This Privacy Policy describes how Jaspari LLC, operating the Jaspari Studies clinical trial patient recruitment platform ("Jaspari Studies," "we," "us," or "our"), collects, uses, discloses, and protects personal information about individuals who visit our recruitment pages, submit an intake or eligibility form, or are otherwise referred to or contacted through the Jaspari Studies platform (each, "you" or a "volunteer"). This Policy applies to the Jaspari Studies platform, including pages found at addresses such as jaspari.com/ready/... and related intake, screening, scheduling, and update pages (collectively, the "Platform").
This Policy does not apply to Client organizations’ own use of the Jaspari Studies portal as clinics or research sites, which is governed by the Master Services Agreement between Jaspari Studies and that organization. This Policy also does not apply once a healthcare provider or research site has accepted you as a patient or trial participant; at that point your relevant health information is generally protected health information governed by that provider’s own notice of privacy practices and, in the case of Jaspari Studies’s own involvement in supporting a clinical trial on a provider’s behalf, by the HIPAA Business Associate Agreement between Jaspari Studies and that provider. The informed consent form for any specific clinical trial, if you choose to participate, will separately describe how information about your participation is used, and will govern to the extent it conflicts with this Policy. Your use of the Platform is also governed by our Terms and Conditions, available at https://jaspari.com/studies/terms-and-conditions.
1How Your Information Reaches Us
Jaspari Studies operates a platform connecting individuals interested in clinical trials with the healthcare providers, clinics, and research sites (each, a "Client") running those trials. We receive personal information about you through several channels, and our role with respect to that information depends on the channel:
In most cases, you submit your own information directly to Jaspari Studies through an intake or eligibility form on the Platform, typically after clicking an advertisement or link. In this case, Jaspari Studies determines the purposes and means of processing that information, including how it is used to match you against current and future studies, and Jaspari Studies is the controller of that information for purposes of applicable data protection law. Once you are matched to a specific Client’s study and your information is sent to that Client as a referral, the Client independently determines how it uses your information from that point forward, and the Client becomes an independent controller of your information for its own subsequent use.
In some cases, a Client provides Jaspari Studies with the contact information of an individual with whom it already has a lawful, existing relationship, such as its own patient, so that the Client may add that person to a study through the Platform. In this case, Jaspari Studies did not collect your information and is not its original source; Jaspari Studies acts as a service provider or processor on behalf of that Client, and the Client, not Jaspari Studies, is the controller responsible for the notices and consents that applied when your information was first collected. If you have questions about how your information was obtained in this circumstance, we encourage you to contact that Client directly, though you may also contact us using the information in Section 12 and we will assist where we are able.
We may also receive your information through other lawful channels not described above, such as from a referral partner, a third-party lead source, or another compliant means of collection, in which case the party that collected your information is responsible for having done so consistent with applicable law and its own disclosures to you, and Jaspari Studies uses that information consistent with this Policy once received.
2Information We Collect
When you submit an intake or eligibility form on the Platform, we collect the personal information you provide, which may include your first name, date of birth, telephone number, ZIP code or other location information, and your answers to questions about medical conditions, medications, or other eligibility criteria relevant to the study or studies you may qualify for. If you choose to refer another person, we collect that person’s name and telephone number as provided by you. If you correspond with us or a Client through the Platform, including by text message, we collect the content and timing of those communications. If you are later scheduled for an appointment, we or the applicable Client site may collect additional information necessary for scheduling and visit reminders.
We also automatically collect certain technical information when you use the Platform, such as your IP address, browser type, device information, the pages you view, and similar usage data, including through cookies and comparable technologies used for security, fraud prevention, and understanding how the Platform is used.
3How We Use Your Information
We use the information described in Section 2 to: determine which current or future studies you may be eligible for, based on the condition, medication, or eligibility criteria you or a matching study’s rules require; ask you any additional eligibility questions needed to complete that determination; connect you with a Client whose study you appear to match, including by sending your information to that Client as a referral; send you text messages and other communications about your submission, your match status, and, where you have provided consent, about other current or future studies that may be relevant to you; support appointment scheduling and send appointment-related reminders where applicable; detect and prevent fraud, abuse, and misuse of the Platform; and comply with our legal obligations. Where a Client has referred an existing contact to us as described in Section 1, we use that information solely to place that person into the applicable study and support the same categories of activity described above on the Client’s behalf.
4Matching Logic
The Platform evaluates the eligibility information you provide against the inclusion and exclusion criteria of the studies configured on the Platform in order to determine which studies to present to you and which Client, if any, to send your information to as a referral. This determination is based on the information you provide and the criteria a study’s administrator has configured, and it does not involve inferences about you beyond what you or, where applicable, a referring Client have provided. If you believe you were matched or excluded in error, you may contact us using the information in Section 12 to request that a person review your submission.
5Referring Someone Else
If you indicate that you are submitting on behalf of, or in addition to, another person, we will ask you for that person’s name and telephone number. We obtain that person’s own consent before sending them any text message directly; until that consent is obtained, we do not message the referred person and instead send you, the submitter, information describing who you referred so that you may choose to reach out to them yourself.
6SMS Consent and Opt-Out
By submitting your telephone number through the Platform, you consent to receive text messages from Jaspari Studies at that number regarding your submission, your candidacy for current or future studies, appointment scheduling and reminders where applicable, and related account communications. Message frequency varies depending on your activity and the studies you are matched to. Message and data rates may apply. Consent to receive text messages is not a condition of using the Platform or of consideration for any study.
You may opt out of receiving further text messages at any time by replying to any message we send you with any of the following keywords: STOP, UNSUBSCRIBE, END, QUIT, or CANCEL. Once we receive one of these keywords, we will send you a one-time confirmation that you have been unsubscribed, and we will not send you further messages unless you opt back in as described below. You may opt back in and resume receiving messages by replying with any of the following keywords: START, UNSTOP, YES, or SUBSCRIBE.
In addition to these keywords, we use artificial intelligence and natural language processing as a supplementary layer of review to identify opt-out requests that are not exact keyword matches but that nonetheless clearly express an intent to stop receiving messages, such as "leave me alone," "please do not message me," "stop contacting me," or similar phrasing embedded in a longer reply. This additional review is designed to honor a genuine opt-out request even when it is not phrased as one of the exact keywords above, while avoiding treating an unrelated or ambiguous use of a similar word, such as asking to stop or cancel something else entirely, as a request to stop all texting. If you intend to opt out of text messages, we recommend using one of the exact keywords above to ensure it is processed immediately.
Carriers are not liable for delayed or undelivered messages. Standard message and data rates may apply based on your mobile carrier and plan. For more information about our SMS practices, see our Terms and Conditions at https://jaspari.com/studies/terms-and-conditions.
7How We Disclose Your Information
We disclose your information to the following categories of recipients:
Clients. When you are matched to a study, we share your relevant intake and eligibility information with the Client operating that study, and with the site, study staff, or scheduling personnel that Client designates, so that they may evaluate and, if appropriate, contact you regarding participation. More than one Client may operate studies you could match to, and your information is shared only with the Client or Clients whose study or studies you are matched to and referred for, consistent with the matching process described in Section 4.
Service providers. We share information with vendors who perform services on our behalf, such as text messaging and communications delivery, hosting and infrastructure, scheduling support, and analytics. These providers are authorized to use your information only to provide services to us and not for their own independent purposes.
Legal and safety purposes. We may disclose information where we believe in good faith that disclosure is necessary to comply with a law, regulation, subpoena, or other legal process, to protect the rights, property, or safety of Jaspari Studies, a Client, a volunteer, or others, or to detect, prevent, or address fraud, security, or technical issues.
Business transfers. We may disclose information in connection with a merger, acquisition, financing, reorganization, or sale of some or all of Jaspari LLC’s assets, in which case information you have provided would be among the assets transferred.
With your direction or consent. We may disclose information for other purposes where you have directed or consented to that disclosure.
We do not sell your personal information to unrelated third parties for their own independent marketing purposes.
8Cookies and Similar Technologies
We use cookies and comparable technologies on the Platform for purposes that are necessary to operate the Platform, such as maintaining your session and preventing fraud, and, where applicable, for measuring how the Platform performs and is used. You can control cookies through your browser settings; if you block or disable cookies, some parts of the Platform, including form submission, may not work correctly. Where required by applicable law, we will present you with a mechanism to manage non-essential cookie preferences before they are set.
9Data Retention
We retain the information you provide for as long as you may remain a candidate for a current or future study, so that we may continue to match you against studies that become available after your initial submission, which is the reason we ask for and retain your information in the first place. We do not currently apply an automatic deletion schedule to volunteer information based on the passage of time alone. You may request that we delete your information at any time by contacting us using the information in Section 12, and we will honor that request except to the extent we are permitted or required to retain particular information, such as to complete an active referral, resolve a dispute, defend a legal claim, or comply with a legal obligation, in which case we will retain only what is necessary for that purpose and for no longer than necessary. We periodically review whether continuing to retain volunteer information remains consistent with the purpose for which it was collected.
10Data Security
We use reasonable administrative, technical, and physical safeguards designed to protect your information against unauthorized access, use, or disclosure. No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of information you provide to us.
11Children’s Privacy
The Platform is intended for individuals who are 18 years of age or older, or the age of legal majority in their jurisdiction. We do not knowingly collect personal information directly from anyone under that age, except where a specific study is designed for pediatric participants, in which case information about a minor may only be submitted by that minor’s parent or legal guardian. If you believe we have collected information from a minor other than as permitted by this Section, please contact us using the information in Section 12 and we will take steps to delete it.
12Your Choices and Rights; How to Contact Us
You may decline to provide information, though doing so may mean we are unable to match you to a study or otherwise assist you. You may request access to, correction of, or deletion of the personal information we hold about you, or ask questions about this Policy, by contacting us at privacy-policy@jaspari.com or by mail at Jaspari LLC, 131 Continental Drive, Newark, DE 19713. We will respond within the time required by applicable law, and may need to verify your identity before completing certain requests. Depending on where you live, you may have additional rights described in Section 13, Section 14, or Section 18 below.
13Additional Disclosures for U.S. State Residents
Depending on the state in which you reside, you may have some or all of the following rights with respect to your personal information: the right to know or access the categories and specific pieces of personal information we have collected about you; the right to request correction of inaccurate personal information; the right to request deletion of personal information we have collected from you; the right to opt out of the sale or sharing of your personal information and out of its use for targeted advertising, to the extent applicable; the right to limit the use and disclosure of sensitive personal information, including health information, to what is reasonably necessary to provide the services you have requested; and the right not to receive discriminatory treatment for exercising these rights. We do not sell personal information as described in Section 7. You may exercise these rights by contacting us as described in Section 12. You may also designate an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may separately verify your identity directly with you.
14Additional Disclosures for the European Economic Area, United Kingdom, and Switzerland
This Section applies to the processing of personal information about individuals located in the European Economic Area, the United Kingdom, or Switzerland, and supplements the rest of this Policy. Where this Section conflicts with another part of this Policy as applied to such individuals, this Section controls.
Controller. As described in Section 1, Jaspari Studies is the controller of personal information you submit to us directly and, once your information is referred to a Client, the Client becomes an independent controller of your information for its own subsequent use. Where a Client has referred an existing contact to us, the Client remains the controller and Jaspari Studies acts as processor, as described in Section 1.
Legal bases for processing. We process your personal information on the following legal bases, as applicable: your consent, such as for SMS communications as described in Section 6; the performance of steps you request prior to, or in connection with, a potential referral to a Client, treated as necessary to take steps at your request; our legitimate interests in operating and securing the Platform and matching volunteers to relevant studies, where those interests are not outweighed by your rights and interests; and compliance with a legal obligation to which we are subject. Where we process special category data, such as health information, we do so on the basis of your explicit consent or another basis permitted under Article 9 of the General Data Protection Regulation.
Your rights. Subject to applicable conditions and exceptions, you have the right to: request access to your personal information and a copy of it; request rectification of inaccurate or incomplete personal information; request erasure of your personal information; request restriction of processing; receive personal information you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible; object to processing based on our legitimate interests; not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, subject to Section 4 above; and withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal. You may exercise these rights by contacting us as described in Section 12, and you have the right to lodge a complaint with the data protection supervisory authority in your place of residence or where the conduct at issue occurred.
International transfers. Jaspari Studies operates from the United States, and personal information you provide may be transferred to, stored, and processed in the United States and other countries that may not offer the same level of data protection as your home jurisdiction. Where required, we rely on appropriate safeguards for such transfers, such as the European Commission’s Standard Contractual Clauses, and will provide further information about the specific safeguards used upon request.
18Consumer Health Data in Washington and Other States
Categories of consumer health data we collect and why. We collect information about your medical conditions, medications, and other eligibility-related health information that you provide through the Platform, for the purpose of determining which current or future clinical trials you may be eligible for and connecting you with a Client operating a matching study, as described in Sections 2 through 4.
Sources. We collect this information directly from you when you submit an intake or eligibility form, and, where applicable, from a Client that has provided us with the contact information of an individual with whom it has its own existing relationship, as described in Section 1.
Categories shared, and with whom. We share your consumer health data with the Client whose study you are matched to and referred for, and with service providers who support that referral and our operation of the Platform, as described in Section 7. We do not sell consumer health data, and we do not share consumer health data for purposes of targeted advertising.
Consent. Outside of what is reasonably necessary to provide you the specific service you have requested, such as matching you to a study and sending your information to a Client you are referred to, we obtain your affirmative, opt-in consent before collecting or sharing your consumer health data, and any consent we obtain to share your consumer health data is separate and distinct from consent to collect it. You may withdraw consent at any time by contacting us as described in Section 12; withdrawal does not affect information already shared before you withdraw.
Your rights. In addition to the rights described in Section 13, you have the right to confirm whether we are processing your consumer health data, to access that data, to withdraw consent for its collection or sharing, and to request deletion of your consumer health data, including data held by our service providers and, where feasible, by Clients or other third parties to whom we have disclosed it in connection with a matter you are still an active candidate for. You may exercise these rights by contacting us as described in Section 12. We will not retaliate against you for exercising these rights.
Washington’s My Health My Data Act, and comparable consumer health data laws in other states, require certain businesses to maintain a standalone consumer health data privacy policy, separately and prominently linked, in addition to a general privacy policy. This Section is intended to satisfy that requirement with respect to consumer health data we process about Washington consumers and, to the extent applicable, consumers in other states with comparable requirements, and should be read together with, but is distinct in purpose from, the rest of this Policy. This Section does not apply to protected health information governed by HIPAA, which is addressed in the introduction to this Policy.
19Links to Other Websites
The Platform may contain links to third-party websites or services that we do not own or control, including a Client’s own website. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy notices before providing information to them.
20Changes to This Policy
We may update this Policy from time to time. If we make a material change, we will provide notice by updating the "Last Updated" date above and, where appropriate, through the Platform or by other reasonable means. Your continued use of the Platform after a change becomes effective constitutes your acceptance of the updated Policy.
21Contact Us
If you have questions, concerns, or requests regarding this Policy or our handling of your personal information, please contact us at:
This Policy is supplemented by our Terms and Conditions, available at https://jaspari.com/studies/terms-and-conditions, which governs your use of the Platform generally. To the extent this Policy and the Terms and Conditions conflict regarding the handling of personal information specifically, this Policy controls.