Privacy Statement

Last Updated Date: March 6, 2020

TrialCard is committed to maintaining the privacy and security of your personal information. This Privacy Statement summarizes how TrialCard Incorporated (“TrialCard”, “we”, “us”) collects and utilizes personal information. This Privacy Statement applies to information we collect through our website at corp.trialcard.com and mobile versions of our website (collectively, the “Site”), by phone, at conferences or events, and anywhere else where we display this Privacy Statement (collectively, the “Platforms”). By continuing to access or interact with our Platforms, you accept the practices described in this Privacy Statement as of the last updated date and application of this Privacy Statement to the collection, use and disclosure of your personal information as described herein.

We want to give you the opportunity to know what information we collect, how we use and disclose it, and your rights and choices with regard to that information.

You should check this Privacy Statement regularly to see if there have been any changes.

Information We Collect and Sources of the Information

Information You Provide. If you wish to utilize certain features of our Platforms, you may be asked to register. Those features currently include:

• Access to dashboards, white papers, brochures, product fact sheets and other publications
• Use of certain TrialCard products made available online
• E-mail newsletters subscriptions

The information collected when a user registers may include but is not limited to: full name, e-mail address, physical or mailing address and area of interest information. If you register on our Platforms, we may use this information to contact you about our products and services or to follow up with you on information or services you requested.

Information Collected Automatically. We may also automatically collect and receive your personal information when you visit the Site. We use this information, which typically remains in aggregate form and does not identify individual users, to improve the Site and the services we offer. If a combination of information we collect does identify you as an individual, we will treat the combined information as personal information. The following are examples of how we automatically collect information through the Site:

Cookies. A “cookie” is a small data file stored on your computer’s web browser, or other passive means of data collection. Cookies are used to personalize your visit, remember your preferences, or to enhance your experience with our Platforms. We do not enable “cookies” on our Platforms with one exception. We and our service providers (including our website host) use cookies as part of our system administration for the Site, in order to track how users interact with the Site (e.g., to track user sessions and comments, to remember settings and search history, for analytics tracking or functionality). We use this information to detect and resolve website problems, enhance the features of our Site, and to assist with customer support.

Browser and Device Information. Our web server automatically collects information from your computer and navigation patterns when you visit the Site, including your Internet Protocol (IP) address, the computer’s operating system, the type of browser you use, and the specific web pages visited during your connection. We may also track data such as the total number of visits to the Site and the number of visitors to each page of the Site. We do not track users over time and across sites.

TrialCard may also share statistical or demographic information in aggregate form with third parties for marketing or research purposes. This aggregate data will not contain any information that identifies you individually. TrialCard does not share, sell, rent, or trade personal information with third parties for their commercial purposes. We also do not permit third parties to track users of the Site over time and across sites for the third party’s direct marketing purposes. The Site also uses analytics tools such as Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how you use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google in aggregate form. Google uses this aggregated information on our behalf in order to evaluate use of the Site, compile reports on Site activity and other services relating to Site activity and usage. You can learn more about Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout.

How We Use Information

We may use your personal information to accomplish our business and commercial purposes including to:

• Respond to your questions or fulfill your requests or otherwise provide our services or Platforms
• Personalize your experience and provide user-experience features of our Site and Platforms
• Administer our business, enhance our services and products using analytics
• Enable you to register for an account or submit your questions
• Protect our legal rights or the health or safety of our customers or others
• Comply with our legal obligations or to respond to law enforcement or legal and regulatory inquiries or requests

How We Share Information

Except as described in this Privacy Statement, we do not share your personal information outside of our corporate family of companies without your consent. When appropriate we share your information with:

• Our parent company, subsidiaries and affiliates for business operations and to send you information about products or services we think may be of interest to you.
• Service providers who provide services to support our operations. All service providers are contractually required to protect your information and are prohibited from using it for their own marketing activities or purposes other than providing services to us.
• Third parties when required by law or to comply with valid legal process (such as a search warrant, subpoena or court order) or to protect TrialCard’s rights or property, or during emergencies when safety is at risk.
• Successor entities in the event of a transfer of control of TrialCard or substantially all of its assets.

Your Rights and Choices

Update or Amend Your Information. We want to keep your information accurate and up-to-date. Therefore, if you believe that your contact information needs to be updated, you can email us at PrivacyPolicy@trialcard.com or call us at 919-845-0774 (between the hours of 9:00 am and 5:30 pm Eastern) to correct or update your contact information.

Communication Preferences. You may choose at any time to remove your name, telephone and fax numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by emailing at PrivacyPolicy@trialcard.com or calling us at 919-845-0774 (between the hours of 9:00 am and 5:30 pm Eastern).

If you are a California resident, see the “Notice to California Residents” section below for more information on your rights and choices.

Links to Other Website

Other websites you visit — including those linked from the TrialCard website to social media platforms or other third-party sites — are independent from TrialCard and may have their own privacy policies. Other websites might use personal information differently than this Privacy Statement permits. We strongly encourage you to review the privacy policies of any site before providing any personal information. We are not responsible for the privacy practices or content of third-party websites.

Security

We use reasonable and appropriate safeguards to protect personal information from unauthorized access or use. We also contractually require our vendors to protect personal information from unauthorized access or disclosure.

Changes to this Privacy Statement

We reserve the right to modify this Privacy Statement at any time and may apply changes to previously collected information, as permitted by applicable law. We may periodically update our privacy policy to describe how new features may affect our use of your information. Any material updates to this Privacy Statement will be posted on the Site and we will indicate the last updated date of the changes. Be sure to periodically reread this Privacy Statement to take note of such changes. Your continued use of the Site or our Platforms indicates your acceptance of the practices described in this Privacy Statement as of the posted updated date.

Do Not Track Signals

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, TrialCard does not currently respond to “Do Not Track” signals from a visitor’s browser. For more information about do not track signals, please visit https://allaboutdnt.com/.

Children’s Privacy

The Site is note intended for use by children under the age of 16. TrialCard does not knowingly collect or solicit personal information from children under the age of 16 or knowingly allow such persons to register on the Site. Should we learn that someone under the age of 16 has provided any personal information to or on the Site, we will remove that information as soon as possible.

Notice to California Residents

The information included in this section applies to residents of California. If you have questions about this Privacy Statement, including anything in this section for California residents, or would like a printed copy of this Privacy Statement, please contact us using the contact information at the bottom of this Privacy Statement. You may also print a copy of this Privacy Statement by selecting the “Print” button in your web browser.

Collection of Personal Information. For details on the personal information (as defined by the California Consumer Privacy Act of 2018 or the “CCPA”) we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting that information, and the third parties with whom we shared that information, please refer to the corresponding sections of this Privacy Statement as follows:

• Information We Collect and Sources of the Information – Categories of personal information we collected and the sources from which personal information was collected
• How We Use Information – Our business or commercial purposes for collecting personal information
• How We Share Information – Third parties with whom we shared personal information

Your CCPA Rights and How to Exercise Them

If you are a California resident, you have certain rights, pursuant to the CCPA. These CCPA rights may only apply in certain circumstances and are subject to certain exemptions.  Please see the information below for a summary of your rights and how to exercise your rights. Please note that we may ask for certain information as necessary to verify your request in accordance with applicable law.

• Right to Know. You have the right to request that we disclose what pieces of personal information we collect, use, disclose and/or sell about you. To exercise your right to know, please submit your request to PrivacyPolicy@trialcard.com.
• Right to Delete. You have the right to delete personal information that we collect or maintain about you. To request deletion of your information email PrivacyPolicy@trialcard.com or call 919-845-0774 . You will be required to provide certain information which we will use to verify your request. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law. We will notify you of any such exceptions as applicable to your request.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to request deletion, or right to opt-out of sale in accordance with applicable law.

You can exercise your CCPA rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request.

Disclosure of Personal Information

• We did not share, sell, rent, or trade personal information with third parties for their commercial purposes in the last 12 months.
• We do not knowingly collect the personal information of minors under age 16 and do not sell such information.

Third-Party Marketing Disclosure

Under California Civil Code Section 1798.83, California residents with whom we have a business relationship can request information about the types of personal information, if any, we shared with third parties for the direct marketing purposes of the third parties and the identities of the third parties with whom we shared such information in the immediately preceding 12 months. We have not disclosed any personal information in this manner in the last 12 months. You may contact us with any questions about this information using the contact information at the bottom of this Privacy Statement.

How to Contact Us

For any questions or comments regarding our information or security practices or this Privacy Statement, you may contact us:

• By E-mail: PrivacyPolicy@trialcard.com
• By Phone: 919-845-0774 (between 9:00 am and 5:30 pm Eastern)
• By Mail: 2250 Perimeter Park Drive, Suite 300, Morrisville, NC 27560 Attn: Legal Department