OpenTrials.com ("OpenTrials," "OpenTrials LLC," "we," "us," or "our") respects your privacy. This Privacy Policy explains what personal information we collect, how we use and share it, and the choices available to you. It applies to visitors, individuals interested in clinical trials ("Volunteers"), members of our Volunteer Network, and researchers or sponsors who submit trial information ("Researchers") (collectively, "you").
By using OpenTrials, you consent to the practices described in this Privacy Policy.
1. Information We Collect
1.1 "Get Notified" Requests (trials Not Yet Recruiting)
When you ask to be notified about a trial that is not yet recruiting, we collect: name, email address, phone number, and ZIP code.
1.2 "More Info" Requests (trials Recruiting or Enrollment by Invitation)
When you request more information about an active trial, we collect: name, phone number, email address, and ZIP code.
1.3 "Notify Me" Requests (trials "Completed")
When you ask to be notified about similar clinical studies that may become available in the future for a trial listed as "Completed," we collect: name, email address, phone number, and ZIP code.
1.4 Volunteer Network Sign-Up
When you join our general Volunteer Network, we collect: name, phone number, ZIP code, and general health condition/interest area (selected from a dropdown menu).
Before joining, you will be asked to affirmatively check a separate consent box confirming that you understand how this information will be used.
General health condition information is treated by us as sensitive information. We collect it only with this affirmative, separate consent, and only for the purpose of matching you with potentially relevant trials and Research Teams, using the confirmation-based process described in Section 3 below.
1.5 Researcher / Sponsor Submissions
When a Researcher submits a trial or requests advertising, we collect: researcher name, organization, facility ZIP code, trial subject/title, study goals, timeline, and condition/disease information, along with any billing/contact details needed to process an advertising request.
1.6 Automatically Collected Information
Like most websites, we may automatically collect certain technical information when you visit, such as IP address, browser type, device information, pages viewed, and referring URLs, typically through cookies, log files, and similar technologies. See Section 7 (Cookies) below.
1.7 Information We Do Not Intentionally Collect
We do not ask for or intend to collect Social Security numbers, government ID numbers, insurance information, or detailed medical records. Please do not submit such information through our forms.
2. How We Use Your Information
We use the information described above to:
- Operate, maintain, and improve the Service;
- Notify you when a trial you're interested in begins recruiting or when your Volunteer Network profile appears to match a trial;
- For "Get Notified", "Notify Me" and "More Info" requests, forward your request and contact details to the relevant Research Team so they can reach out to you about that specific trial;
- For the Volunteer Network, identify potential trial matches based on your general condition/interest, notify you of the potential match, and -- only if you affirmatively respond to indicate interest -- share your contact information with that specific Research Team;
- Allow Researchers to list, manage, and (where applicable) pay to advertise trial information on the Service;
- Respond to inquiries and provide customer support;
- Maintain the security and integrity of the Service;
- Comply with legal obligations; and
- Analyze aggregate usage trends to improve the Service (using de-identified or aggregated data where possible).
We do not use your health-condition information to make medical decisions on your behalf, and we do not use it for targeted advertising to you.
4. Sensitive Health Information
Because we collect "general condition" information for the Volunteer Network, we:
- Collect it only with your clear, affirmative, separate consent at the point of collection;
- Use it solely to identify potential matches, and share it with a specific Research Team only after you affirmatively confirm interest in that match (see Section 3);
- Do not sell it to third parties for advertising or marketing unrelated to clinical trial matching; and
- Provide you the ability to review, correct, or delete this information at any time (see Section 6).
Note on applicable law: OpenTrials is not a healthcare provider, health plan, or healthcare clearinghouse, and we do not act as a "business associate" under the Health Insurance Portability and Accountability Act (HIPAA). As a result, information you submit to us is not protected by HIPAA in the way records held by your doctor would be. Instead, it is protected under this Privacy Policy and applicable law, including:
- The FTC Health Breach Notification Rule, which requires certain non-HIPAA-covered entities that handle personal health record information to notify affected individuals (and, in some cases, the FTC and media) following a data breach; and
- Applicable state consumer health data laws -- for example, Washington's My Health My Data Act, and similar laws in Nevada and Connecticut -- which may provide additional rights regarding "consumer health data."
We maintain administrative, technical, and physical safeguards designed to protect this information and have a breach response process in place consistent with these laws (see Section 8).
5. Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy -- for example, for as long as a "Notify Me" request remains pending, or until you ask us to delete your information -- and thereafter as needed to comply with legal obligations, resolve disputes, and enforce our agreements. Researcher submission data is retained for the duration a listing is active plus a reasonable administrative period.
6. Your Choices and Rights
Depending on your state of residence, you may have rights to:
- Access the personal information we hold about you;
- Correct inaccurate information;
- Delete your personal information;
- Opt out of the sharing/disclosure of your information with Research Teams described in Section 3 going forward (note: for "Get Notified", "Notify Me" and "More Info" requests, opting out may mean we cannot forward that specific request, since sharing is how that service functions; for the Volunteer Network, you can opt out of future match notifications at any time without affecting matches you've already confirmed);
- Withdraw consent to future collection or use of your general condition information; and
- Non-discrimination for exercising your privacy rights.
To exercise any of these rights, contact us at [privacy email]. We will respond within the time required by applicable law. We may need to verify your identity before completing certain requests.
If you are a California resident, you may designate an authorized agent to submit requests on your behalf, subject to our ability to verify that authorization.
8. Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure, including:
- Encryption at rest: Sensitive personal information, including contact details and general condition data, is encrypted in our database using industry-standard AES-256 encryption.
- Encryption in transit: Data transmitted between your browser and our servers is protected using TLS/HTTPS encryption.
- Access controls: Access to personal information is limited to personnel and systems that need it to operate the Service.
- Secure hosting infrastructure: Our infrastructure is hosted on servers with industry-standard security controls, including firewalls, restricted administrative access, and regular security monitoring.
- Breach response: We maintain a process for detecting, assessing, and responding to security incidents, including notification to affected individuals (and, where applicable, the FTC or other regulators) consistent with the FTC Health Breach Notification Rule and applicable state law.
However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
9. Children's Privacy
OpenTrials is not directed to children under 18, and we do not knowingly collect personal information from children under 18 without appropriate parental/guardian involvement. If you believe a child has provided us personal information, please contact us so we can delete it.
10. International Visitors
The Service is intended for use by individuals located in the United States, and clinical trial information is primarily sourced from the U.S. registry ClinicalTrials.gov. If you access the Service from outside the United States, your information will be transferred to and processed in the United States.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will post the updated version with a new "Last Updated" date, and, for material changes, provide additional notice as appropriate (e.g., a banner on the Service or direct notice for registered Researchers).
12. Contact Us
Questions or requests regarding this Privacy Policy or your personal information can be sent to:
OpenTrials.comPO Box 54356
Jacksonville, FL 32245
USA
Email: [email protected]