This Signant Health Application End User Privacy Policy (“Privacy Policy”) addresses the collection, use, and disclosure of information that Signant Health (“We” or “Signant Health”) may gather when you (“You” or “End User”) access or use applications (including web and mobile applications) made available by Signant Health, such as Signant Health’s RTSM Mobile Application. THIS PRIVACY POLICY APPLIES ONLY TO INFORMATION ABOUT END USERS OF SIGNANT HEALTH APPLICATIONS, NOT INFORMATION ABOUT THIRD PARTIES (E.G., RESEARCH SUBJECTS AND PATIENTS) STORED ON SERVERS THAT AN END USER MAY ADD, ACCESS, AND EDIT THROUGH THE SOFTWARE. PLEASE SEE AGREEMENTS APPLICABLE TO OUR HOSTED SERVICES REGARDING HOW SUCH THIRD PARTY INFORMATION IS COLLECTED, USED, AND DISCLOSED. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the applicable Signant Health license agreement or terms of service (e.g., the Signant Health RTSM Mobile Application Terms of Service).

     Please review the entire Privacy Policy to learn the types of End User information Signant Health gathers, how Signant Health uses that End User information, what End User information is disclosed and to what third parties, and how Signant Health safeguards your End User information. As used in this Privacy Policy, the terms “use,” ”using,” “process,” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, but not limited to, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within the Signant Health enterprise or among its affiliates.

     Please also check back periodically as this Privacy Policy may change from time to time. The End User information Signant Health gathers is and will be subject to the Privacy Policy in effect at the time the information is gathered. Should you have any questions or concerns at any time, please feel free to contact us.

     This Privacy Policy applies only to Signant Health Software. This Privacy Policy does not apply to any products or services (including websites and software) managed, maintained, and/or hosted by third parties not directly affiliated with Signant Health that you may visit, e.g., via a link provided through the Software. Signant Health does not control the privacy policies of other products or services to which we may provide links. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.

     By submitting information to us and by using the Software, Signant Health will assume that you have read, understood, and consent to this Privacy Policy, all applicable Signant Health license agreements and terms of service, all amendments to the Privacy Policy and applicable Signant Health license agreements and terms of service, and all applicable Signant Health rules and policies (collectively, the “Agreement”). We also assume that you consent to Signant Health’s use of information and data as described in the Agreement. If you do not consent, you should not access or use the Software.

1. Information Signant Health Collects

     A. Personal Information and Non-Identifying Information

     We may collect personally identifiable information about you (“Personal Information”) when an account is created for you to access and use hosted services and software provided by Signant Health. Personal Information includes, but is not limited to, your name, username (if it personally identifies you), and answers to security questions (if they personally identify you), and any other information that you decide to provide to Signant Health that could be used to personally identify you. This information may be provided to us directly by you or through a third party who authorizes you to access and use the Software on its behalf (e.g., a clinical research sponsor).

     We also collect other information that you provide when using the Software and hosted services and software that does not identify you (“Non-Identifying Information”). Non-Identifying Information includes, but is not limited to, individual preferences. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).

     We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Software and related services (including hosted services required for full use of the Software), complete your transactions, and respond to correspondence from you.

     We may also combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Software, and to analyze and understand how the Software is used.

     B. Usage Data

     When you use the Software and related hosted services and software, our servers automatically record information that the Software sends from your device. The information sent automatically by the Software is referred to as “Usage Data.” This Usage Data may include information such as the manufacturer and model of your mobile device; your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; portions of the Software you use, the time spent interacting with certain portions of the Software, information you search for using the Software, access times and dates; and other statistics.

     We use this information to monitor and analyze use of the Software and related services and for technical administration, to increase the functionality and user-friendliness of the Software and related services, and to better tailor the Software and related services to our End Users’ needs.

     C. Other Business Partners and Vendors

     We work closely with certain business partners and vendors and we may provide End User information to our business partners and vendors so that they can assist us in providing the Software and related services and software to you. For example, we may employ third-party companies and individuals for any of the following: to provide or facilitate the Software and related services and software on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of features or functionality; or to assist us in analyzing how the Software and related services and software are being used.

     D. Business Transfers

     As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about End Users generally is often a transferred business asset. In the event that Signant Health itself or substantially all of Signant Health’s assets are acquired, information about our End Users may be one of the transferred assets.

     E. Compliance with Law and Protection of Signant Health and Others

     We may release End User information when we believe, in our sole discretion, that release is appropriate: to comply with the law, including but not limited to, in response to a subpoena served on Signant Health; to enforce or apply the Privacy Policy, an applicable license agreement or terms of service, or other agreements, rules, and policies; to protect the rights, property, or safety of Signant Health, our End Users, or others; or to prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable (including exchanging End User information with other companies and organizations for fraud protection).

     F. Aggregate Site Use Information

     We may release aggregate End User information (without revealing any Personal Information about you) to third parties in order to promote or describe use of the Software.

2. Collection of Information

     Signant Health may use a number of different techniques and technologies to collect Personal Information, Non-Identifying Information, and Usage Data. For example, Signant Health may use cookies, local storage, webview, device identifiers, log files, embedded scripts, and/or other technology used to monitor your Signant Health experience.

     A. Collection of Personal Information and Non-Identifying Information

     As is regular practice on many websites, the Software uses cookies and other technologies to help us understand which parts of the Software are more popular and how much time users spend there. A cookie is a small amount of data that is sent to and stored on your device from our server. Cookies allow you, for example, to enter your password less frequently or to remember your preferences during an online session. The Software includes first-party cookies that send data directly to Signant Health and may include third-party cookies that send data to our trusted third-party contractors strictly for the monitoring and administration of the Software and related services and software (i.e., not for purposes of marketing or advertising by such third parties). The cookies that the Software uses do not store Personal Information, but they may store Non-Identifying Information. Since cookies are now used as industry standard, most devices automatically accept cookies. There is no feature in the Software that allows you to disable the cookies used by the Software.

     The Software permits you to login and access data on a server operated by or on behalf of Signant Health. This data may include information, including personal information and protected health information (PHI), about third parties such as research subjects and patients. Most data that the Software interacts with, including End User Personal Information and Non-Identifying Information we collect through the Software and the third-party data accessible through the Software, are stored and maintained remotely on such a server. For security and performance reasons, the data stored on your personal device is limited and do not include your username or password or any data about third parties (including PHI). For further detail about how third-party data are collected, used, and disclosed by Signant Health, please see agreements applicable to our hosted services.

     B. Collection of Usage Data

     Usage Data are collected automatically by the Software and our servers interacting with the Software. You agree that we and our trusted third-party contractors may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to facilitate the provision of software updates, product support and other services to you related to the Software.

     C. Tracking

     The Software does not track End Users’ online activity across different websites, other than potentially recording referring/exit pages as part of Usage Data. There is no feature within the Software that sends “do not track” signals to Signant Health’s servers, and Signant Health’s servers do not accept or process “do not track” signals sent by Web browsers.

3. Use and Sharing of Information by Signant Health

     The End User information that Signant Health collects may be added to our databases and used for business purposes, including for a statistical analysis of End Users’ behavior, for product development, for content improvement, or to customize the content and layout of the Software.

     Signant Health’s policy is not to share the End User information it collects with third parties other than as specified below, or where an End User expressly consents to our sharing of certain information with a third party. We may share End User information with third parties under the following circumstances:

     A. Third Party on Whose Behalf You Use the Software

     In the case where you access and use the Software and related services and software on behalf of and with the authorization of a third party (e.g., a clinical research sponsor with whom you have a direct agreement), we may collect information about you through such third party and we may disclose information about you to such third party. For example, such third party may create accounts and issue log-in credentials for you to use the Software and related services and software. To the extent such accounts and credentials include Personal Information about you, such information may be provided to Signant Health by such third party. Additionally, we may provide such third party with certain Usage Data regarding its authorized End Users’ access to and use of the Software in connection with our providing services to such third party.

     B. Other End Users

     For purposes of documenting transactions completed by an End User using the Software, certain information about an End User may be made available to other End Users of the Software within the same enterprise or acting on behalf of and with the authorization of the same third party. For example, End Users separately using the Software on their own devices who are authorized to access the same online data (e.g., co-workers or contractors working on a common research study) may be able to learn when each of them used the Software to access, add, or edit certain data.

     C. Other Business Partners and Vendors

     We work closely with certain business partners and vendors and we may provide End User information to our business partners and vendors so that they can assist us in providing the Software and related services and software to you. For example, we may employ third-party companies and individuals for any of the following: to provide or facilitate the Software and related services and software on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of features or functionality; or to assist us in analyzing how the Software and related services and software are being used.

     D. Business Transfers

     As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about End Users generally is often a transferred business asset. In the event that Signant Health itself or substantially all of Signant Health’s assets are acquired, information about our End Users may be one of the transferred assets.

     E. Compliance with Law and Protection of Signant Health and Others

     We may release End User information when we believe, in our sole discretion, that release is appropriate: to comply with the law, including but not limited to, in response to a subpoena served on Signant Health; to enforce or apply the Privacy Policy, an applicable license agreement or terms of service, or other agreements, rules, and policies; to protect the rights, property, or safety of Signant Health, our End Users, or others; or to prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable (including exchanging End User information with other companies and organizations for fraud protection).

     F. Aggregate Site Use Information

     We may release aggregate End User information (without revealing any Personal Information about you) to third parties in order to promote or describe use of the Software.

4. International Transfer

     Please note that Signant Health is based in the United States and the servers with which the Software interacts are located in the United States. If you use the Software from outside the United States, please note that your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction, where privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy, followed by our submission of information through the Software, represents your agreement to the transfer of such information to the United States and the handling of your information consistent with this Privacy Policy and applicable United States law.

5. Changing or Deleting Your Information

     All End Users who have created an account on the Software may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.

6. Security

     We are very concerned with safeguarding your information. We employ administrative, physical, and electronic measures designed to protect your information, as well as the third party data you may access through the Software, from unauthorized access. For example, we use commercially reasonable security measures such as encryption, firewalls, and secure socket layers (SSL) to protect End User information.

     Except as expressly provided in our services agreements, any information you transmit through the Software to Signant Health, you do at your own risk. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Software in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

7. Children’s Privacy

     We are committed to protecting the privacy of children. End Users must be at least thirteen (13) years of age to access and use the Software. By using the Software, you represent and warrant that you are thirteen (13) years of age or older and that you agree to and agree to abide by all of the terms and conditions of the Agreement. If Signant Health believes that you are under the age of thirteen (13) or that you are not old enough to consent to and be legally bound by the Agreement, Signant Health may, at any time, in its sole discretion, and with or without notice: (i) terminate your access to or use of the Software (or any portion, aspect, or feature of them), or (ii) delete any content or information that you have posted through the Software.

8. Contacting Us

If you have any questions about this Privacy Policy, please contact us.