Leapcure provides Services relating to clinical trial awareness and recruitment, specifically utilising digital marketing strategies to assist in pairing interested and potentially eligible individuals with clinical trials. This Privacy Policy describes how Leapcure, Inc. ('Leapcure') uses, discloses and otherwise processes the personal information provided when individuals engage with Services that Leapcure offers (the 'Services'). This Policy is designed to inform you about what types of personal data we collect when you complete a screening through our Services, how your data is used, with whom it is shared and your rights regarding your personal data. 

This Policy does not apply to the processing of your personal data if you are potentially accepted into a clinical trial at a later date. That specific clinical trial will have a separate privacy notice and related informed consent form which would be provided to you at the time of enrolment in that clinical trial. 

Leapcure obtains consent from each individual we collect data from in order to determine if that individual is eligible for the clinical trials for which we are recruiting. Leapcure acts as the Processor of your data on behalf of the Controller, who is our Client. Leapcure is utilised to perform digital clinical trial recruitment of patients like you, and processes this data to determine your suitability for potential participation in a current and/or future clinical trial. 

When you complete a screening through our Services, you may provide to us: 

● Contact details, such as your first and last name, phone number and email address. ● Biographic and demographic information, such as date of birth, gender and postcode. 

● Communications that we exchange with you, including when you contact us with questions or feedback, such as by email, phone or text message. 

● Health and medical information such as diagnosis and previous treatments will be confirmed, but no health and medical information beyond the individual’s attestation is ever collected. 

Third-party sources. We may combine personal information we receive from you directly, including our screening questionnaire, with personal information you explicitly share through other sources, such as: 

● Information from social media platforms. We may maintain pages on social media platforms, such as Facebook, LinkedIn, X, Google, YouTube, Instagram and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

● Patient Advocacy organisations, such as patient advocacy groups you have previously connected with about your interest in a clinical trial. 

● Research organisations, such as clinical trial investigators or contract researchers. 

User experience data collection. We and our service providers may log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and our website, such as: 

● Online activity data, such as which of our website pages you viewed, how long you spent on a screen, navigation paths between screens and information about your activity on a screen, and whether you have clicked links within them. 

We store all of the above-referenced information collected from individuals in our TLS/SSL secure database, which has restricted access to essential individuals and is password protected. When you complete a screening through our Services, all information collected, including notes from calls with individuals to confirm answers to the screening questionnaire, are stored only in the database defined above. The data is stored in a localised database in the Frankfurt region in Germany.

 How We Use Your Data 

We use your data for the following purposes or as otherwise explicitly described at the time of consent to this policy: 

Contact details and clinical trial preferences. We will collect your contact details (such as name, postcode and email address) and clinical trial participation preferences when you submit information to be initially screened for the clinical trial. All data is collected only after you explicitly consent under Article 6(1)(a) of UK General Data Protection Regulation (GDPR), which provides the lawful basis for data collection.  Examples include: how far you are willing to travel, how you prefer to be contacted and your previous participation in clinical trials. This data will be used to contact you if you meet the requirements for a clinical trial. Processing of your data for these purposes is necessary for you to express your interest in the clinical trial through our Services. If you do not qualify for this clinical trial, but provide your consent for future consideration, your contact details and participation preferences will be kept on file to inform you of future clinical trial opportunities. 

Health data. We will collect information about your health when you complete an initial screening with our Services, such as your confirmation of whether you have suffered from the studied condition, your current disease stage, prior medical findings and any ongoing treatments. This data will be used as necessary to assess your eligibility for the clinical trial. Leapcure does not conduct automated decision-making or profiling for any part of its initial eligibility assessment for the clinical trial. If you successfully complete the initial screening process through our Services conducted by a member of the Leapcure team, which means meeting the clinical trial study criteria as a possible patient participant, you will then be connected directly with the clinical trial research team at a study site so they can further evaluate your participation in the clinical trial. This connection includes sharing the screening results, including your health data, with the research team. The research team will assess your eligibility for the clinical trial based on the data you have provided to us and your initial screening evaluation through our Services. You will be 

asked to provide your explicit consent at the time you register for a screening with our Services, which will act as your consent for the sharing of this data with Leapcure and, potentially, the research team. 

Providing your personal data is necessary to ensure you can be initially screened for the clinical trial through our Services. All health data is collected only after you explicitly consent under Article 9(2)(a) of UK General Data Protection Regulation (GDPR), which provides the lawful basis for data collection. If you refuse to provide this data, or do not provide any consent required to process this data, we may not be able to conduct a preliminary screening through our Services. 

If you are accepted into the clinical trial, the provision of your data for the clinical trial sponsor and/or the research team for all purposes in connection with the clinical trial will be governed by separate privacy notices that will be provided to you at that time. 

User experience data. We collect and use your personal data to provide user support, and to operate and improve our Website and Services. The lawful basis for this processing is our legitimate interests (UK GDPR Article 6(1)(f)), specifically, our interest in understanding your user experience so we can support you, and in providing, analysing, and improving our Website and Services. 

As part of these activities, we may create aggregated, de-identified or other anonymous data from user experience data we collect. We may use this anonymous data for user experience purposes, such as improving our website and screening questionnaire experience and to better tailor experiences to website users, including to analyse and improve the Services provided and promote our business. 

Compliance and protection. We may use your data to: 

● Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; 

● Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 

● Audit our internal processes for compliance with legal and contractual requirements and internal policies; 

● Enforce the terms and conditions that govern our website and Services and

● Prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft. 

We may share your user-experience and clinical-trial–interest data with: 

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery and website analytics services). 

Business clients. We share your personal information with business clients to help better assist you in finding a clinical trial. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. 

Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Leapcure or our affiliates (including, in connection with a bankruptcy or similar proceedings). 

We are collecting your data to determine your interest in and suitability for specific clinical trials. 

Your personal health and clinical-trial–interest data may also be shared with the sponsor of the clinical trial (and/or representatives working on the sponsor’s behalf, such as data processors) in pseudonymised form for the purpose of sharing updates on clinical trial patient recruitment efforts and asking questions about specific considerations for patients on the clinical trial. Pseudonymised form means that the data that identifies you is replaced with a data-subject identification number, which is a number specific to you, to protect your identity. 

We may share your pseudonymised data with our representatives, and providers of services and functions on our behalf (that is, providers of hosting services, cloud services and other information technology service providers) or consultants, who will use the data for the purposes described above. The data is stored in a localised database in the Frankfurt region in Germany. 

If we transfer your personal data internationally, these countries may not provide the same protections as the data protection laws where you are based. We will ensure relevant safeguards are in place to afford adequate protection for your personal data, and we will comply with applicable data protection laws. In particular, if you reside in the UK, we rely on an UK government adequacy decision, on contractual protections for the transfer of your personal data or a derogation if available. For more information about how we transfer personal data internationally, please contact us as set out in the “How to Contact Us” section below.

Leapcure does not collect cookies to track users on its website or through its services nor does it engage in interest-based advertising or direct marketing emails. There are a number of ways to limit online tracking across browsers and websites, which we have summarised below: 

● Restricting cookies in your browser. Browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser pop-up. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. 

● Blocking advertising-ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. 

● Using privacy plug-ins or browsers. Leapcure does not use cookies to track users, but you can block websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plug-ins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. 

● Platform opt-ins. The following advertising partners offer opt-in features that let you opt in of use of your information for interest-based advertising: 

o Google: www.adsettings.google.com 

o Facebook: www.facebook.com/about/ads 

o X: www.x.com/settings/personalization 

● Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: 

o Digital Advertising Alliance for Websites: outout.aboutads.info 

o Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices 

o Network Advertising Initiative: optout.networkadvertising.org 

Note that because these mechanisms are specific to the device or browser on which they are exercised, you will need to opt in on every browser and device that you use. 

Do Not Track. Some Internet browsers may be configured to send 'Do Not Track' signals to the online services that you visit. To find out more about 'Do Not Track,' please visit http://www.allaboutdnt.com. 

Leapcure would like to make sure you are fully aware of all of your data protection rights. Your participation in our Services is always voluntary. Every user is entitled to the following: 

The right to access – You have the right to request that Leapcure provide copies of your personal data.

The right to rectification – You have the right to request that Leapcure correct any information you believe is inaccurate. You also have the right to request that Leapcure complete any information you believe is incomplete. 

The right to erasure – You have the right to request that Leapcure erase your personal data, under certain conditions. 

The right to restrict processing – You have the right to request that Leapcure restrict the processing of your personal data, under certain conditions. 

The right to object to processing – You have the right to object to Leapcure’s processing of your personal data, under certain conditions. In addition, you have the absolute right to object to processing for direct marketing and any other related profiling as specified by Article 21 of the UK General Data Protection Regulation (GDPR).

The right to data portability – You have the right to request that Leapcure transfer the data we have collected to another organisation or directly to you, under certain conditions. 

The right to withdraw consent – You have the right to withdraw your consent, which we obtain before collecting any data, at any time, to no longer be considered for our Services. 

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact our Data Protection Officer at: privacy@leapcure.com 

We retain personal data for as long as we have to by law, or where there is no legal requirement, we will only store it for as long as necessary to fulfil the purposes for which it was collected as described in this Policy. To determine the appropriate period for retaining your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we use personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

If you are not considered to be eligible for the current clinical trial, we will delete your personal data (or anonymise it so it is not possible to identify you). If you have asked us to do so, we may retain your contact details and participation preferences to inform you of future clinical trials. 

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. 

We employ a number of technical, organisational and physical safeguards designed to protect the data we collect. However, no security measures are fail-safe and we cannot guarantee the security of your personal information. 

Our Services are not directed at, or intended for use by, children under the age of 13, and we do not knowingly collect personal data directly from children under 13 (or under the age of digital consent in your jurisdiction, which is 13 in the UK under the Data Protection Act 2018).

Some clinical trials we support may include minors as eligible participants. Even where this is the case, Leapcure does not market its Services to children or solicit information from them directly. Where a trial involves a participant under 18, any personal data relating to that minor should be provided only by, and with the consent of, the minor's parent or legal guardian, who acts on the minor's behalf throughout the pre-screening process. Where we rely on consent as our lawful basis for processing a child's data, we obtain that consent from the holder of parental responsibility and take reasonable steps to verify it.

If we learn that we have collected personal data from a child under 13 without verified parental or guardian consent, we will delete that data promptly. If you are a parent or guardian and believe your child has provided us with personal data without your consent or if you wish to request access to, correction of, or deletion of your child's data  please contact us at privacy@leapcure.com. We will complete erasure requests in accordance with Article 17 UK General Data Protection Regulation (GDPR) (the "right to be forgotten"), which applies with particular force to data collected from children.

Leapcure reserves the right to alter this Privacy Policy, so please review the policies and website frequently. If Leapcure makes a material change we will notify you here, by email, by means of a notice on our home page, or other places Leapcure deems appropriate within 30 business days. What constitutes a 'material change' will be determined in good faith. 

You can reach us by email at privacy@leapcure.com or by mail at the following address: 

Leapcure

701 NE 136th Ave, Ste 200

Vancouver, WA 98684

USA 

If you would like to learn more about Leapcure, please email us at info@leapcure.com or visit our website (www.leapcure.com) to request information.

Our UK Representative

You may contact our local representative with any questions, requests, or complaints about your personal data:

Laura Brencher
laura@leapcure.com

Please mention [Company Name] when you reach out so they can route your query to us quickly.

Should you wish to report a complaint or if you feel that Leapcure has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office: 

Email: icocasework@ico.org.uk 

Address: Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF UNITED KINGDOM 

I am interested in learning about potential clinical trial eligibility and understand that this may involve submitting specific data relating to myself and my health. I understand that Leapcure will collect data about my experience on Leapcure’s website for the purpose of improving the user experience. I have read the Privacy Policy and Terms of Use and agree to the processing of my data by Leapcure. 

By submitting this information, I confirm that it is ok for Leapcure or affiliated study research personnel to contact me about possible clinical trial participation.