Privacy Notice

Website Privacy and Security Policy
Effective Date: 10/27/2021

X Factor Advertising gathers and processes your personal information at the request of the study Sponsor in accordance with this privacy notice and adhering to relevant data protection regulations and laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why, and in what time and manner we process your personal data.

Privacy Policy
This Privacy and Security Policy (Privacy Notice) explains how the Data Controllers, Data Processors, Sub-Processors, and/or the owners and operators of this website (also referred to as “we” or “us” in this Privacy Notice), each within their respective definitions, roles, and authorities, collect and may use information about you that you submit on this website and the actions taken to help protect the privacy and security of that information. This notice DOES NOT apply to information that is collected through this website that does not identify you in any way, such as aggregated information about groups (rather than individuals), which we might use to show likely trends or geographic groupings.

In compliance with data protection and privacy laws, and/or where other contractual elements require, we ensure that you can exercise all applicable informational rights with respect to your personal information that may be submitted by you via this website, including but not limited to, the right of access and correction, submitting a complaint, objecting to data processing, requesting data deletion, restricting certain conditions of data processing, and requesting information and further clarification of the categories of data collected and transmitted while using this website.

By using this website, you consent to the data practices described in this statement. Please do not use this website if you do not agree with the terms set forth in this Privacy Notice.

Purpose and Scope
This notice applies to all Personal Data gathered for use and on behalf of the Sponsor through this website (collectively, the “Site”). The purpose of the Site is to obtain information about your interest in participating in the Oasis studies for which you may be qualified (“Purpose”). In order to determine whether you prequalify for a clinical trial for which we may be identifying potential patients, or to identify a clinical research center in your area, we may ask you to provide us with information about yourself.

The personal information we collect may include your name, email address, physical address, phone number, and certain other personal information including limited health information that is necessary to determine if you are an eligible candidate for possible inclusion in this clinical trial. We will only seek health and other personal information that is relevant to this clinical trial.

You understand and agree that by providing Personal Data through this Site, you may be contacted in connection with the Purpose. We make no guarantee that you will qualify for participation in this clinical trial. By using the Site, you consent to the data collection, use and practices described and outlined in this Privacy Notice.

Information Storage
The data protection and security of your Personal Data is important to us. We employ the use of reasonable physical, electronic, and administrative measures along with technology safeguards that are designed specifically to protect your Personal Data from loss, unauthorized access, misuse, disclosure, alteration, and unintended destruction. However, regardless of our efforts and the device you use to access the Site, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission or through other nefarious means.

Information Access
Your information will be released to the clinical trial site you have chosen. It may also be partially accessed by contracted parties and contact coordinators working directly with the participating clinical trial sites. In any event, only authorized individuals that have undergone training in security and compliance measures regarding personal information are permitted to handle the data. However, we have the responsibility to process all of your submitted information we may receive from you, under the Privacy Shield Framework guidelines and principles when releasing your information to the participating site you have selected.

Information Disclosure
Your personal information may be disclosed if, and to the extent, required by law, court order, or other governmental authority, and may be used or disclosed for the specific purposes for which it is collected and as authorized by law. As stated above, your contact information and other personal information, if collected through authorized submission by you, will be sent to the participating clinical trial site you have chosen. This occurs automatically after your submission of information; the screener website will automatically inform the clinical trial site, via email and/or direct transfer, of your interest in participating in the clinical trial.

Our website(s) may also use Google Analytics and Facebook Technologies to customize content, provide advertising, and to collect information about how many visitors we receive, their general geographic location, and how they use our website(s). This feedback helps us to improve offered services and the website user experience. Any data retrieved by us through Google Analytics contains no personally identifying information and is not transmitted back to Google.

Please note that although this Privacy Notice governs personal information collected through the website as maintained by us, when your personal information is transferred to others, as provided for in this Privacy Notice and in accordance with our ongoing responsibilities and the Privacy Shield principles, it is no longer governed by this Privacy Notice. It is, however, protected by the participating clinical trial site’s individual policies, practices, and applicable laws and jurisdictions.

Other than the use and transfer of information outlined above, no personal data of any kind that is provided by you, is sold, transferred, or used in any way by us, other than in compliance with the conditions described herein.

Information Retention
All information stored by us is kept on our secure servers until the conclusion of the study. Once the study has concluded, all potential patient information that has been submitted as part of the online screening process will be destroyed, unless retention of such information has been authorized by you prior to its submission. You may also request deletion of your Personal Data prior to the stated term of retention expiration if you no longer wish to remain registered with the Site by sending an email to the Data Processor at data.privacy@xfactoradvertising.com.

Cookie Usage
Our websites and/or screener pages employ the use of session cookies which are pieces of information, or markers, that the web server sends to your computer when you access our website(s). Session cookies are sent upon your arrival at our website to provide additional functionality and ease of use; especially helpful to you when you fill out forms. The types of session cookies we use typically expire upon logout or a short time thereafter. In any event, no permanent or perpetual cookies are used, or placed on your device.

By continuing your use of this website, you accept the use of cookies in accordance with the purposes described in this Privacy Policy.

If you do not wish to accept the session cookies, please do not use this website. You may also manage cookies at any time through your browser settings. To find out how to manage cookies, please visit www.aboutcookies.org, then select "How to Control/Delete Cookies" and follow the instructions for your browser.

Exclusions
This Site may provide the ability to connect with other websites, social networks or applications (“Third-Party Sites”). Accessing those links or enabling those connections may allow the third party to collect or share information about you. Those Third-Party Sites are beyond our control and are subject to the terms of the Third-Party Sites’ privacy policies, and therefore are not governed by the terms of this Privacy Notice. Please review the privacy policies and terms of use of any Third-Party Sites before providing your information to them as we are not responsible for the privacy practices or content or data collection of Third-Party Sites.

Information Removal
You may request to have your information removed from our database prior to its eventual destruction. In the event your information has already been passed to the clinical trial site you selected; you will need to contact the trial site directly to remove your submitted information from their database.

To request to have your information deleted, or to be removed from our database, email privacy@xfactoradvertising.com. Please include your name, study name, and approximate date you submitted your information.

For all requests to exercise informational rights, access to data, to request data categories collected, or to submit a complaint, please contact our Data Protection Officer at:

• By email: data.privacy@xfactoradvertising.com
• By fax: 503-235-6572, Attn: Privacy Officer
• By postal mail: 5 Centerpointe Drive, Suite 400, Lake Oswego, OR 97035 - USA, Attn: Privacy Officer

To help X Factor Advertising identify your Personal Data, please inform X Factor Advertising that your request relates to the Oasis studies recruitment site.

Data and Information Protection Laws
X Factor Advertising as operators of this website, comply with the EU-U.S. and Swiss-U.S. Privacy Shield Framework(s) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. X Factor Advertising has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

We conform our website(s) compliance to the EU-U.S. and Swiss-US Privacy Shield Framework and Principles. We are committed to subjecting all personal data received from Swiss and European Union (EU) member countries respectively, in accordance to the Privacy Shield Framework regulations and applicable principles to ensure the rights of all EU and Swiss individuals using or providing information on the website(s).

We are responsible for the processing of personal data we receive, and subsequent transfers to contracted and authorized third parties as outlined herein. We are committed to complying with the Privacy Shield Principles for all onward transfers, when applicable, of personal data from the EU and Swiss territories.

Independent Data Processor Compliance
In certain instances, the operators of this website, who at times may be contracted specifically by the Data Controller(s) on their behalf, independently process and transfer the data that is provided by you through your use of this website’s screener page. Notwithstanding the terms, conditions, and controls outlined above, as contracted, and defined Data Processors, we commit to processing personal data in compliance with all General Data Protection Regulations (GDPR), Privacy Shield principles, and other applicable data protection laws and regulations, and to resolve complaints about our collection, or use, of your personal information. Swiss and European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us utilizing one of the methods detailed under the “Information Removal” Section of this Privacy Policy.

However, in compliance with the Privacy Shield Principles, X Factor Advertising commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at:

• By email: data.privacy@xfactoradvertising.com
• By fax: 503-235-6572, Attn: Privacy Officer
• By postal mail: 5 Centerpointe Drive, Suite 400, Lake Oswego, OR 97035 - USA, Attn: Privacy Officer

The Federal Trade Commission has jurisdiction over X Factor Advertising’s compliance with the Privacy Shield.

In the event that a complaint has not been resolved, an individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information regarding those options please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Privacy Notice Updates
We may periodically update this notice. When posting updates to this notice, we will also revise the “Effective Date” appearing at the top of the notice. We encourage you to visit and review this notice periodically to be informed of changes in how we may be using your information. Your continued use of the Site after the posting of any changes to this Privacy Notice shall constitute your agreement to be bound by any such changes. Any changes to this notice are effective immediately after posting.

By your use of this clinical trial website and/or screener you acknowledge and accept the terms outlined in this Privacy and Security Policy.

X Factor Advertising, 5 Centerpointe Drive, Suite 400, Lake Oswego, OR 97035 – USA

CCPA Privacy Notice for California Residents

Effective Date: 10/27/2021

This CCPA Privacy Notice relates solely to the website Oasisstudies.com and all related subdomains of that site (collectively, the “Site”). The Sponsor (“we”, “us”, “our”) are required by the California Consumer Privacy Act of 2018 (“CCPA”) to explain to California residents (“Consumers”) about online and offline practices with regard to how we collect, use, and share their personal information and about the rights and choices we offer them regarding our handling of their personal information.

Personal Information Defined
When we use the term personal information in this notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Information that is lawfully made available from federal, state, or local government records
• Information that is de-identified or aggregated consumer information
• Information excluded from the CCPA’s scope, including:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or certain clinical trial data
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
  • Other information subject to an exemption from the CCPA’s coverage

Personal Information We Collect, Use and Share
As we explain in our Privacy Notice:

• Cookies and other Tracking Tools

  We may use cookies and other tracking tools to analyze website traffic. If you would like to opt out of our use of cookies and/or other tracking tools, please review the instructions provided in the Tracking Opt-Out section below.

• Directed Disclosures

  When Consumers who visit the Site share their information for the Purpose identified in the Site Privacy Notice. To fulfill the Purpose, we may share consumer information with affiliates, service providers and/or sites in connection with certain clinical trial recruitment activities. These disclosures are inherent to the Purpose and directed by the consumer.

How we collect, use, and share personal information about Consumers

The CCPA requires businesses to disclose their collection and use of specific categories of personal information enumerated in the CCPA. We do not sell your personal information. Below is a summary of how we currently collect, use, and share personal information in relation to the Site:

California Residents’ Privacy Rights
The CCPA grants Consumers with certain rights which are subject to certain limitations and exceptions. This section describes these rights. If we are not able to complete some or all of a Consumer’s verifiable consumer request, we will communicate the reason to the Consumer in writing.

• Information. Consumers can request information about the Personal Information we have collected about them and how we have used and shared their Personal Information during the past 12 months. We have made this information available to California residents without need for request by including it in this notice above.
• Access. Consumers can request a copy of the Personal Information that we have collected about them over the past 12 months. In certain cases, we are not permitted by the CCPA to provide you with certain sensitive information in response to an access request, such as your social security or driver’s license number.
• Deletion. Consumers can ask us to delete the Personal Information that we have collected from them. In certain circumstances, the CCPA allows us to deny Consumer requests to delete their personal information, such as instances where we need the information to complete a transaction for which the Personal Information was collected or where we need the Personal Information to comply with a legal obligation.

  Consumers are entitled to exercise the rights described above free from discrimination.

• Requesting access to, or deletion of Personal Information
  With respect to your Personal Data Processed through this Site, please note that the owner and data controller of this website has instructed its Processor, X Factor Advertising, not to provide us with any identifying information about you. As a result, we receive anonymized data from X Factor Advertising. However, as the data controller, we reserve the right to obtain any such identifying information about you from X Factor Advertising and use such information in accordance with this Privacy Notice, in the future. We will update this Privacy Notice accordingly if any such change is implemented. If you wish to exercise your Personal Data rights, we ask that you contact our Processor, X Factor Advertising, as follows:
  • Fax: 503-235-6572, Attn: Privacy Officer
  • Email: data.privacy@xfactoradvertising.com
  • Postal mail: 33548 Edward Ln., Suite 110, Scappoose, OR 97056 Attn: Privacy Officer

To help X Factor Advertising identify your Personal Data, please inform X Factor Advertising that your request relates to the Oasis studies recruitment site.

• Identity verification

  The CCPA requires us to verify the identity of the individual submitting a Consumer request to access or delete personal information before providing a substantive response to the request. Where possible, we will attempt to verify your identity by asking you to confirm information that we have on file about you or your interactions with us. Where we must ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. You do not need to create an account with us to exercise your rights

• Authorized agents

  You can designate an “authorized agent” who has registered with the California Secretary of State to submit verifiable consumer requests on your behalf. You can also make a Consumer request on behalf of your minor child. We will require the authorized agent to have a written authorization confirming that authority.

How We Respond to Verifiable Consumer Requests
We will acknowledge receipt of your verifiable consumer request within 10 days of our receipt of your request and we will endeavor to substantively respond within 45 days of our receipt of your request. If we need to extend our response time (up to 90 days from receipt of your request) we will inform you in writing of our reasons for doing so. We will deliver your Personal Information via your online account with us, if you have one, or by other secure electronic means. If we are unable to process your verifiable consumer request in whole or in part, we will explain our reasons for doing so.

Please note that we do not typically charge a fee to respond to verifiable consumer requests unless they are excessive, repetitive, or manifestly unfounded. If we determine that your verifiable consumer request warrants the assessment of a fee, we will inform you of the reasons supporting our determination and provide you with our estimate of the costs to fulfill your request before we take action to enable you to determine whether you would like us to complete your request.

Changes to This Privacy Notice
We may periodically update this notice. When we post changes to this notice, we will also revise the “Effective Date” appearing at the top of the notice. If there are material changes to this notice, we will notify you by email or by posting a notice on our home page. We encourage you to review this notice periodically to be informed of how we are using your information and to be aware of any changes to it. Your continued use of this website after the posting of any amended notice shall constitute your agreement to be bound by any such changes. Any changes to this notice are effective immediately after we post it.

Tracking Opt-Out Guide
Like many companies online, we may use services provided by other companies that use tracking technology. These services rely on online tracking technologies, such as cookies and web beacons, to collect directly from your device information about your browsing activities, about your interactions with websites, and about the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services which we have summarized below:

• Blocking cookies in your browser

  Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

• Blocking advertising ID use in your mobile settings

  Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers

  You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features like Brave or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.