Privacy Policy

QD Solutions, Inc. is a healthcare advertising agency based in Austin, Texas that specializes in the clinical research industry. QD works on behalf of pharmaceutical and biotech companies (also known as study sponsors), as well as contract research organizations, to help recruit participants into medical research studies that are evaluating investigational medications and devices. We also create websites, apps, and other print and digital materials to support research study participants in these studies.

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 or our clients.

QD is providing this Privacy Policy to explain our information practices regarding the App.

This Privacy Policy does not apply to information collected by QD offline or through any other means, including on any other mobile application or website operated by QD or any third party. It also 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 App.

By using this App, 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, do not use the App, and delete the App from your smart device.

QD reserves the right to change this Privacy Policy at any time upon posting an updated privacy policy on this App. Please review this Privacy Policy each time you use this App to understand if there are any revisions to it. We place the date upon which we last updated this Privacy Policy at the end of this Privacy Policy. By accessing the App, 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.

The App is intended for, and shall only be used by, research study participants and/or the caregivers/partners of research study participants (the “Users,” “you,” “your”) who have been granted access to the App.

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

QD collects contact information from Users. We don’t store 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. 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.

QD’s role is to provide Users with information to aid in their study participation. QD does not conduct medical research studies. We do not develop medicines, drugs, devices, medications, or treatments. We provide an electronic Form (the “Form”) that allows Users to email their study clinic/site and submit study-related questions.

QD collects your email address and phone number to verify your identity and create your App account. We collect additional data when you complete your profile, which may include your first and last name, nickname, street address, city, state, and postal code, as well as the name, phone number, and email address of your emergency contact. We also collect any data you may enter into the App, such as appointment dates and times, eDiary entries, and questionnaire responses. If you grant the App access to your personal phone calendar, we will only use your calendar to provide appointment entry details (e.g., locations, times, participants). We do not view your calendar or contacts.

This information is used to enhance your experience with the App and support your study participation as needed. We recognize that this data is sensitive and collect only that which we believe would be useful in supporting your study participation. We will only use your data for the purpose of providing you with study information and helping you contact the study team through the Form.

We also may collect non-personal information about how you use the App for, among other things, the operation and improvement of the App. 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 the App, 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 App, the paths you take within this App, and the length of time that you spend on this App. We use this information in the aggregate to better understand how to improve the quality of this App.

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.

For study participants, we obtain data about you when you use the App 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 provide data. You have come to this App and provided your information because you chose to do so.

Only QD system administrators will have direct access to the information you provide in the App. If you choose to email your study clinic/site using the Form, only the study clinic/site administrators will have access to the information you share. QD will not have access to your email correspondence.

This App 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.

Personally identifying information that you have voluntarily submitted electronically is delivered to servers located within the United States. By using this App, you consent to the transfer of this personally identifying information and non-personally identifying information, and to our use of such information as outlined in this Privacy Policy.

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 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 App user in our advertising.

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.

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.

QD Solutions acts as a service provider to its life science and pharmaceutical clients. We process personal information solely on behalf of and under the instructions of those clients. QD does not sell or share personal information.

If you are a California resident and would like to exercise your privacy rights under the California Consumer Privacy Act (CCPA) or the California Privacy Rights Act (CPRA), please submit your request directly to the sponsor or organization that is responsible for your study. QD will cooperate with its clients in fulfilling all verified privacy rights requests.

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.

We process personal data based on one or more of the following legal bases: (1) your consent; (2) the necessity to fulfill a contract with you; (3) compliance with a legal obligation; (4) the protection of your vital interests or those of another person; (5) performance of a task carried out in the public interest; and (6) our legitimate interests, provided that they do not override your rights and freedoms.

Under GDPR, individuals in the EEA have the following rights:

• Right to Access: You have the right to request access to your personal data and obtain a copy of it
• Right to Rectification: You can request correction of any inaccurate or incomplete personal data
• Right to Erasure: You have the right to request the deletion of your personal data under certain conditions
• Right to Restrict Processing: You may request that we limit the processing of your personal data under certain circumstances
• Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or direct marketing
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller

Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. To withdraw consent, please contact us at 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. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

We will respond to verified requests to access, correct, or delete personal data within 30 days, and sooner when reasonably possible. In certain circumstances, this period may be extended as permitted by law, and we will notify the requester if an extension is required.

If we transfer your personal data outside the EEA, we ensure that such transfers are safeguarded by one of the following mechanisms: (1) an adequacy decision by the European Commission; (2) Standard Contractual Clauses approved by the European Commission; or (3) Binding Corporate Rules. These safeguards ensure that your data is protected to the same standard as within the EEA.

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the nature of the data and the purposes for which it is processed.

We implement a variety of security measures to ensure the safety of your personal data, including encryption, access controls, and regular security audits. These measures are designed to protect your personal data from unauthorized access, disclosure, alteration, or destruction.

If you believe that our processing of your personal data violates GDPR, you have the right to lodge a complaint with a supervisory authority in the EEA. We encourage you to contact us first to address any concerns directly.

We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of personal data. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

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