Privacy Policy

This "Privacy Policy" describes the privacy practices of Rxtraresearch and Rxtra Research Public Benefit Corporation (collectively, "Rxtraresearch", "Rxtra Research", "we", "us", or "our"). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information from users of our websites (including rxtraresearch.com and teamscopeapp.com and rxtraresearch.com) and related services, (collectively, our "Services") and explains the rights and choices available to individuals with respect to their information. This Privacy Policy governs any of the Services on which the Privacy Policy is posted. It applies to the users of our Services ("Users"), research participants, academic institutions, and our business customers  "Customers" and, to the extent that Customers share it with us, their employees and authorized users’ data.  For purposes of the GDPR, the Customer is the controller of Customer Data. Rxtraresearch is not the controller of and does not have ownership of Customer Data. Please direct any questions regarding Customer Data to the Customer for which you work or which collected your information using a Rxtraresearch platform or application.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Categories of Personal Information We Collect

We may collect a variety of personal information from or about you or your devices from various sources, as described below.

A. Information You Provide To Us

• Personal and Business Contact Information. If you request a demonstration, or interact with our business team, we may request information such as your first name, last name, postal address, email address, telephone number, job title, and employer name.

• Qualification Information. If you sign up to participate in clinical trials, we will collect the responses you provide through the Services such as answers to eligibility questions relating to clinical trials, which may include your gender, date of birth, health information, genetic information, medical records, location information, demographic information, living situation, education, or employment information. These questions will vary based on the specific clinical trial.

• Registration and Profile Information. If you sign up for an account, register to use our Services, sign up for notifications or updates, or participate in our surveys, we may ask you for your first and last name, username and password, email address, telephone number, organization or institution name, department name, industry, interests, and preferences.

• Medical Information. If you choose to upload your medical records to our Services, we will receive the contents of the medical or health related information.

• Feedback and Correspondence. If you contact us directly, we may receive additional information about you, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

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B. Information Automatically Collected

Location Information. We may infer your general location information, for example by using your internet protocol (IP) address.

Device Information. We may collect an IP address from visitors to our Services. We use IP addresses to help diagnose problems with our server(s), to administer the Services, and to monitor activities on and interactions with our Services.

We may also automatically log information about the device and software you use to access our Services. For example, we may log operating system name and version, device manufacturer and model, browser type, browser language, screen resolution, application installations, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services such as the pages or other content you view, the website you visited before browsing to our Services, the searches you conduct, your comments, any content you post, how long you spent on a page, access times and information about your use of and actions on our Services.

Information from Cookies and Similar Technologies. We and our third party partners collect information about you using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Please refer to the Cookies and Similar Technologies section for more details.

C. Information We Receive From Third Parties

Information from third party services. If you choose to link our Services to a third party account, we may receive information about you, including your profile information and your photo, education information, genetic information, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.

Medical Records. With your permission and at your direction, or at the request of a study site for a clinical trial in which you are participating, we may receive your electronic medical records from third parties such as a hospital, doctor, or other health facility. If your medical records are provided solely at the request of a study site for a clinical trial in which you are participating, our use of those records is in accordance with the informed consent for the clinical trial and the privacy policy of that study site.

Public Information. We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services for the purpose of analyzing and improving the Services that we provide.

Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you for the purposes of being able to provide you with marketing and similar opportunities that would be of interest to you, consistent with your expressed options regarding marketing communications.

For Marketing and Advertising Purposes

With your consent or as permitted by applicable law and consistent with this notice, we may use your information for marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant valuable or otherwise of interest to you.

How We Share Your Personal Information

No mobile information will be shared with third parties/affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. We do not rent or share your personal information without permission or as described in this policy.

Cookies and Similar Technologies

What Are Cookies?

We may collect information using "cookies." Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies We Use

Our Services use the following types of cookies for the purposes set out below:

• Essential Cookies. These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These are primarily used by our employees and contractors.

• Functionality Cookies. These cookies allow our Services to remember choices you make when you use our Services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences or re-enter information every time you visit our Services.

• Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered may include the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day and duration they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.

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Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the "settings," "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings. Please review your web browser's "Help" file to learn the proper way to modify your cookie settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit https://www.allaboutcookies.org.

Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. In addition, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Tracking Tags

We may also use tracking tags (which are also known as web beacons) on our Services to track the actions of users while on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, tracking tags are embedded on webpages. Tags compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using tracking tags is not linked to our users' personal data.

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no accepted standard on how to respond to "Do Not Track" signals, and we do not respond to such signals. To find out more about "Do Not Track," please visit https://allaboutdnt.com/.

Security

The security of your personal information is important to us. We make reasonable efforts to protect your information by using      various organizational, technical and physical measures designed to improve the security of the information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security or privacy of your information.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at dataprivacy@rxtraresearch.com.

International Data Transfer

Rxtraresearch is headquartered in the United States. Your personal information may be accessed by or transferred to the United States or to our affiliates or third parties elsewhere in the world. By providing us with your personal information, you consent to this transfer. We use commercially reasonable measures to protect the privacy of your personal information, regardless of where it is processed or stored. 

See Additional Information for the European Union. 

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via the contact information you have provided to us or another manner that we believe reasonably likely to reach you. This may include posting a specific announcement on our Services.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at dataprivacy@rxtraresearch.com, or write to us at:

Rxtraresearch
[ Office address ]
Attention: Data Protection Officer

Personal Information

References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by European data protection legislation.

Controller and Data Protection Officer

For the purposes of European data protection legislation, we act as the controller of personal information solely for data collected for marketing and sales purposes. This includes processing data to inform you about our products and services, respond to your inquiries, manage our promotional activities, and fulfill our legitimate interests in marketing and business development. Our Data Protection Officer can be reached at dataprivacy@rxtraresearch.com. See the "Contact Us" section above for additional contact details.

Legal Bases For Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the list below. If you have questions about the legal basis of how we process your personal information, contact us at dataprivacy@rxtraresearch.com.

• To provide the Services. Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

• To communicate with you;

• To create anonymous data for analytics; and for compliance, fraud prevention and safety. These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• To comply with law. Processing is necessary to comply with our legal obligations.

• With your consent. Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at dataprivacy@rxtraresearch.com.

Use For New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our Customers (including Contact, Identity, Financial and Transaction Information) for seven years after they cease being Customers for financial and tax purposes.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your Rights

For individuals located within the European Economic Area ("EEA"), European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails;

• Access. Provide you with information about our processing of your personal information and give you access to your personal information;

• Correct. Update or correct inaccuracies in your personal information;

• Delete. Delete your personal information;

• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice;

• Restrict. Restrict the processing of your personal information;

• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to dataprivacy@rxtraresearch.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

• Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.

• For transfers to third parties in the United States, ensuring they participate in the Data Privacy Framework.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Data Privacy Framework - EU-U.S., UK Extension, Swiss-U.S.

Rxtraresearch complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Rxtraresearch has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Rxtraresearch has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

As a participant in the Data Privacy Framework, Rxtraresearch is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Our accountability for personal information we receive in the United States under the Data Privacy Framework and subsequently transfer to a third party is described in the Data Privacy Framework Principles. In particular, we remain responsible and liable under the Data Privacy Framework Principles if third-party agents that we engage to process the personal information on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the Data Privacy Framework Principles, Rxtraresearch commits to resolve complaints about our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact Rxtraresearch at: dataprivacy@rxtraresearch.com

Rxtraresearch has selected a third party to serve as its independent recourse mechanism (IRM) for dispute resolution arising from certain transfers or processing of Personal Information (non-HR data) under Data Privacy Framework. Rxtraresearch has further committed to refer unresolved Data Privacy Framework complaints under the EU-US and Swiss-US Data Privacy Framework Principles to the EU Data Protection Authorities (DPAs). If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact your National DPA at https://edpb.europa.eu/about-edpb/board/members_en for more information or to file a complaint. The services of DPAs are provided at no cost to you. Under certain conditions, more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.     

Notice to Residents of California

We strive to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”), and the amendments and authority promulgated thereunder. 

We collect personal information from and about you for a variety of purposes. To learn more about the types of Personal Information we collect, the sources from which we collect or receive Personal Information, and the purposes for which we use this information, please see the rest of this policy.

We have collected the following categories of personal information from consumers within the last twelve (12) months:

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California Rights and Choices

CCPA provides California residents with certain rights regarding their personal information (subject to certain limitations at law). The following paragraphs describe these CCPA rights and explains how to exercise those rights. 

Right to Deletion

The CCPA allows California residents the right to request that we delete any Personal Information about you that we collect and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information to confirm your identity, we will delete (and in turn direct our service providers to delete, if applicable) your Personal Information from our records, unless an exception applies. 

A request may be denied if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;

• Debug products to identify and repair errors that impair existing intended functionality;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Enable solely internal uses that are reasonably aligned with consumer expectations;

• Comply with a legal obligation and requests from law enforcement agencies; and

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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Right to Opt-Out of the Sale of Your Information

Request Submissions 

To exercise the access and deletion rights under the CCPA as described above, please submit a verifiable consumer request by emailing us at dataprivacy@rxtraresearch.com.   

Verifiable Consumer Requests

A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests for access, which can only be made twice during a twelve (12) month period, and deletion must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Timeframe for Responding to Requests and Format

We will respond to your request within thirty (45) days of receipt. The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing. 

Fee

We do not charge individuals a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA prohibits a business from discriminating against California residents for exercising the rights outlined above. 

No Financial Incentive

We do not offer any financial incentives or price or service differences in an attempt to influence a resident’s decision whether or not to exercise a right afforded to the consumer under the CCPA.   

Authorized Agent

A California resident may use an authorized agent to submit a right to access request or a request to delete. 

Personal Information Related to Marketing

We may also collect name, business address, email address, and phone numbers of contacts for the purpose of business-to-business marketing of our Services. For example, we may collect your information from trade shows or from website inquiries and white paper downloads. We do not sell this contact information.

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Last Updated: March 5, 2025