Data are being processed and request access their Consumer Personal Data;
request correction of inaccuracies in their Consumer Personal Data;
request deletion of their Consumer Personal Data;
if Consumer Personal Data is available in a digital format, request to obtain a copy of the Consumer Personal Data that the Consumer previously provided in a portable and, to the extent technically feasible, readily usable format that allows the Consumer to transmit the data to another person/entity that determines purposes and means of processing the Consumer Personal Data (“Controller") without hindrance; and
request to opt out of the processing of the Consumer Personal Data for purposes of: (A) targeted advertising; (B) the sale of Consumer Personal Data; or (C) automated processing of the Consumer Personal Data to evaluate, analyze or predict personal aspects relating to the Consumer's health, personal preferences, interests or behavior (“Profiling") in furtherance of a decision that produces a legal or similarly significant effect concerning the Consumer.

If you are a Consumer who would like to make any of the requests noted above, please contact 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 60 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.

Please be aware that Consumers have the right to not receive discriminatory treatment for the exercise of their privacy rights under consumer privacy laws; this includes without limitation, the right of a Consumer who is an employee, applicant, or independent contractor not to be retaliated against for the exercise of their consumer privacy rights. SPLASH CLINICAL LLC will not discriminate against any Consumer for the exercise of those rights.

In addition to all of the Consumer rights mentioned above, Consumers who reside in the State of California (“CA Consumers") also have the right to know what Consumer Personal Data a business has collected about the CA Consumer, including the categories of Consumer Personal Data, the categories of sources from which the Consumer Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Consumer Personal Data, the categories of third parties to whom a business discloses Consumer Personal Data, and the specific pieces of Consumer Personal Data a business has collected about the CA Consumer. CA Consumers wishing to make any request noted in this paragraph should submit a request to SPLASH CLINICAL LLC at privacy@splashclinical.com.

Verification of Consumer Requests

Consistent with applicable consumer privacy laws, upon receiving a Consumer request, SPLASH CLINICAL LLC attempts to verify that a Consumer submitting a request is the Consumer about whom SPLASH CLINICAL LLC has collected Consumer Personal Data. SPLASH CLINICAL LLC generally attempts to perform such verification by matching data points provided by a Consumer with data points that SPLASH CLINICAL already maintains about that Consumer. In certain cases, SPLASH CLINICAL may request certain additional information from a Consumer for purposes of performing verification.

Agents of Consumers

A Consumer may use an agent to submit any of the Consumer requests described above on the Consumer's behalf. The agent must follow the same process as Consumers for submitting such requests (as described above). As permitted by applicable consumer privacy laws, SPLASH CLINICAL LLC may request a Consumer who uses an agent to verify the Consumer's own identity directly with SPLASH CLINICAL LLC and/or may request the Consumer to directly confirm with SPLASH CLINICAL LLC that the Consumer provided the agent permission to submit the request.

Any Consumer having questions or concerns about the above-mentioned privacy policies or information practices may contact SPLASH CLINICAL using the privacy contact information noted below.

Privacy Contact Information

Questions or comments regarding this Privacy Policy or our privacy practices may be submitted to: