MDC Performance Portal

Marketing Dashboard

MDC Performance Portal - Privacy Policy

TRUSTe

Effective Date: March 2018

This website (and the database behind it) is operated by MD Connect, Inc. ("MD Connect", "we", "us" or "our") to collect and house data collected from a variety of patient-facing websites ("MD Connect Websites") from individuals who may become patients at a particular practice or investigator site ("Patients"). We assist pharmaceutical and medical device companies ("Client(s)" or "Sponsor(s)") with recruitment of individuals to participate in clinical trials as well as medical practices looking to attract new patients. This Privacy Policy describes our personal information collection procedures for MD Connect Websites involved in clinical trial recruitment or which otherwise operate outside of the United States ("Covered MD Connect Websites") and the choices available to you and Patients regarding our use and disclosure of your and their personal information.

MD Connect collects, uses, and discloses personal information you and Patients share with us directly or voluntarily provide through use of this website (the "Site") and Covered MD Connect Websites (collectively the "Sites"), regardless of how you and they access the Sites or our services. This access may be through the use of a mobile device. We also may collect personal information through our service providers by means of phone conversations with Patients. By providing personal information to us directly or by using the Site, you are consenting to the terms and conditions of this Privacy Policy. Personal information collected by Patients is governed by the Privacy Policy shown on MD Connect Websites. The use of information collected through our service shall be limited to the purpose of providing services for which Clients engage MD Connect, which commonly includes sharing the information of potentially eligible clinical trial participants with local clinical sites participating in their trials or sharing the information of potentially interested patients with medical practices.

Passive Information Collection and Use

The Sites use a passive technology called "cookies" and other similar technologies. With cookies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as browser type, operating system and average time a visitor spends on our websites. MD Connect uses this information to help us understand our website activity and to monitor and improve our websites. Cookies also provide information about you and your preferences, and help us personalize your experience on our websites. You can set your web browser to notify you when cookies are being placed on your system or to not accept cookies. However, if you decide not to accept cookies from our websites, you may not be able to take advantage of all of the features available to you on our websites.

The Sites use another passive technology called "internet tags" or "web beacons". This technology allows us to understand which webpages you visit and helps us optimize and tailor our websites to you and other future visitors.

We partner with third parties to display advertising on our Sites or to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

Mobile Device Information

MD Connect also collects information from and about your mobile device, such as a unique device identifier.

Sensitive Information

Any request on our Sites or through our service providers for sensitive information will be limited to the Identified Stage of the Pre-screening Process, will require express consent (e.g., website check box, you voluntarily clicking a button (e.g. 'Submit') which clearly indicates doing so provides consent), and will be specific and necessary to Sponsors' clinical trial or medical practices' pre-screening requirements. Sensitive personal information that may be collected includes:

  • Medical conditions
  • Severity of condition
  • Medical test results
  • Age
  • Height & Weight
  • Lifestyle/habits (e.g. exercise, smoking)
  • Prior medical procedures
  • Medical symptoms
  • Ethnicity
  • Existing participation status or willingness to participate in a clinical trial
  • Choice of physician or medical clinic
  • Requested or actual appointment date and time

Information Collected in the Pre-Identified Stage of our Pre-Screening Process

When you or Patients visit our Sites or contact us, we collect personal information that you and they provide voluntarily. Most of our Sites contain a Pre-Screening Questionnaire (PSQ) where we collect personal information when Patients answer questions on the Sites or otherwise provide to us by telephone or email. During Pre-Screening, MD Connect only collects personal information that is limited and necessary to evaluate Patients eligibility and qualifications for participation in our Sponsor(s)' current and future clinical trials and Patients eligibility and appropriateness to visit medical practices. Many of our Sites will use a two-stage PSQ, where in the first stage we will ask questions that will not yet uniquely identify the Patient (the "Pre-identified Stage"). This information may include:

  • Medical and demographic information relevant to qualifying for a clinical trial
  • Location information (e.g. zip code in US)
  • Will NOT include any personally identifying information (e.g. name, email, phone number)

Uses and Disclosures of Information in the Pre-identified Stage of Pre-Screening

MD Connect uses and discloses the information collected at this stage for some limited purposes necessary to the operation of our business and the delivery of services to you. These purposes include to:

  • Determine whether Patients may be eligible to participate in a clinical trial,
  • Provide our services and generally manage and administer our business including maintaining business records for reasonable periods;
  • Develop and improve our services;
  • Respond to circumstances permitted or required by law, including defending and bringing legal actions; and
  • Ensure the security and integrity of our websites and operations.

If, through their answers at the Pre-Identified Stage, it is determined Patients will not be eligible for the relevant clinical trial(s) or medical practices, their answers may be stored for the relevant data retention period, but will not be individually identifiable (and thus are not Personal or Sensitive Information). In some cases, they will be asked if they wish to submit personal contact information so that they may be considered for future clinical trials.

If, through their answers at the Pre-Identified Stage, it is determined they may be eligible for the relevant clinical trial(s) or appropriate for a medical practice, they will be forwarded to a second stage of Pre-Screening.

Information Collected in the Identified Stage of Pre-Screening

The Identified Stage of the Pre-Screening Process requires Patients to express consent before submitting Personal or Sensitive information, which then may be collected via the Sites, phone or e-mail. Additional information collected at this stage may include:

  • Personal contact information, such as name, address, telephone number and email address;
  • Patient answers to additional PSQ questions on this Site, including age and basic medical information relevant to qualifying for a clinical trial or being appropriate for a medical practice;
  • Patient answers to additional questions, including medical information, that may be asked in a follow-up phone call from us or our service providers.
  • Location information (e.g. zip code in US)

We combine the personal information Patients voluntarily submit with other information we have collected from them (including that collected at the Pre-Identified Stage), whether on or off-line, to collectively create a record with Personal or Sensitive information for the purposes of determining their eligibility for Sponsor clinical trials. We may also combine it with information we receive about Patients from other sources.

Uses and Disclosures of Information in the Identified Stage of Pre-Screening

MD Connect uses and discloses personal information for a variety of purposes that are limited and necessary to the operation of our business and the delivery of services to you. These purposes include to:

  • Determine whether Patients may be eligible to participate in Sponsors' current clinical trial(s). During the recruitment period for these trials, we may provide Patient screening information and contact information to one of our Sponsor's investigator sites nearest to you;
  • Determine whether Patients may be eligible to participate in future clinical trial(s) of our Sponsors that are similar to the originally described clinical trial(s). In this situation, the information you provided at the Identified Stage of the Pre-Screening Process will be retained for up to 24 months. If you qualify for a future study, you will be contacted by e-mail or phone to determine your interest and consent to further screening.
  • Determine whether Patients may be appropriate for a given medical practice, and if so, pass along their Personal information to that practice.
  • Provide our services and generally manage and administer our business including maintaining business records for reasonable periods;
  • Develop and improve our services;
  • Reply to your requests, inquiries and comments;
  • Contact you via land line phone, cell phone, email, text message (cell and data charges may apply);
  • Respond to circumstances permitted or required by law, including defending and bringing legal actions; and
  • Ensure the security and integrity of our websites and operations.

MD Connect discloses personal information collected through its Sites to affiliated third party service providers, such as IT support services, customer service providers, and other services providers that support us and facilitate the services we provide to you. These companies are authorized to use your personal information only as necessary to provide these services to us. For example, we use Google Analytics, a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of this website, to prepare reports on its activities and share them with us, our contractors, and other Google services.

Google may also use the data it collects to contextualize and personalize the ads of its own advertising network. The personal data collected for this purpose is limited to cookie and usage data. You should refer to Google's privacy policy for more details about their data privacy practices related to this usage.

MD Connect may disclose information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You and Patients will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. Further, we may use and disclose information collected through the Sites as we believe to be necessary or appropriate, including: (a) as permitted by applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain. We may also disclose your personal information to any other third party with your prior consent.

MD Connect reserves the right to use the personal information collected as described above, in a de-identified or anonymized format, i.e. no longer personally identifiable as defined by data privacy regulations, for data aggregation and data analytics purposes.

Unaffiliated Third Party Sites and Services

MD Connect may make unaffiliated 3rd party sites and services available to you to access that require you to provide your consent to the services or products offered by the unaffiliated 3rd parties before access is granted to their site. This Privacy Policy does not address those unaffiliated 3rd party offerings. These offerings are governed by the Privacy Policy of the unaffiliated 3rd party and you should review their Privacy Policy before consenting to access their sites. MD Connect is not responsible for the personal information you provide to these unaffiliated third parties sites, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of or inclusion of a link to any unaffiliated 3rd party site or products on the Site does not imply or serve as an endorsement of it, its services or products by MD Connect.

Use of Site by Minors

Use of this Site, our Sites or our services is not generally directed to individuals under the age of 18, and we request that these individuals not provide Personal Information through the Sites or our service providers unless identified as appropriate in the Pre-Screening criteria. However, there may be some Sponsors of clinical trials or medical practices that are specifically seeking this age group. In such cases, parental consent may be required as part of the Pre-Screening process.

If personal information related to individuals under the age of 18 is identified and deemed inappropriate, reasonable steps will be taken to delete the information.

Security

MD Connect uses reasonable measures in an attempt to protect your and Patients' information, such as using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please notify us immediately by contacting privacy@mdconnectinc.com or by faxing to 781-235-0929.

Choices and Access

By providing us with personal information at either Pre-Screening Stage, you and Patients are consenting to our collection, use and disclosure of their personal information as described in this Privacy Policy.

Upon request MD Connect will provide you and Patients with information about whether we hold any of your or their personal information. If you wish to change your preferences about the personal information you provided to us or wish to withdraw your consent to its retention, use or disclosure, please contact us at privacy@mdconnectinc.com or by faxing to 781-235-0929. However, please note that our response to your request to withdraw consent is subject to legal or contractual restrictions and reasonable notice, including where we have provided or are providing services to you, your consent will be valid for as long as necessary to fulfill the purposes described in this Privacy Policy or otherwise stated at the time of collection.

If you would like to review, correct, update, or delete the personal information that you have provided via the Site, please contact us at privacy@mdconnectinc.com or by faxing to 781-235-0929. We will reply to your request in a reasonable period of time not to exceed 60 days.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Retention Period

We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

Cross-Border Transfer

Your information may be processed in the country in which it was collected or transferred to other countries, including the United States (where our servers are generally located), for processing where laws regarding processing of information may be less stringent than the laws in your country. By using this Site and our services, you consent to the transfer of your personal information to countries outside of your country of residence, including the United States.

Platform Data Collection

MD Connect collects information under the direction of its Clients and occasionally for potential future Client use, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

MD Connect acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to MD Connect's Client (the data controller) or MD Connect directly. If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Clients. MD Connect will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Updates to This Privacy Policy

This Privacy Policy may be revised from time to time. Any changes to this Privacy Policy will become effective when the changes are posted in a revised Privacy Policy on the Site. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.

Your continued voluntary provision of personal information or use of the Site following these changes serves as consent to the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@mdconnectinc.com. or by faxing to 781-235-0929.