Last updated: 01 December 2021

1. Introduction

1.1 Thank you for visiting our website. This privacy policy governs the way we, Rewards for Research Pty Ltd ACN 129 149 015 trading as Trialfacts (Trialfacts, we, us), handle personal information. We recognize the importance of protecting the privacy of research participants, our clients and visitors to our website https://trialfacts.com/. For that reason, we comply with the Privacy Act 1998 (Cth) (Privacy Act) and specifically the Australian Privacy Principles (APP).

1.2 In addition to the Privacy Act, we comply with the General Data Protection Regulation (GDPR) which is in force to protect the privacy of residents of the European Union. We also comply with the HIPAA Privacy Rule which is the privacy protection regime under US law and applies to personal health information.

1.3 Please take a moment to read this privacy policy carefully. By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this privacy policy and any other arrangements that apply between us.

1.4 We may change our privacy policy from time to time by publishing the updated policy on our website with the effective date of the change shown above. We encourage you to check our website periodically to ensure that you are aware of our current privacy policy.

2. What personal information do we collect?

2.1 Personal information is information or an opinion about you, whether true or not, which identifies you or from which your identity can be reasonably obtained.

2.2 We collect personal information about you that we reasonably need for our business functions and activities, which include:

(a) assessing the potential eligibility of potential research study participants for different research studies;

(b) providing the information of willing research participants who are potentially eligible to researchers conducting the relevant studies, and who are searching for eligible participants for their research; and

2.3 providing a service to researchers who are looking to identify potentially eligible participants for their research study. If you contact us to make a general enquiry about potentially being a participant in one of our research studies, we will collect the following personal information from you:

(a) your name;

(b) the name of the company you work for (if applicable);

(c) your email address; and

(d) your phone number.

2.4 If you choose to sign up to participate in one of the research studies that we support on our website, the personal information we will collect from you to make an initial assessment of your eligibility and to ensure recruitment of a representative, diverse and inclusive sample will depend upon the kind of research being conducted, and will vary from study to study. Information that we may need in order for researchers to conduct their study may include the following personal information:

(a) your post code or zip code (US);

(b) your state;

(c) your gender;

(d) date of birth;

(e) information about your education; and

(f) how you heard about us.

2.5 Occasionally, we may ask you for sensitive information if it is relevant to the eligibility criteria or to assist us in selecting a range of participants who are a representative, diverse and inclusive sample of the population. Sensitive information is a subset of personal information and includes:

(a) information or an opinion about your racial or ethnic origin;

(b) information or an opinion about your sexual orientation or practices;

(c) your health information; or

(d) your genetic information that is not otherwise health information.

2.6 If you are a researcher and are considering using our services to find participants to be part of your research studies, we may collect the following personal information from you:

(a) your name;

(b) the name of the company you work for (if applicable);

(c) email address;

(d) phone number; and

(e) how you heard about us.

2.7 Any personal or sensitive information will be collected and held in a fair and lawful manner and not in an intrusive way. Personal and sensitive information is generally collected through our website via a form that you can complete, or an online pre-screen questionnaire which consists of multiple pages.

3. Why do we collect, use and disclose your personal information?

3.1 We only process personal information for purposes that would be considered relevant and reasonable in the circumstances.

3.2 If you choose to make personal or sensitive information available to us on our website by filling out one of our forms or questionnaires, we will use that information to assess your eligibility for a research study that is seeking eligible participants.

3.3 If we determine, from the information you have provided by filling out the forms, that you are eligible to participate in a particular research study, then we will provide that information to the relevant researcher running the research study.

3.4 If you are a researcher, we will use the personal information you provide to contact you and answer inquiries about your use of our services. If you decide to use our services to find participants for your research study, we will only use your personal information for purposes that would be considered relevant and reasonable in the circumstances. Our use of the personal information you provide is limited to what is reasonably required to locate potential participants for your research trial and to facilitate your connection with them for the purposes of the participant participating in your research study.

3.5 We typically collect and handle personal information to enable us to:

(a) screen potential research study participants so that appropriate participants are identified and their details passed on to the relevant researchers;

(b) administer our dealings with you;

(c) assess any complaints made by you;

(d) communicate with you and provide you with relevant information;

(e) assess your needs and preferences so that we can identify research studies that may be more relevant to you;

(f) improve and diversify the researchers and the research studies available on our platform for participants to consider and to be considered for;

(g) comply with our legal and regulatory obligations; and

(h) otherwise manage our business.

4. To whom do we disclose your personal information?

4.1 For potential research participants, we may disclose your personal information for the purposes described in this policy to:

(a) researchers who are looking for participants to be a part of their research study and are looking for eligible participants;

(b) our employees and contractors both in and outside of Australia, and related bodies corporate;

(c) our professional advisors;

(d) specific third parties authorized by you to receive information held by us; and/or

(e) other persons including government agencies, regulatory bodies and law enforcement agencies, if authorised or required by law.

4.2 Our business and website exist for the primary purpose of matching eligible and willing research study participants with relevant research studies that are being conducted. Researchers who require participants for their study use our services for the purpose of finding participants who are eligible and willing to participate in their particular research study. When you provide your personal information, you are doing so with the understanding that we will pass that information onto these third parties who are seeking participants for their research study, and who will use the information that you provide to determine your fitness and eligibility for the study.

4.3 Many of the researchers who use our platform to be paired with eligible participants for their trials are conducting their research trials from, and are located in the United States of America. By providing your personal information to us, you consent to us disclosing your personal information to any overseas recipients for purposes which are necessary or useful in the course of operating our business and you agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress, under the Act.

4.4 We do not sell, trade or rent your personal information to others except for those parties clearly identified when you sign up for participation in a clinical study.

4.5 Trialfacts may provide aggregate statistics about our customers, sales, traffic patterns and related site information to reputable third-party vendors, but these statistics will include no personally identifying information.

5. Do you need to provide us with your personal information?

5.1 You do not need to provide us with your personal information. You may deal with us anonymously or by using a pseudonym if you wish. However, if you choose to deal with us anonymously, you may be ineligible for certain research studies on offer, if it would be impracticable for you to be included anonymously for the research study to achieve its purpose.

6. Direct Marketing

6.1 Like most businesses, we use direct marketing to promote our business from time to time. We may use the information we collect to occasionally notify you about important changes to the website and new Trialfacts services we think you’ll find valuable. If you would rather not receive this information, please notify us, or unsubscribe from any email we have sent you by using the ‘unsubscribe’ option at the bottom of our marketing emails. Make sure to notify us or unsubscribe for each account or email address you have left with us.

6.2 For research participants, you can opt in to be included in our mailing list to receive newsletters which may include information about future research studies that may be of interest to you and for which you may be eligible.

6.3 Personal or sensitive information that we collect about you is only passed onto the relevant third parties for the purposes of assessing your eligibility for research trials or for those third parties to include you in their research trials. We will never pass your information onto third parties for marketing purposes.

7. Cookies

7.1 Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Our cookies do not contain any personally identifying information, but they do enable us to provide features designed to enhance the service we provide. Most web browsers automatically accept cookies, but you can change your browser to prevent that. Even without a cookie, you can still use most of the features on our website, including signing up for studies or email alerts.

7.2 For information on cookie settings of your internet browser, please refer to your browser’s manual.

8. How do we protect your information?

8.1 We respect your privacy and we are committed to safely storing and maintaining your personal information. We take reasonable steps to ensure your personal information is protected from unauthorised access, loss or misuse and have adopted security protocols, including using software to monitor traffic and identify unauthorized attempts to upload or change contents on our website.

8.2 We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

9. Accessing and correcting your information

9.1 Subject to any applicable exceptions in the Privacy Act, you may contact our privacy officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time.

9.2 On the rare occasions when we refuse access, or refuse to make a correction, we will provide you with a written notice stating our reasons why.

9.3 We will respond to all requests for access to or correction of personal information within a reasonable time frame.

10. If you are a resident of the European Economic Area these additional rights apply to you

10.1 We are a data controller of your personal information for the purposes of the General data Protection Regulation 2016/679 (GDPR).

10.2 Under certain circumstances, the GDPR grants you certain rights in relation to your Personal Information. In summary, you have the right to:

(a) request access to your personal information (known as a data subject access request);

(b) request rectification of incomplete or inaccurate personal information that we hold about you;

(c) request erasure of your personal information (and we will comply with such a request unless there is a reason for us to continue to hold and process it);

(d) object to processing of your personal information in certain circumstances, for example, if you feel our processing impacts on your fundamental rights and freedoms;

(e) request restriction of processing of your personal information;

(f) request the transfer of your personal information to you or to a third party; and

(g) withdraw your consent if we are relying on consent to process your personal information.

10. 3 To exercise any of the above rights, please contact our privacy officer on the details below

11. Resolving personal information concerns

11.1 If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our privacy officer.

The Privacy Officer

Address:	Suite 260
	585 Little Collins Street
	Melbourne VIC 3000
Telephone:	(07) 3054 7094
Email:	[email protected]

11.2 We take all complaints seriously and will respond to your complaint within a reasonable time period.

11.3 You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

(a) In Australia, the relevant authority is the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at www.oaic.gov.au, by emailing [email protected], or by calling 1300 363 992.

(b) Contact details for data protection authorities in the European Union can be found here.