Privacy Policy

The following Privacy Policy (the “Policy”) describes how RespondHealth handles your personal information, including related study information, collected from or about you when you use any part of the RespondHealth ecosystem, including our mobile applications and websites (collectively, the “Platform”). This Policy is part of and incorporated into the Terms of Use Agreement applicable to the Platform. By visiting or using the Platform, you agree to accept the practices described in this Policy. If you do not agree, do not access or otherwise use the Platform.

This Policy applies only to information collected through the Platform. Any information collected outside the Platform in connection with a research study (the “Research Study”) will be treated solely in accordance with the informed consent form you signed before participating (the “Informed Consent”).

A. Your health information

To use the Platform, you will need to create a RespondHealth Account. Your Research Site will provide us with an ID number, your phone number, and your email address to set up your Account, and will provide a username and password to finish creating it. The Account gives you control over who can access your Personal Information.

We provide access to the Platform on behalf of the investigator and research site at which you are participating in the Research Study (the “Research Site”). Personal Information collected on behalf of your Research Site may be protected by privacy laws in your country of residence. Our collection, use, and disclosure of that information will be done in accordance with your Informed Consent and those laws. Where this Policy conflicts with the Informed Consent or applicable laws, those documents shall govern.

B. The information we collect

When you create an Account or use the Platform, we may collect personally identifiable information (“Personal Information”) including participant ID, email address, phone number, and self-reported study responses. Self-reported responses are considered Personal Information unless they are no longer associated with identifying information.

RespondHealth records information about your use of the Platform (such as logins and the time and date of survey response submissions) and certain technical data about your device, operating system, and peripherals.

C. How we use the information we collect

1. To provide you with information. We may use Personal Information to send reminders and communications related to your participation in the Research Study, including verification of username and password and Platform updates.
2. Anonymous and aggregate information. We may anonymize Personal Information and aggregate it with information from other users to publish trend statistics, medical studies, reports, lessons learned, and white papers. None of this aggregate information identifies an individual.
3. Coded information. In connection with the Research Study, we replace identifying information with a participant ID number to create “Coded Information.”
4. Other uses. We may use information to detect fraud, IP infringement, violations of our Terms of Use, and other misuses of the Platform; and to conduct research and administrative functions.
5. Customer support. We may use Personal Information from you when you contact our support team to investigate and resolve issues.

D. Sharing your information

Other than as described in this Policy, we do not sell or provide your Personal Information to unaffiliated third parties. As described in your Informed Consent, we will disclose Coded Information to your Research Site for the Research Study and for storage and processing during and after the study. We may also disclose Personal Information to service providers who work on our behalf and have agreed to comply with this Policy, or otherwise in accordance with your Informed Consent and applicable law.

If we are involved in a merger, acquisition, sale, or similar event, your information may be included in the transferred assets. We will take appropriate actions to prevent such information from being disclosed to a third party in such an event.

We may share anonymous and aggregate information only as permitted by your Informed Consent. We may also disclose Personal Information in response to lawful requests by public authorities, including national security or law enforcement requirements.

E. Security

We maintain administrative, technical, and physical safeguards designed to protect the information we collect. No system is 100% secure, and we cannot guarantee absolute security. We are not responsible for the security of information you transmit over networks we do not control.

• Industry standard encryption for sensitive information at rest and in transit.
• Production, processing, and research environments are kept separate, with access restricted and limited to essential personnel. Information is de-identified or pseudonymized.
• Formal incident management program designed to ensure secure, business continuous service.
• Formal data breach procedure consistent with our privacy and security policies.
• State-of-the-art intrusion detection and prevention measures.

F. Your privacy choices

1. If your contact information changes, if you no longer wish to receive communications, or if you wish to modify settings, please email clientsupport@respondhealth.net.
2. You may access, update, or change your Personal Information within your Account Settings. To delete your Account, email clientsupport@respondhealth.net. Note that deleting your Account will not remove information already provided to your Research Site.
3. To opt out of your information being used for any purpose, email optout@respondhealth.net. To stop email communications, click “unsubscribe” at the bottom of any email.
4. Unless you request deletion, we store your Personal Information as long as your Account is open or as required by law.

G. Children’s privacy

The Platform is not intended for, and does not knowingly collect information from, children under the age of 13. A parent or guardian assumes full responsibility for any information about a child provided to RespondHealth. If you become aware that a child has provided us information without consent, please contact our Privacy Officer.

H. Changes to this policy

We reserve the right to update this Policy from time to time by posting a new version on this page. Continued use of the Platform after changes are made constitutes acceptance of those changes. If we make any revisions that materially change how we use or share previously collected information, we will give you the opportunity to consent before applying them.

I. Data Privacy Framework

RespondHealth complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. RespondHealth has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles for personal data received from the European Union. To learn more, visit dataprivacyframework.gov.

With respect to Personal Information received or transferred under the Data Privacy Framework, RespondHealth is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. We act as the “processor” on behalf of the “controller” and perform data processing within the bounds of the controller’s mandate.

J. Complaints

If you believe we have infringed your rights, contact us so we can address your concerns informally:

If you do not receive timely acknowledgement, you may submit your complaint to PrivacyTrust, an independent third party, at privacytrust.com/drs/respondhealth. The services of PrivacyTrust are provided at no cost. As a last resort, EU and EEA individuals may seek redress from the DPF Panel, a binding arbitration mechanism.

K. Data retention

We store your Personal Information only as long as necessary for the purposes for which it was collected, or as required by law.

L. Contact information

The Office of the Privacy and Data Protection Officer can be reached using the contact information below.