Rose Research Website Privacy Policy

Effective date: July 31, 2020

This Privacy Policy (the “Policy”) explains how Rose Research Center, LLC (“Rose Research Center,” “us,” “our,” or “we”) collects, uses, discloses, and protects personal information that we collect from you through the eResearch Application (the “App”) and our websites (the “Websites”) at www.roseresearchcenter.com, www.quitsmokingstudies.com, www.researchsmoking.com, www.researchecig.com, www.juulstudy.com, www.quitsmokingtrials.com (the App and the Websites collectively, the “Services”).

Information We Collect About You 

When you use or access the Services, we may collect personal information, such as the following:

• Biographical and contact information, such as name, gender, age and date of birth, email address, physical and mailing address, time zone, and phone number.
• Information you submit in connection with nicotine use questionnaires, such as the manner in which you smoke or otherwise consume or use tobacco products, how long you have smoked cigarettes/e-cigarettes, the frequency with which you smoke cigarettes/e-cigarettes, and cigarette/e-cigarette preferences (including preferred brand, preferred flavor, and whether you smoke menthol cigarettes).
• Information you submit in connection with health history questionnaires, such as height, weight, information related to alcohol consumption (including frequency and nature of alcohol consumption), current or past medical conditions, a list of any prescriptions, over-the-counter medications, supplements, or inhalers you are taking/using or recently took/used, whether you are pregnant, nursing, or planning to become pregnant, and whether you are willing to submit to a urine drug screen.
• Login credentials, such as username and password.
• Communication preferences.
• App and Website settings and other preferences.
• Proximity to test site locations.
• Photograph of your government-issued ID (e.g., driver’s license, state or military identification card, passport, or similar types of ID), and information displayed on your government-issued ID, such as the number or barcode associated with government-issued ID (e.g., driver’s license number).
• Your photograph.
• Information that you provide to us or that we otherwise receive from or about you when you communicate with us through the Services, including through telemedicine sessions and support requests.
• Information on how you learned about Rose Research Center or the Services.
• Information collected through surveys and questionnaires that you complete, including surveys and questionnaires that are part of clinical trials or clinical trial recruitment protocols.
• Information described in, or otherwise collected pursuant to your consent, including eConsents through which you agree to participate in clinical trials and other research conducted through the App or otherwise.
• Biometric data, such as scans of facial geometry.
• Other information that you submit or otherwise provide to us through the Services.

We also may collect certain other information automatically when you use or access the Services, such as the following:

• Device Information: Certain information is automatically collected about your device, such as such as IP address, MAC address, and operating system.
• Cookies, pixels, and similar technology: Cookies, pixels, and similar types of technology allow us and third parties to collect and track information such as browser type, time spent on online services, pages visited, referring URL, and other online traffic data.
• Information Collected in Connection with Analytics Technology: We may use various technologies to learn more about how visitors use the Services, such as Google Analytics. Google Analytics uses cookies to help us analyze how visitors use the Services. The information generated by the cookies about your use of the Services or websites includes your IP address. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: https://policies.google.com/technologies/partner-sites. We may also use other technologies to monitor your activities on our website.
• IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever you use or access the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive and collect your approximate location from your IP address to understand from what regions of the world our website visitors come.
• Location Information: We may receive your approximate location or data that indicates your approximate location, such as your IP address.

How We Use Your Information

We may use personal information that we collect about you for purposes that include the following:

• Providing the App, the Websites, and our other websites, applications, and services to you and others.
• To conduct clinical trials and perform research.
• For internal business operations, such as evaluating and improving the effectiveness of our operations (including the App, the Websites, and our other websites, applications, and services), conducting research and analysis, developing new services, and performing other internal business operations, including as described elsewhere in this privacy policy.
• To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our websites, applications, or other services.
• To maintain the safety, security, and integrity of our websites, applications, other technology assets, and our business.
• Understanding how you and our customers use the Services and to determine what features and services may interest you, our customers, and others.
• To create deidentified or aggregate information (i.e., non-personal information). Note that this Policy does not address non-personal information, such as deidentified and aggregate information, which we may use and disclose for any purpose, including to market and promote our company, websites, applications, and other services.
• To communicate with you and others, including to encourage your participation in clinical trials for which we believe you may be a suitable participant.
• Calculating user levels and diagnosing server problems.
• Storing information about your preferences and recognizing you when you use the Services.
• Verifying your identity.
• Determining your location.
• To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
• To comply with applicable law, other legal requirements, and industry standards.
• Protecting the legal rights, property, safety, and security of us, our users, and others.
• Complying with applicable law and industry standards and enforcing our policies, terms of use, or rights arising from contracts.
• To evaluate an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• For such purposes as you may authorize or consent to, including as set forth in eConsents through which you agree to participate in clinical trials and other research conducted through the App or otherwise.

In addition to the uses described above, we may use personal information collected through the Websites for marketing and promotional purposes.

Disclosure of Your Information

We may disclose personal information we collect about you:

• To clinical trial sponsors.
• To regulatory bodies, including the U.S. Food and Drug Administration.
• To our affiliates.
• To our contractors, service providers, and other third parties we use to support our organization.
• To communicate with you and others.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our policies, terms of use, or rights.
• To investigate or prevent unlawful activities or misuse of the Services.
• To protect the rights, property, or safety of us, our users, or others.
• To a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• For such purposes as you may authorize or consent to, including as set forth in eConsents through which you agree to participate in clinical trials and other research conducted through the App or otherwise.

In addition to the disclosures described above, we may disclose personal information collected through the Websites for marketing and promotional purposes.

Your Choices

You may choose not to provide the personal information we request. However, not providing information we request may restrict your ability to use certain features of the Services or participate in clinical trials or research. You may be able to restrict the collection of personal information or functionality through your device’s operating system, but doing so may prevent you from using the functionality of the Services or participate in clinical trials or research. You may modify your profile, remove yourself from consideration for future clinical trials, or adjust your communication preferences by logging into your profile and making any appropriate adjustments or by contacting us using the information in the “Contacting Us” section. Some Internet browsers have a “do-not-track” feature that let you tell websites that you do not want to have your online activities tracked. The Services do not respond to, browser “do not track” signals. We may allow third parties to use the Services to collect personal information about your online activities over time and across different websites, applications, and other online products or services.

Security

We maintain safeguards intended to protect the personal information collected through the Services.

Changes to this Policy

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Effective Date of the Policy, above. We encourage you to periodically review this Policy for the latest information on our privacy practices.

Contacting Us

If you have any questions or comments about this Policy or our privacy practices, please contact us at: help@roseresearchcenter.com.