PRIVACY POLICY

Last updated February 26, 2020

Thank you for choosing to be part of our community at High Enroll, LLC (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at singamnv@highenroll.org.

When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you, in the clearest way possible, what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Apps and our services.

This privacy notice applies to all information collected through our mobile application, (“Apps“), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the “Services“).

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

10. DO WE MAKE UPDATES TO THIS POLICY?

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 1. WHAT INFORMATION DO WE COLLECT?

Information automatically collected

In Short:   Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Information collected through our Apps

In Short:   We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:
  • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Apps.
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
                                                                                                                             
  • To deliver services to the user. We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:
  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at Pending.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

10. DO WE MAKE UPDATES TO THIS POLICY?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Pending, by email at Pending, or by post to:

High Enroll, LLC 
Pending
580 Walnut Street
Cincinnati, OH 45202
United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

This privacy policy was created using Termly’s Privacy Policy Generator.

 

How can you review, update, or delete the data we collect from you?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.
This privacy policy was created using Termly’s Privacy Policy Generator.

 

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:

  • You add your contact information to your profile on the App.
  • You use our support services, either directly through High Enroll or through our service providers.
  • You communicate with us, including by text, email, or phone.
  • You complete customer surveys.

 

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

  • You download and use the App.

 

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

  • High Enroll Customer site administrators add contact information for the Studies through their Customer Portal.
  • When High Enroll Customers add contact information for site administrators to their Customer Portal.

 

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:

  • Identifiers or User Profile: Installation ID, user ID, dynamic IP address, hashed password, permissions.
  • Device: device platform, OS version, device model.
  • Usage Patterns: screen navigation, user events, usage time, response time, all server requests, access logs, change history.
  • System Information: response times, system monitoring.

 

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:

  • Your mobile device manufacturer.
  • Your mobile service provider.
  • App store and platform providers.

 

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:

  • To our subsidiaries and affiliates.
  • To our contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of High Enroll’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by High Enroll about our App users is among the assets transferred.
  • To fulfill the purpose for which you provide it or with your consent.
  • To comply with any court order, law or legal process, including to response to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App End User Licensing Agreement, and for billing and collection.

 

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.