Healthcare Communications Group (HCG) Privacy Policy

Our Commitment to Privacy:
Your privacy is important to us. When we ask you to provide us with personal and confidential information we use secure, not publically available, systems in order to safeguard that information and make sure that it is used only for the purposes you intend. HCG always encrypts your personal information when we are collecting or transferring it. To better protect your privacy, we provide this notice explaining our online information practices.

The Information We Collect:
Through forms on our SUMMIT Web site and call center, we collect information that can be used to identify or contact you. This "personal information" allows us to determine if you may be eligible for a clinical trial. Personal information may include name, address, or date of birth. It also allows the clinical trial site conducting the trial to contact you regarding your participation and may allow us to contact you if you are eligible for a future clinical trial. You will always be given the opportunity to tell us how and if you would like to be contacted.

Information about you or your usage on any of our corporate or screening Web sites may also be collected through log files or cookies, created as you fill out forms or browse. "Cookies" are pieces of information that may be placed on your computer by a Web site for the purpose of facilitating and enhancing your communication and interaction with that Web site. This information will remain anonymous and aggregate information which does not identify any specific individual will not be used to contact or identify you, and is not considered personal information.

The Information We Offer:
Information provided through the HCG Web site and the sites it sponsors has been developed by HCG staff.

Information specific to a clinical trial is developed in consultation with trial sponsors and medical staff, and has been subject to IRB review and approval before being posted to any site.

HCG is a private corporation, and its Web sites are wholly supported by the organization.

The information provided on the HCG corporate Web site and sites sponsored by HCG is designed to support, not replace, the relationship that exists between site visitors and their physicians.

Advertising Policy:
Neither the HCG corporate Web site, nor any of the sites that HCG sponsors, displays advertising

How We Use Your Information:
HCG is a marketing consulting firm for the pharmaceutical, biotechnology, and medical device industries, helping to accelerate completion of clinical trials.

We use your personal information in order to determine if you may be eligible to participate in a clinical trial. You can be sure that:

We will not use your personal information without your permission
We will not share your personal information with anyone without your explicit approval
We will keep your personal information private and secure
HCG does not sell information to outside parties, but we may share personal information with designated clinical trial study sites if you have given permission

Information is shared only if a Web site user has:
• Successfully completed a pre-screening questionnaire
and
• Expressly consented to have his/her information shared
• Information may be used by study sites to further determine if a person may be eligible to participate in a clinical trial.

HCG reserves the right to access and/or disclose personal information as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment, or other violations of any law, rule, or regulation or the Web site's policies. We may transfer your personal information to a third party that purchases or merges with HCG; however, we shall only do so to a party that commits to provide the same level of privacy as set forth in this policy.

Our Commitment to Data Security:
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and HCG, or information stored on the Web site or our servers, will be completely free from unauthorized access by third parties such as hackers. Your use of the Web site demonstrates your assumption of this risk.

HIPAA Compliance:
Federal regulations called the "Privacy Rule" were issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The Privacy Rule protects certain health information and balances an individual's need to keep health information confidential with benefits that may be gained from health care research. HIPAA regulations cover certain corporate entities, although HCG is not a covered entity as defined by these regulations. However, because HCG works with organizations that may be covered entities; we have adopted additional safeguards to further protect the privacy of potential clinical trial volunteers.

European Data Protection Policy:
Personal information collected from users in countries of the European Union will be transferred to the United States only with your proper permission, and in compliance with the United States Department of Commerce Safe Harbor Certification. We confirm that the data security practices that protect your personal information comply with all European laws on data protection and that you may exercise all rights accorded to data subjects under European laws.

Changes to the Policy:
We regularly review our policy to ensure that it provides an appropriate level of protection for your personal information. From time to time, we may make changes to our policy to keep it current with industry standards. We will post the date of the most recent revisions on this page. Please keep in mind that your use of our Web site means that you accept our privacy policy.

How to Contact Us:
Should you have other questions or concerns about these privacy policies, please call Lisa Branson, HCG's Director of Technology Integration at 310.606.5700 or send an e-mail to lbranson@HCG.com.