This Privacy Policy describes how Lightship Inc. and its affiliates, including Lightship Clinical Research Ltd. in the UK (collectively, “Lightship,” “we,” “us,” or “our”), collects, uses, shares, and safeguards personal information. This Privacy Policy sets out at a high level how we comply with data protection, privacy, confidentiality, and associated laws in the USA and UK and may be supplemented by additional wording specific to a particular data collection from you. Depending upon whether you are in the USA or UK, it also tells you about your rights and choices with respect to your personal information and how you can reach us to get answers to your questions. You can jump to specific topics by going to the headings below:

Types Of Personal Information We Collect & For What Purposes
Sharing Of Information
Your Rights & Choices Regarding Your Personal Information
How We Protect Personal Information
Miscellaneous
Contact Information

If you are a UK/EEA candidate applying for a job at Lightship, please visit our Employee Recruitment Privacy Notice.

If you are visually impaired, you may access this notice through your browser’s audio reader.

Types Of Information We Collect & For What Purposes

Wherever you are, here are examples of the type of information that we collect from and about you and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Clinical trial recruitment	If you choose to take part in a clinical trial, we will collect your name, contact details, date of birth and other screening information, which may include but is not limited to, health and medical/ medication history, ethnicity, height, weight, family history and any other information necessary to determine your suitability for a given trial. We may also ask for your opinion on our service through the provision of an optional satisfaction survey.	We obtain your consent to process this information to assess your eligibility for a given trial and for safety reasons should you go on to participate in the trial.  If you have provided your consent, then we may also add your details to our database so that we can inform you about suitable clinical trials in the future. Where necessary, we may also request a copy of your medical history from your treating physician following your authorisation.
Health screening	On some occasions, we offer screening and testing services for certain diseases in communities. We collect your name, contact details and necessary medical information.	Once the test has been performed, the data/result will be shared with you. If you provide your consent, your information will be added to our database to ensure we can contact you about current and future trials or related initiatives relevant to your health condition(s).
Market research	You may take part in our market research without volunteering any of your personal information. However, you also have the option of providing identifying information, including your contact details, which may be linked back to your feedback/opinions collected as part of the survey.	Market Research provides us with valuable insights. You can take part without being identified, or where you choose to provide your personal information, we will seek your consent to process this information.  We may then contact you about current and future trials or related initiatives relevant to your health condition (if you have disclosed this information to us).
Client relationship management	We collect the name, contact details, and other professional information about our clients and their employees, or any third parties employed or engaged by them, with whom we may interact.	Where relevant to our client contracts, we will contact them concerning normal business administration, such as projects, services, B2B marketing, satisfaction surveys, and billing.
Investigator / Healthcare professional engagement	We collect personal information, such as your name, contact details, age, gender, ethnicity, licensure coverage, or other professional information. If you are acting as an investigator on a trial, we may also be required to conduct a background check.	We obtain your consent when processing your personal information to understand your qualifications and training necessary to conduct a trial, for diversity and inclusion monitoring, to identify native languages which can be matched to the needs of our client’s and patients, and for the purposes of performing our contract with you, as it relates to normal business administration, satisfaction surveys, and billing, where relevant.
Patient mobile application	Patients who have enrolled in a trial will be offered Lightship’s secure Patient App. The App will collect account credentials such as name, email address, scheduling information for study visits and responses to health questionnaires and satisfaction surveys.	Patients will consent to the use of Lightship’s Patient App to manage account access, scheduling of study visits and engagement with Lightship’s study team throughout the course of a trial. This is designed to provide patients with a safe and convenient way to manage and share information. Should a patient not consent to use of the App, our study team can discuss alternative approaches for engagement.
Feedback/Support	If you provide feedback or contact us for support, we will collect your name and email address, as well as any other information that you wish to send to us in order for us to respond.	By submitting a request to us, you consent to us processing your personal information to act upon your query, feedback, or issue.
Employment	If you apply for a job posting, or become an employee or contractor, we collect information necessary to process your application or to hire and/or retain you as an employee or contractor.  This may include your contact details, professional qualifications, employment history and government issued identification. If necessary for a given role, we may conduct background checks, including criminal history and professional disbarment where the local law permits.	We use information about current employees or contractors to manage your employment or engagement, or in anticipation of a contract with you. In some contexts, we are also required by law to collect certain information about our employees or contractors. We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Email interconnectivity	If you receive an email from us, we use certain tools to capture data related to when you open our message or click on any links or banners it contains.	We obtain your consent prior to enabling this functionality to understand how you interact with our communications so that we may make them more relevant to you.
First party cookies	We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed to enable the website to function appropriately from a technical standpoint and to improve the user experience of the site. This can include information about your device or browser.	We have a legitimate interest in collecting strictly necessary cookies for our website to function. Where we collect cookies to improve the performance of our website based on how you interact with it or to personalise your experience based on your preferences and interests. We will always seek your consent. We apply the same approach to cookies when you access our website via your mobile device.
Third party cookies	We work with third parties to help us identify potential participants for our clients’ trials and for other purposes. These third parties may use technology, such as cookies, to track whether you have completed a questionnaire on our site.	The terms and conditions should be set out in the privacy policy of the third party’s website through which you came. Lightship does not have control over these types of cookies.
Web logs	When completing one of our online questionnaires (e.g., study online screener or market research survey), we collect your Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used).	We have a legitimate interest in monitoring our networks and the visitors to our websites to cut down on fraudulent activity or bogus screeners completed by a robot.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. Where legally necessary, if we believe you do not already know that we hold personal information about you (e.g., we do not have an existing active relationship with you), we will inform you that we are now holding your data, the reasons why, and inform you of your rights and choices.

Where permitted by appliable law, we may process your personal data for a compatible purpose secondary to the primary reason for collection, such as obligations under law or scientific research in the public interest. We may also process your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, equality and diversity monitoring, or a violation of our policies.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

• Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. Except as described elsewhere on our site, we will not provide personally identifiable information to any non-affiliate in exchange for compensation or consideration without your explicit consent.
• Medical and Other Consultants. We may share information with research coordinators, investigators, and physicians (including your general practitioner), safety monitors and statisticians, who advise on, supervise or are otherwise involved in carrying out screening activities to facilitate recruitment onto a trial.
• Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
• Public. Some of our websites may provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publicly available.
• Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, and provide technical support.
• Courts, regulators, and competent authorities.  We may share your information as and when the need arises.

When we share data with our contractors and service providers, this will be under suitable contractual conditions of confidence including security safeguards.

Your Rights & Choices Regarding Your Personal Information

The following rights and choices are available to you, but some exceptions may apply based on our reason for processing your personal information and the local privacy laws in your jurisdiction. Depending on the above, you may have the right to:

• Access Your Personal Information. You may request that we send you or another organisation or person a copy of your personal information held by us. 
• Change Your Personal Information. We rely on you to ensure that the personal information we hold is up to date. You may request us to correct or modify your personal information where it is inaccurate or incomplete at any time. Note that we may keep historical information in our backup files as permitted by law.
• Delete Your Personal Information. Typically, we retain your personal information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information or request that we delete your personal information. Note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our legitimate business purposes, which could be to honour your wish not to be re-contacted.
• Object to Certain Processing. You may under certain circumstances object to our use or disclosure of your personal information.
• Withdraw Your Consent. You may withdraw consent at any time or for any reason where such processing is based upon consent (for example, when signing up to hear about Lightship’s studies). If you withdraw your consent for the processing of personal information, then we may no longer be able to provide you services specifically related to the consent you have withdrawn.
• Restrict Certain Processing. You may, under certain circumstances, request that we restrict processing of your personal information
• Text Messages. If you receive an automated text message from us, you can opt-out of receiving future text messages by replying “STOP.”
• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. 

Please submit written requests and questions about your rights via our online webform or to privacyinquiry@lightship.com or call or write to our US or UK team using the contact information below.

Please note that, as required by law and for your protection, we will need to verify your identity before we are able to fulfil your information rights request. Depending on your request, we will ask you to validate existing information that we already have on file for you to ensure we are confident about your identity. We may also use two factor authentication techniques to do this. Following successful verification, we will fulfil your request to the extent necessary under applicable law and within applicable legal timelines. In some circumstances, you may designate a representative to submit requests to exercise your privacy rights on your behalf. We will require the representative to verify that they have been authorised to make this request on your behalf by presenting a copy of the signed permission. This should be submitted at the time of issuing the request to us. Without this information, the request may be denied.

How We Protect Personal Information

We use a number of technical and organisational security measures in an attempt to safeguard your data against any unauthorized access, disclosure, or loss and evaluate these measures on an ongoing basis. However, no method of transmission over the internet or use of electronic storage is fully secure; therefore, we do not guarantee that your data will be 100% secure from theft, loss, or unauthorized access.

In the event that we are required by law to inform you of a personal data breach, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether such access or use has been authorized by you. If you have reason to believe that your interaction with us is no longer secure (for example, if your account password has been compromised), please notify us immediately using the contact information below.

Miscellaneous

The following additional information relates to our privacy practices:

• Transmission Of Your Personal Information Outside of Your Home Country. Your personal information may be transferred to, stored, accessed from, and / or processed outside of the country where we collect it from you. This may include countries which may not be deemed as having the same or equivalent levels of personal information protection as your country. In such cases, we have put in place appropriate measures to protect your personal information when transferred, such as data transfer agreements and other contractual commitments or technical and organisational measures, which ensure legally appropriate safeguards. For more information on the measures that we use when transferring your personal information outside of your home country, please contact us using the details below.
• Retention Of Your Personal Information. Typically, we retain your personal information for an appropriate period given the nature of our interaction with you and in line with our records retention policy, unless a longer retention period is required or permitted by law.
• Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted, or we collected your personal information will generally continue to govern that information unless we receive your consent to the new privacy policy, where relevant. If your consent is not necessary, the new version of the policy will apply from the date stated. Our privacy policy includes a “last updated” date, which refers to the date that the current version was last substantively modified.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, please contact us at the appropriate address below. We will respond to your requests and provide you with any necessary additional privacy-related information. 

US Team:
privacyinquiry@lightship.com
+1-855-544-4820
Lightship, Inc.
222 Pacific Coast Highway 10^th Floor 
El Segundo, CA 90245

UK Team:
privacyinquiry@lightship.com
0808-189-0937
Lightship Clinical Research Limited
11^th Floor, Whitefriars Lewins Mead
Bristol
England, BS1 2NT

If you are in the UK and are not satisfied with our response, you have a right to lodge a complaint with the Information Commissioner’s Office.