Who We Are:

We are QD Solutions, Inc. (“QD”), an advertising agency based in Austin, Texas that specializes in the clinical research industry.

What We Do:

QD works on behalf of pharmaceutical and biotech companies (also known as study sponsors), as well as contract research organizations, to help our clients recruit participants into medical research studies that are evaluating investigational medications and devices. We develop ad campaigns and build websites to attract and locate potential research subjects who are interested in participating in these studies. We also provide an online questionnaire system, called QDPre-Screener™, that is used to determine whether a potential participant lives near a study clinic and meets initial study criteria for participation. QD may also collect and store business contact information submitted by study investigators and medical staff who run the research studies of which QD is associated.

Overview of This Policy:

At QD, we believe privacy is important, and we are committed to protecting it through our compliance with this policy. QD adopted this Privacy Policy (our “Privacy Policy”) to comply with federal privacy guidelines, state privacy guidelines (such as “CCPA”), the EU General Data Protection Regulation (“GDPR”), and other privacy laws that may be applicable to QD Solutions, Inc. or our clients.

QD is providing this Privacy Policy to explain our online information practices regarding this website (this Site), including mobile applications that may be downloaded from it (the Apps), as well as email, text, and other electronic messages between you and this Site. This Privacy Policy is also applicable to contact information forms (the Forms) submitted by study medical staff.

It does not apply to information collected by QD offline or through any other means, including on any other website operated by QD or any third party. It also does not apply to QD or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with QD. Finally, it does not apply to QD or any third party, including through any application or content (including advertising) that may link to or be accessible from this Site.

By using this Site, the Apps and/or the Forms, you agree to the terms of this Privacy Policy and, if you provide us your personal information, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with this policy, please do not provide us any information and cease use of this Site, the Apps, and/or the Forms.

QD reserves the right to change this Privacy Policy at any time upon posting an updated privacy policy on this Site. Please review this Privacy Policy each time you use this Site, the Forms, or any App to understand if there are any revisions to it. We place the date upon which we last updated this Privacy Policy on the last page of this Privacy Policy. By accessing this Site, the Apps, and/or the Forms, you indicate your agreement to and acceptance of the terms of this Privacy Policy, and consent to the collection, retention, and use of your information consistent with this Privacy Policy, as may be amended from time to time.

Responsibilities for This Site and Study:

The Site, the Apps, and the Forms are intended and shall only be used by US residents who are 18 years of age or older.

Who are QD’s clients:

Our clients are pharmaceutical and biotech companies, as well as contract research organizations, both domestic and global.

What We Require of Our Clients:

We require that our clients abide by all applicable laws as it relates to your personal data provided to us on this Site.

What We Do in Conducting Our Business:

QD is engaged by clients to develop marketing/advertising campaigns that promote medical research studies, inclusive of attracting and pre-screening potential participants, through a study-specific websites that we develop and manage, who can be referred to the study investigators for further consideration, utilizing an online system on which the pre-screening data can be held for reference by the investigators. QD also collects business contact information from site personnel that are participating in studies of which QD is associated. We don’t hold your data for purposes other than that for which it was collected. We don’t use data we collect in one study for another study. We don’t share the data we collect from you with other businesses for their use, with the exception of sharing your data with our clients and the investigators conducting the study. We never sell or monetize your data. We host our systems in the cloud with reputable providers. However, their role is only to host and care for our systems and back up our data. They do not have the ability to access, view, or handle your personal information in any way.

Our Role as Processor of Your Data:

QD acts on behalf of its clients. We do not conduct medical research studies. We do not develop medicines, drugs, devices, medications, or treatments. We do not determine who can participate in a study and who cannot. We do not determine which study sites/clinics participate in a study. We do not decide what data should be collected. Those decisions are made by our clients -- the sponsors of the studies. We are a processor of information. We work on behalf of our clients to help promote their studies in an effort to find interested participants and provide a means, via an electronic, online questionnaire, to evaluate whether they match initial requirements for study participation. For study sites, we provide paper or electronic Forms that allow study sites to submit their contact information so it can be listed on the study website, which allows potential study participants to contact them.

The Types of Data We Process:

For potential study participants, QD collects your data to enable investigators (doctors participating in the study) to contact you, using your name, address, telephone number, and/or e-mail address, should you express interest in participating in a study. The rest of the data collected is used to see if you meet initial pre-qualifying criteria for study participation. Some of this information describes you and may include medical information about you. We recognize that this data is sensitive and collect only that which we believe would be useful in determining your appropriateness for a particular study. We will only use your data for the purpose of determining if you meet the initial study criteria and then, if you do meet initial criteria and indicate a desire to be contacted about study participation, make it available for use by the investigators and their staff. If you do not meet initial criteria for participation in the study, any information you provided as part of this initial online evaluation is deleted.

We also may collect non-personal information about how you use this Site and the Apps for, among other things, the operation and improvement of this Site and the Apps. Non-personal information is data in a form that does not, on its own, provide direct association to you, and includes but is not limited to technical information about how you access this Site, including but not limited to browser information, operating system, unique device identifiers, IP address, referring site, visit metrics, action metrics, page view metrics, search metrics, and others. This information may be collected through technologies provided by third parties. Information that might be collected using these technologies includes, for example, the pages you visit on this Site, the paths you take within this Site, and the length of time that you spend on this Site. We use this information in the aggregate to better understand how to improve the quality of this Site.

As is common among internet site operators, we may use Google Analytics, a web analytics services provided by Google, Inc., to help us understand how users use the site, including the web browser used, device type, and operating system that a user has, as well as the date of the visit and the pages visited. In other cases, we may use the “Amazon CloudFront” service provided by Amazon Web Services, which offers a content delivery network that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Amazon CloudFront’s network. This enables Amazon CloudFront to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the internet. In this context, Amazon CloudFront may also use cookies or other technologies deployed to recognize internet users, which shall, however, only be used for similar purposes as described above. The use of Amazon CloudFront is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible.

For study site personnel, we collect business contact information and post this information on the study website so potential study participants near your clinic can contact you to learn more about the study. This information typically includes the name of the study’s principal investigator, the name of the study site/clinic, the site address, the site phone number, and the site contact’s name and email address. We only use this data to list on the study website those clinics/sites who want to be put in contact with potential study participants. Once the study is closed or we are instructed by the study sponsor (whichever comes first), the site data is deleted.

Disclaimer of HIPAA Applicability:

QD is not a covered entity as defined in the federal medical record privacy statute known as the Health Insurance Portability and Accountability Act of 1996, as amended, and the regulations issued under that law (HIPAA). Additionally, with respect to any data we will obtain about you, since our clients are also not HIPAA covered entities, we are not a business associate under HIPAA. While the investigators with whom we may share your information are often HIPAA-covered entities (and may be required to treat your information confidentially under HIPAA), QD does not provide a service to them, and thus is not their business associate either. Therefore, even though the data we collect about you contains medical information that is the type of information commonly protected under HIPAA, it is not subject to any of the protections available to you under HIPAA. HIPAA is inapplicable to our relationship with you.

How We Obtain Data About You:

For potential study participants, we obtain data about you when you click on our advertisement for a study, visit this Site, and submit your data. We don’t buy data about you, gather it from social media, or obtain it in other ways. We will never target you directly to ask you to participate in a study. You have come to this Site and provided your information because you chose to do so to be considered for the study.

For study site personnel, we obtain the data from a contact sheet or study survey (the Form) that you fill out and submit back to us, either on paper or electronically. You provided us with this information because you want your site/clinic to be listed on the study website so that you can be put in contact with potential study participants.

Our Use of Cookies:

Like many websites, this Site also may use a technology called cookies. A cookie is a small text file that a Web server gives your browser to store on your computer when you access a website. Cookies can store many types of data and may be placed on your browser by QD. We may also use cookies to store preferences; record session information; develop information about Site visitors’ preferences and interests; record past activity at a Site to provide better service when you return to our Site; or customize Web page content based on information you voluntarily provide.

However, in all cases in which cookies are used, QD will not use the cookie to collect personally identifying information from this Site, unless you voluntarily agree to enter the information. Most Web browsers are set up to accept cookies. You can, however, reset your browser to refuse all cookies or to indicate when a cookie is being sent. Additionally, when you first came to this Site, you may have been presented with an option, at the bottom of the homepage, to accept or reject cookies. Note, however, that some portions of this Site may not work properly if you refuse cookies.

Do Not Track:

“Do Not Track” (DNT) is a privacy preference that users can set in their web browsers to inform websites that they do not want certain information about their browsing activities to be collected and tracked across websites. When enabled, the DNT signal is automatically sent by the user’s browser to websites and online services they visit.

QD Solutions is committed to respecting your privacy and providing transparency about how we handle your data. However, at this time, our website does not respond to DNT signals from web browsers. This is because there is no universally accepted standard for how companies should interpret and respond to DNT signals.

While our website may not respond to DNT signals, we take your privacy seriously and implement a variety of security measures to protect your personal information. We also provide options for you to control your data, such as:

• Opting out of cookies: You can manage your cookie preferences through your browser settings or our website’s cookie consent tool.
• Managing your data: You have the right to access, correct, or delete your personal information collected by us. Please refer to our Your Privacy Rights section for more details.
• Targeted advertising: At this time, QD does not purchase targeted advertising for its clients, or to promote itself. Should this change, we will update this Privacy Policy, inclusive of information about how to opt out of targeted advertising.

As industry standards for Do Not Track signals evolve, QD Solutions will continue to monitor developments and may update this policy to reflect changes in our practices. We encourage you to review this section periodically for any updates.

Who Will Have Access to the Data You Provide?

For potential study participants, the pre-screener system has access points for the study site personnel, QD system administrators, and the sponsoring client. Of these, only the investigator can access and view your data. The sponsor can only view statistics about the study, including how many people have participated in the online pre-screener, how many have met initial study criteria, how many have submitted their contact info for site follow-up, how many enroll in the study, and similar information. Sponsors cannot see your personal data. System administrators can set up and modify accounts on the system, but they do not access your personal data unless you specifically request a change or, in rare cases, there is a system problem whereby the site is unable to access your data.

potential study participants, the pre-screener system has access points for the study investigators, QD system administrators, and the sponsoring client. Of these, only the investigator can access and view your data. The sponsor can only view statistics about the study, including how many people have participated in the online pre-screener, how many have met initial study criteria, how many have submitted their contact info for site follow-up, how many enroll in the study, and similar information. Sponsors cannot see your personal data. System administrators can set up and modify accounts on the system, but they have no access to your personal data.

For study site personnel, only QD Solutions staff will have direct access to the business contact information submitted on the Forms. QD will provide the study sponsor with the Forms data, if requested.

Collection of Personally Identifying Information from or about children:

For study site personnel, only QD Solutions staff will have direct access to the business contact information submitted on the Forms. QD will provide the study sponsor with the Forms data, if requested.

This Site is not intended or designed to attract children or anyone under the age of 18.

Based on global regulations, persons under the age of 18 may not consent to participate in a medical research study on their own. Only a parent or legal guardian can consent for a child to participate in a study. If under consideration for a study, proof of identity and age verification documents will prevent participation without approved consent by a parent or legal guardian. Therefore, we do not knowingly collect, use, or disclose personally identifying information from persons under the age of 18. If we learn that we have collected the personally identifying information of a user under the age of 18, we will take steps to delete the information as soon as possible.

If you are a parent or guardian who believes that we have inadvertently collected personally identifying information from your child who is under 18 years of age, please contact us immediately by sending an email to privacy@qdsolutions.com to request that we delete his or her information from our records.

Use of the QDScreener™ platform:

On study Sites where the user wants to learn if they meet initial eligibility criteria needed to be considered for study participation, the QDPre-Screener™ platform is used. The QDPre-Screener™ platform is the system behind this Site used by you, a potential study participant, who is interested in possible participation in a clinical trial or medical research study. The system is designed to respect your privacy and never asks for, collects, or keeps your information longer or for purposes other than it is needed.

You have visited our study website and wish to be considered as a potential participant for a medical research study. We will need to collect information from you -- some of which is personal contact information, and some that is medical. We will collect this information without requesting your further consent for its processing in that this is the needed and preparatory step for entering into an agreement to participate in a medical research study. We are processing your information at your request for this purpose. If you choose not to proceed or cancel at any time, there will be no record of your personal data. We may use cookies. Cookies are used for security and tracking the effectiveness of our ad campaigns and use of social media platforms in attracting interested candidates to the study.

If you decide to learn whether you meet initial eligibility criteria for the study, an online questionnaire will be presented that will determine, based on your answers, whether you meet initial criteria for study participation. For example, if a specific study requires women-only, 60 years and older, any individual not in this group will not be considered for participation, and any information that had been collected will be discarded.

If the QDPre-Screener™ platform determines that you meet initial eligibility criteria, based on your answers to the online questionnaire, it will then attempt to determine if you are located in an area where the study is being conducted by asking for your postal code or from accessing your IP address. If you are not located in an area where there is a study site, no further information is requested, your postal code or IP data is deleted, and other than being counted numerically as a QDPre-Screener™ visitor for the purpose of statistics, there is no information held about you.

Only if it is determined that you meet specific prequalifying criteria and are willing to proceed for further screening will your personal identification and contact information be collected, and your questionnaire responses will be saved for review by the investigators performing the study. If, based on further screening and review by the study investigators, you are not enrolled into the study, your data will be deleted.

If you are under the age of 18 years, study participation requires the expressed consent of a parent or legal guardian. Therefore, potential participants under the age of 18 who are interested in participation in a pediatric study must have their online questionnaires completed by a parent or guardian. No matter your age, you will be asked if you meet certain age requirements as part of the online questionnaire. Your age will be verified by the investigators. If you are not of age, any data input will be discarded. If age has been misrepresented or cannot be verified, you will not be allowed to take part in the study, and any collected data will be deleted.

If you decide to enroll in the study, both you and the investigator will discuss and agree on the terms for your participation. You will also learn about the information that will be collected during the study and the means by which it will be collected. You will review and sign needed agreements, including permissions, disclosures and/or the informed consent form (ICF). QD has no part in the agreements between you and the investigator apart from our role of gathering information in preparation for your participation in that agreement. We did not request your consent to collect your information. We used another approach for data collection that is allowed under the law in this type of arrangement. We collected your data and provided it to the investigator based on your submission as a preparatory step for your ICF agreement and study participation.

If you enroll in the study, your data will be stored for access and reference by the investigators until completion of the study or your departure from the study. When the study is completed, or if you withdraw or depart for any reason, any data held by QD will be deleted, as directed by the sponsor, unless other arrangements were made between you and the investigator and/or sponsor about which we are notified.

Automated Processing:

The QD screener employs automated processing for three purposes – to determine (based on your response when asked) if you are of age to participate (for example, 18 years of age or older), if you are located near a study location, and if you meet initial study requirements for participation. Should your answers result in a system response that you are ineligible for the study, and you feel that this system determination is in error, please email us at privacy@qdsolutions.com. Please include your name and email address in your email, as well as why you feel the system erred in its assessment of you.

Security of Data Stored by QD:

QD has security measures in place to protect against the loss, misuse, and alteration of information under our control. While we make reasonable efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information. You agree and acknowledge that QD shall not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or personally identifying information has been compromised, please immediately notify us immediately at privacy@qdsolutions.com.

QD Ads:

QD develops advertisements for our clients to promote their medical research studies. Historically, we have rarely placed ads to promote our business, as we are largely found based on our reputation. However, should we place QD promotional ads in the future, we will never use personal information about any study participant or site visitor in our advertising.

Your Privacy Rights; Access to or Correction of your Personally Identifying Information:

If you have any questions about this Privacy Policy or any disclosure of personal information to third parties, if you would like to request a copy of your personally identifiable information stored by QD, or if you would like to update or correct your personally identifiable information stored by QD, please send an email containing your request to privacy@qdsolutions.com. You must provide your full name, and email address. You may be asked to provide verification of identity. This is a prudent practice for your protection.

For potential study participants, please be advised that QD can only comply in regard to the data we have collected and stored. Data held by clinical investigators that is collected as part of the study itself is not in QD’s control and we have no access. For this data you must contact the investigator directly. Therefore, you agree, by use of this Site, that QD may transfer your data to clinical investigators for the purpose of engaging in medical research studies.

For study site personnel, please be advised that QD can only comply in regard to the data we have collected and stored. Data held by sponsors that is collected as part of the study itself is not in QD’s control and we have no access. For this data you must contact the study sponsor. Therefore, you agree, by use of the Form, that QD may store and use your data for the purpose of providing your contact information to potential study participants.

Your California Privacy Rights:

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our CCPA Privacy Notice.

For users in the European Economic Area (EEA):

This Privacy Policy applies to all users, including those in the European Economic Area (EEA), and is designed to comply with the General Data Protection Regulation (GDPR). It explains how we collect, use, and protect personal data in accordance with GDPR.

Contact Us:

If you have any questions regarding our Privacy Policy, contact us at privacy@qdsolutions.com.

This Privacy Policy was last updated on August 21, 2024.