Consumer Health Data Privacy Notice
Last Updated Date: April 1, 2024
This Consumer Health Notice applies to personal information defined as “consumer health data” under US state privacy laws, including Washington’s My Health My Data Act and Nevada’s consumer health privacy law.
Scope
This Consumer Health Data Privacy Notice (this “Notice”) describes how Subject Well, Inc. and its group entities (“SubjectWell,” “we,” “us,” or “our”) collect, use, share and otherwise process consumer health data in connection with our website https://www.trialsearch.com and mobile versions of our website or anywhere else we display this Notice (collectively, the “Site”) to offer clinical trial participant recruitment services (the “Services”). It also applies to consumer health data collected by email, phone, or other offline communication mechanisms.
When we use the term “consumer health data” in this Notice, we mean personal information that is linked or reasonably linkable to an individual who acts in an individual or household context and that identifies such individual’s past, present, or future physical or mental health status. It does not include publicly available information, aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you or your device (and certain measures are taken for ensuring compliance), information about individuals acting in the employment context, or personal information that is used to engage in public or peer-reviewed scientific, historical, or statistical research that meets applicable requirements at law.
Consumer Health Data We Collect, Use Cases, Data Sharing
The table below describes the categories of consumer health data collected and the purpose for which the data is collected and purpose for which it will be used or shared; the categories of such data that are shared; and the categoriThe table below describes the categories of consumer health data collected and the purpose for which the data is collected and purpose for which it will be used or shared; the categories of such data that are shared; and the categories of third parties and specific affiliates with whom we share consumer health data. We do not “sell” consumer health data in exchange or money or other valuable consideration or share consumer health data for cross-context behavioral advertising.es of third parties and specific affiliates with whom we share consumer health data. We do not “sell” consumer health data in exchange or money or other valuable consideration or share consumer health data for cross-context behavioral advertising.
Category of Consumer Health Data
Purposes for Collection, Use or Sharing & Manner of Processing
Categories of Third Parties With Whom Consumer Health Data Is Shared
Information about your health-related conditions, treatments, diseases, or diagnoses
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Social, psychological, behavioral, and medical interventions
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Health-related surgeries or procedures
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Use or purchase of prescribed medication
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Bodily functions, vital signs, symptoms or health measurements
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Diagnoses or diagnostic testing, treatment, or medication
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Gender-affirming care information
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Reproductive or sexual health information
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Data that identifies an individual seeking health care services
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Information derived or inferred from non-health information
To provide our Services you have requested, including matching you to potential research studies; to communicate with you about the Services; to comply with law
Service Providers or Contractors; Clinical Trial Investigators and Sites or their Staff and Agents; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
Sources of Consumer Health Data
Sources of consumer health data we collect and use are:
Directly From You. When you interact with us on our Site or use our Services, we (or our service providers) may collect the consumer health data you choose to share with us.
Inferences. We may infer certain information about you based on information provided from any of the sources listed above.
Consumer Health Data Rights
We offer certain privacy rights regarding your consumer health data as stated below, subject to certain limitations at law.
Right to Know Consumer Health Data
The right to confirm if we are collecting, sharing, or selling consumer health data concerning you.
Right to Access (Right to Know Specific Pieces of Information) / Portability
The right to access and obtain a copy of the specific pieces of consumer health information we have collected about you, including a list of all third parties with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties.
Right to Withdraw Consent to Collect and to Share Consumer Health Data
The right to withdraw consent from our collection (i.e., use) and sharing (with third parties) of your health data.
Right to Request Deletion of Consumer Health Data
The right to request deletion of the consumer health data we maintain about you.
How to Exercise Your Privacy Choices Regarding Consumer Health Data
Please submit a request by filling out our Privacy Rights Request Form here or by emailing us at privacy@subjectwell.com and include “Consumer Health Data Request” in the subject line of your message.
We may need to authenticate your identity and request before processing it, which may require us to obtain additional personal information from you. In order to authenticate your identity, we will generally require either the successful authentication of your existing account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address, and mailing address in the original request, as well as an explanation of the rights you wish to exercise. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
Right to Appeal
In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@subjectwell.com. If your appeal is unsuccessful, Washington residents can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
Additional Information for Nevada Residents
We limit third party collection of consumer health data over time and across different websites while you use our Site. Where third-party cookies, pixels or tracking technologies are enabled on our Site, we require such third parties to act as our service providers. However, third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device used to access our Site. Such collection by third parties is not related to SubjectWell’s collection of consumer health data from you. We encourage you to view the privacy notices of those third parties for more information about their data practices and your privacy choices with regard to those activities.
We also offer data rights with respect to all personal information we process, which include the rights noted above and the right to correct your information. You can submit a request by filling out our Privacy Rights Request Form here or by emailing us at privacy@subjectwell.com and include “Correction Request” in the subject line of your message.
If your appeal is unsuccessful, Nevada residents can raise a concern or lodge a complaint with the Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
Changes in Notice
From time to time, we may change this Notice. We will notify you of any material changes to this Notice as required by law. We will also post an updated copy of this Notice on the Site. Please check the Site periodically for updates.