Last updated: January 22, 2020
PRIVACY NOTICE. PLEASE READ ALL OF THIS NOTICE. YOU WILL BE ASKED TO CONSENT TO THE USE OF YOUR PERSONAL DATA BEFORE YOU SUBMIT IT.
The sponsor of this study has engaged a third-party – Definitive Media, Corp. (doing business as THREAD) to collect the registration and study data you elect to provide. THREAD collects personal data to determine whether you qualify to participate in the study or to supply your study data to the researchers (the “study team”) for the purpose of the study. THREAD collects this data through the registration website or through a study application THREAD operates on behalf of the study team.
THREAD and the study team have entered into a legal agreement that addresses the handling of your personal data.
When you register, THREAD collects from you, data necessary to determine whether an individual does, or does not, qualify to participate in the study. Under the terms of THREAD’s contract, THREAD may share this personal data with study team members only if you qualify as a potential participant in the study.
When you become a study participant, THREAD maintains the study application that gathers the personal data and information necessary to the research. THREAD does not always know exactly what data your study team collects using this application. THREAD uses and stores personal data collected through any device or application only in deidentified, tokenized form. THREAD may be asked by the study team to share personal data in a deidentified form.
The notice below provides important information about how we protect the data we collect through the registration website and the study application.
What We Collect and How We Use It
The type of personal data we collect depends on whether you are registering for a study or participating in a study and using one of the study applications.
THREAD collects personal data necessary to determine whether you qualify for the study. You submit this personal data in response to the questions asked on the registration website. The study team determines what data it needs to qualify candidates and the questions to be asked – THREAD does not. THREAD only provides the study team with the results of the registration process and the personal data of qualifying individuals. The information that may be collected includes, but is not necessarily limited to: name, pass or fail outcome to the verification questions, and responses to qualification criteria determined by the study team. This data is used by the study team to place prospective participants in research studies. Once qualified, you will be asked to provide contact information in order to ship study materials to you. This information may include, but is not necessarily limited to: your name, mailing address, phone number, and email address.
Your study team uses an application to collect certain data from you to facilitate the research study. THREAD also requires that you provide us with an email address to enable you to sign in to the application and to retrieve a forgotten password.
This application may be used to collect certain types of information, including, but not necessarily limited to:
- Data generated or collected by your mobile device sensors, including accelerometer, gyroscope, proximity sensor, ambient light sensor, camera, compass, and barometer.
- Data obtained through the study application, such as your responses to surveys and questions.
- Data generated or collected by a third-party FDA-listed medical device, wearable device, health application or similar device, wearable or tool that collects data and information from the participant.
THREAD does not always know exactly what data your study team collects using this application. THREAD uses and stores data collected through any device or application only in deidentified, tokenized form, and may share such data with the study team for purposes of carrying out the study.
How We Share Data With Third Parties
THREAD may share your personal information with
- The study team when you ask us to share it, for example, in order to submit your application.
- A third-party service provider hired to help operate our business.
- Those who need it to satisfy a legal or regulatory requirement.
How Long We Keep Your Information
THREAD maintains data about you only for as long as we have a legitimate business need or for as long as the study team may require, which may be as long as 25 years if you qualify as a study participant.
Information About Children
Study applications are not intended for, nor designed to attract, individuals under the age of 18. We do not collect personally identifiable information from any person we know to be under the age of 18 without explicit consent from their parent or guardian. We require individuals under 18 to obtain such consent prior to using our study applications.
Cross-Border Transfers of Data and Where We Store Your Information
THREAD stores, transfers, and processes your information, including personal information, on servers primarily located in the United States and in other locations that THREAD deems necessary or convenient to provide its services. THREAD adheres to the principles in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and is in the process of self-certifying that adherence to the U.S. Department of Commerce.
THREAD’s handling of personal data is subject to investigation by the U.S. Federal Trade Commission (FTC). THREAD has designated JAMS as its Alternative Dispute Resolution (ADR) provider. JAMS is an independent body designated to resolve data-related complaints made by individuals. If THREAD is unable to resolve an issue with you, a complaint can be filed with JAMS at this link: https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.
If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. We agree to be subject to the investigatory power of the FTC to ensure our compliance with the Privacy Shield Principles. To learn more about the Privacy Shield program, please visit the Privacy Shield website. You can check on our status by searching for us under the name, Definitive Media, Corp.
Cookies and Tracking
When you access the THREAD website, we may automatically collect information as you browse. This information is sometimes referred to as web analytics and/or clickstream data, and may include, but is not necessarily limited to:
- The name of you Internet Service Provider (ISP)
- Browser type and version
- Operating system and device type
- Average time spent on our site(s)
- Pages viewed
- Information accessed
- The Internet Protocol (IP) address used to connect your computer to the Internet
- Other relevant statistics
We may combine this automatically collected log information with other information we collect about you. We do this to enhance the services we offer you, to improve marketing and analytics, and to support site functionality.
Exercising Your Data Rights
For Residents of the European Union
The General Data Protection Regulation (GDPR) provides EU residents with certain rights in their data. You have the right to access your data, and in some circumstances to correct or erase it. To exercise these rights, you can contact THREAD at firstname.lastname@example.org or our representative in the EU at email@example.com, work with our dispute resolution service, or your data protection authority. You may need to go through a verification process to ensure that we are providing the correct data to you and to determine if the study team is the controller of the information requested. You also have the right to lodge a complaint with a data protection authority. For more information, please contact your data protection authority.
In some instances, because we store certain data on a deidentified basis, we may not be able to associate particular data to you. THREAD is unable to remove information that is deidentified or tokenized upon collection as THREAD will not reidentify the information for individual users.
In the event we are unable to resolve any complaints you may have about our handling of your personal data, individuals may also file a complaint with our designated, independent, alternative resolution provider: JAMS. Information about JAMS can be found at their website: https://jamsadr.com/file-an-eu-us-privacy-shield-claim.
For California Residents
We are currently not required to comply with the California Consumer Protection Act (CCPA). At its discretion, THREAD may respond to California residents regarding their data with respect to the following:
- The categories of data we have collected and the categories of sources.
- The business purposes for sharing the data.
- The categories of third-parties with whom we have shared data.
- The ability to access the specific pieces of data we process and the right to delete your data.
For Nevada Residents
Nevada law provides residents with the right to review, correct or update their personal information and/or opt out of the sale of personal information. If you are a Nevada resident and would like to review, correct, or update your personal information, you or your authorized representative may submit your request to firstname.lastname@example.org. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.
We generally do not disclose or share personal information for profit. Under Nevada law, residents have the right to direct us to not sell or license your personal information to third-parties. To exercise this right, if applicable, you or your authorized representative may submit a request to email@example.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.
Third-Party Mobile Applications and Services
The THREAD mobile applications may contain links or references to third-party mobile applications, products, or services. Information collected by third-parties is governed by their privacy practices, and we encourage you to learn about the privacy practices of those third-parties.
Changes to Our Business
We reserve the right to transfer information to a third-party in the event of a sale, merger, dissolution, or other transfer of all or substantially all of the assets of THREAD, or in the event that we discontinue our business or file a petition, or have filed against us a petition in bankruptcy, reorganization, or similar proceeding, provided that the third-party agrees to adhere to the terms of this Privacy Statement.
How to Contact Us
Should you have other questions or concerns about these privacy policies or procedures, or any other privacy related concerns or complaints, please email us at: firstname.lastname@example.org.
You may also contact us by mail at:THREAD Research
155 El Camino Real, Suite B
Tustin, California 92780
Our Data Protection Officer can be contacted at: email@example.com. The telephone number for the DPO is 714.730.4958.
If you are in the EU, then you may contact our representative in Europe at: firstname.lastname@example.org.
California and Nevada residents may contact our DPO, as above, or email us at: email@example.com.