Privacy

Wondros Privacy Policy

Last updated: March 31, 2022

This Privacy Policy (“Policy”) discusses Hungry Heart Media, Inc. d/b/a Wondros’ (“WONDROS,” “we,” “us,” or “our”) practices relating to the collection, use, and disclosure of personal information through our websites, which include the Clinical Trials Guide, (“Websites”). For the purposes of this Policy, the term “Websites” refers collectively to Wondros.health, Wondroshealth.com, and Wondros-health.com. We respect your privacy and have developed this Policy to demonstrate our commitment to protecting your privacy.

This Policy is incorporated into and made part of our Terms. Please read our Terms and this Policy carefully. It is your choice whether or not to provide personal information to us. If you choose to do so, you are giving us your express consent to use, process, and disclose your personal information as set forth in this Policy. If you choose not to provide your personal information to us, you may not be able to use the full extent of our Websites.

Scope of this Policy

This Policy is intended to describe how we process personal information relating to the use of and/or subscription to our Websites.

This Policy does not apply to information that:

we collect offline or through any other means not listed above,
is collected by any third party, including through any application or content that may link to or be accessible from or on the Websites, and
we collect from our employee and non-employee workers, job applicants, job candidates, or independent contractors.

In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identified such as a name, an identification number, location data, and online identified or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.

Personal information is required for us to be able to provide certain features of our Websites or services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to companies that help us to provide those services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use certain features of our Websites or services.

Our Websites may contain links that enable you to share content on social media, and to other websites (i.e., the clinical trial sponsors’ websites and clinicaltrials.gov) or to third-party apps that do not operate under this Policy. These third-party services, websites, and apps may independently solicit and collect personal information from you and, in some instances, provide us with information about your activities on those websites. We encourage you to review the privacy statements of all third-party websites you visit to understand their privacy practices.

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review each such third party’s privacy statement and other otherwise understand its privacy practices, before providing personal information directly to it.

Personal Information We Collect

We collect personal information to operate effectively and provide you with the best experiences with our Websites. As described in further detail below, you provide some of this information directly, such as when you create an account or contact us. We also collect some of your information, such as your IP address, automatically when you visit and use our Websites.

Information Provided by You

We ask for and may collect personal information about you such as your name, e-mail address, and zip code. The most common of these circumstances where you would provide personal information include the following:

Registering to create an account on our Websites: In order to create a user account, you may be required to provide your first and last name, email address, and zip code.
Personalizing and customizing your account: Once you have created your user account, we may ask you questions to help us customize your account (such as, whether you are looking for trials for yourself or a loved one, whether you are looking for trials to manage as a study trial manager), and whether you want to receive notifications from us (i.e., whether you would like to receive notifications for trial updates or keyword alerts).
Contacting us: When you contact us, we may ask you to provide, or confirm, personal information so that we can respond to your request.
Receiving our newsletters, or marketing or promotional communications: If you sign up to receive email notifications of trial updates or key word updates, our newsletters, or promotional communications or notifications from us, we may ask you to provide your personal information (such as your name and email address) so that we can provide these to you.

We do not receive or store any of your financial information or payment processing information.

Information that We Collect From You On Our Websites

We also may use various technologies to collect information from your computer or device and about your activities on our Websites.

Information collected automatically: We may automatically collect information from you when you visit our Websites. This information may include your IP address, location data, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information. We use Google Analytics to collect information. You can learn about how Google Analytics collects and processes data here.

Cookies: When you visit our Websites, we may assign your device one or more cookies to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Websites. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Websites, we will record your user or member ID, which is your email address, and the name on your user or member account in the cookie file on your computer. We store your unique member ID in a cookie for automatic sign-in. This cookie is removed when you sign-out. For security purposes, we will encrypt the unique member ID and any other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Websites may not function properly.

Other technologies: We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Websites. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to users of our Websites to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on your device, web beacons are embedded invisibly on the web pages (or in emails) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count visitors to certain pages, and to understand usage patterns. We also may receive an anonymous identification number if you come to our Websites from an online advertisement displayed on a third-party website.

Information Collected From Other Sources

We may also obtain information about you from other third parties. We may combine this information with information we collect through our Websites or from other sources.

How We Use Personal Information

While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

We may use information that we collect about you to:

register and create your own user account on our Websites
personalize content and enhance your user experience on our Websites such as sending you information on clinical trials or editorial content that may match your interests based on your answers to screening questionnaires or your saved searches
deliver the services or information that you have requested
administer surveys and questionnaires, and perform corresponding analysis
for marketing purposes, including helping us create and deliver content most relevant and impactful to you, develop and display marketing and advertising tailored to your interests on our site, and measure and improve the effectiveness of our marketing campaigns (if you prefer that we not contact you in this manner please follow the Opt-Out instructions elsewhere in this Policy)
perform research and analysis about your use of, or interest in, our Websites
aggregate or de-identify information
for service administration where we need to contact you for reasons related to our Websites (for example, where we need to send you a link to reset your password; notify you about updates to our Websites, this Policy, or our Terms of Use; manage your account; provide you with customer support, or otherwise contact you in response to your requests, comments, and questions)
enforce our terms and conditions
manage our business and perform functions as otherwise described to you at the time of collection
protect against or identify possible fraud
for legal compliance purposes

Sharing of Personal Information

As discussed more fully below, we share your personal information as necessary to provide the services you request, including sharing information with service providers; when required by law; to protect rights and safety, and with your consent.

We may share personal information with:

Our service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include customer relationship management software; website hosting; web forms for questionnaires; email marketing vendors; providing customer service; performing business and operations analysis; and supporting our Websites. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

Other situations: We also may disclose your information:

In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms and conditions or other agreements or policies.
In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
When you provide us with your consent to share your information with third parties.

Third-Party Privacy Policies: Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

Aggregated and Non-personal Information: We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties.

Transfer of Information

Your personal information may be transferred to, stored, and processed within the United States. Additionally, we may transfer your personal information to other countries in certain circumstances, for example because a server or third party service provider is located there. BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO ANY TRANSFER, STORAGE, AND PROCESSING IN ACCORDANCE WITH THIS POLICY.

There are potential risks to you associated with transferring your information to the United States due to the absence of an adequacy decision and appropriate safeguards. These risks include the risk that you will not be able to exercise your data protection rights under applicable law to protect yourself from unlawful use or disclosure of your information. The data protection and privacy laws of other countries, including the United States, may not afford you the same level of protection as those in your own country.

Your Privacy Rights

How You Can Access Your Information

If you have an online account with us, you have the ability to review and update your personal information online by logging into your account. You can also review and update your personal information by contacting us using the contact information provided below.

You may request to have all of your personal information collected by us removed from our database by submitting a request to our contact as set forth in the Section below entitled “Contact Us,” identifying the subject as “Privacy.” We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Websites or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties’ policies.

Your Choices About Collection and Use of Your Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Websites because such information may be required in order for you to create an account, participate in a survey; or ask us questions.

Opt-Out

When you create a user account on our Websites, you may be given a choice as to whether you want to receive marketing or promotional e-mail messages. At any time you can choose to no longer receive marketing or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication. You may modify your choice at any time by using the “Opt-Out” link as described above. It may take up to 10 business days for us to process an opt-out request. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

Even if you opt-out of receiving marketing or promotional communications, you may continue to receive other types of transactional and relationship e-mail communications, such as service announcements, notifications relating to your account, and surveys.

Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law or defined in an agreement. We may retain personal information for longer where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

We will also retain usage data for internal analysis, to strengthen the security, or to improve the functionality of our Service.

Children’s Personal Information

Our Websites are not directed at children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you may not use our Websites or provide your information to us through the Websites or otherwise. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy.

Security

The security of your personal information is important to us. We follow generally accepted standards (including by taking physical, electronic and procedural measures) to protect the personal information that we collect and process.

While we are focused on the security of your personal information and follow standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov for information about how to protect yourself against identity theft.

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

Changes to this Policy

We may modify this Policy from time to time and will notify you of any updates to our Policy by posting the revised Policy on our Websites. The last updated date set forth at the top indicates the last time we revised this Policy. We encourage you to review the Policy each time you visit our Websites to see if this Policy has been updated since your last visit.

Additional Information for Residents in Certain Jurisdictions

California

In this section, we provide information for California residents as required under California privacy laws, including the California Consumer Privacy Act (the “CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information.

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The Section above entitled “Personal Information We Collect” sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Section above entitled “Personal Information We Collect,” and for the purposes described in the Section above entitled “How We Use Personal Information.”

If you are a California resident, the CCPA grants you certain rights and imposes restrictions on particular business practices as set forth below:

Do-Not-Sell: California residents have the right to opt-out of the sale of their personal information. We do not sell personal information.
Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Delete are described below.
Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed and sold about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

categories of personal information collected;
categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties with whom we have shared their personal information;
categories of personal information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and
categories of personal information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.

Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

If you are a California resident and would like to make a request to exercise your rights under the CCPA, please contact us as set forth in the Section below entitled “Contact Us.” Please allow forty-five days for a response.

An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, or requests to delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Section below entitled “Contact Us.”

Do Not Track Disclosure

We do not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information

Contact Us

If you have any questions about this Policy or our privacy practices, please contact us by e-mail or postal mail as follows:

WONDROS

Attn: Legal

5450 W Washington Blvd

Los Angeles, CA 90016

Email: privacy@wondroshealth.com