SplashBIO™ Biomarker-Driven Enrollment
Partner With SplashBIO

Privacy Policy

Effective Date: 16 June 2026

Privacy Commitment

This Privacy Policy applies to websites, online platforms and related services (each and collectively referred to herein as the "Site") developed, maintained and operated by SplashBIO, INC. (referred to herein as "SplashBIO", "we" or "us"). SplashBIO is a clinical trial enrollment company that uses biomarker-driven pre-screening to reduce screen failures and accelerate trial enrollment. Users of and visitors to our Site (referred to herein as "users" or "you") are responsible for carefully reading this Privacy Policy in its entirety. This Privacy Policy describes the information we collect about you and how we keep your personal information safe and confidential. Please be advised that SplashBIO may maintain and/or operate other websites or digital properties (apart from the Site) which are governed by different privacy policies or notices that are made accessible to you on those other websites or digital properties, and we encourage you to review the applicable privacy policy or notice on the website or digital property that you utilize.

SplashBIO understands that privacy is important to you. The information that we collect about you from our Site will be maintained and used in accordance with this Privacy Policy and applicable laws, rules and regulations. By accessing our Site, you agree to the terms and conditions set forth herein. If you do not agree to any of the terms or conditions in this Privacy Policy or other applicable privacy policies or notices, please do not access or use any part of our Site.

By providing us with your Personally Identifiable Information (as defined below), including Personal Health Information (as defined below), you consent to the collection and use of any information you provide in accordance with this Privacy Policy.

SplashBIO may share information among its subsidiaries and third parties working with or on behalf of SplashBIO, and SplashBIO makes commercially reasonable efforts to ensure such information is protected in accordance with the terms of this Privacy Policy. SplashBIO is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Information We Collect

We will collect information through the use of Cookies (as defined below), Web Logs (as defined below), or IP Address (as defined below). We will only collect Personally Identifiable Information (as defined below) including Personal Health Information (as defined below) if you voluntarily provide such information to us, as described in further detail below.

Cookies

We collect non-identifiable web usage data about your use of our Site through the use of Cookies. A Cookie is a small piece of information that our server sends to your web browser when you access our Site. Every computer that accesses our Site is assigned a different Cookie by SplashBIO. Cookies are capable of storing many types of non-identifiable data. Cookies may be used to help us analyze usage of our Site or to restrict underage use of the Site. We do not link basic data from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store Personal Health Information about you.

Most browser software can be set to reject all Cookies. Note, however, that some portions of our Site may not work properly if you reject Cookies.

IP Addresses

We may also receive IP addresses in the normal course of the operation of our Site. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

Web Logs

SplashBIO uses standard Web Logs that record basic data about your visit to our Site, such as the date and time of the visit, the pages viewed during the visit and the domain name of your Internet service provider.

We do not normally seek to identify individuals from Web Logs. However, we may use Web Logs to identify an individual whom we suspect tried to damage our Site or use them in an unauthorized way. We may share our Web Logs with law enforcement agencies if we believe there has been a violation of computer security or related laws or as otherwise required in order to comply with applicable law or legal process. In addition, we may share our Web Logs (which do not contain any Personally Identifiable Information) with our partners to assist them in better designing their websites for clinical research studies.

Google Analytics

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google") which uses cookies to help analyze how users use the Site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on SplashBIO's behalf under Google's privacy policy, which you can access here: https://support.google.com/analytics/answer/6004245.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our Site. By using our Site, you consent to the processing of your information by Google in the manner and for the purposes set out above.

Collection, Use and Disclosure of Personally Identifiable Information and Personal Health Information

Personally Identifiable Information that may be collected via a clinical research study survey is information that can be traced back to an individual. Personal Health Information is a combination of your Personally Identifiable Information with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your name, it becomes Personal Health Information. Examples of Personally Identifiable Information include your name, home address, telephone number, email address, date of birth, and any other information that may be used to identify you.

You may voluntarily provide Personally Identifiable Information and/or Personal Health Information in a variety of circumstances, and if you choose to do so, you consent to our collection and use of such information as described in this Privacy Policy. For example:

  • We may collect Personally Identifiable Information, including your name, company affiliation and email address, when you provide such information to submit an inquiry to us on the "Contact Us" portion of our Site. We will use such information to respond to your inquiry.
  • We may also collect Personally Identifiable Information and/or Personal Health Information when you provide such information to us in a survey or questionnaire on our clinical research study Sites and we will use such information to determine if you may be eligible for research study participation (such surveys/questionnaires referred to herein as "Study Eligibility Surveys").
  • We also operate call centers for the purpose of communicating with you to verify that information you've provided in Study Eligibility Surveys is accurate and to collect additional Personally Identifiable Information and/or Personal Health Information as needed to determine your eligibility to participate in clinical research studies or further prescreening based on scientifically validated tests. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SplashBIO. Inaccurate information will affect our ability to properly determine if you may qualify to participate in a research study.

While you may view some of our study Sites without providing Personally Identifiable Information, submitting Personally Identifiable Information to us will be required to be considered for participation in a research study.

  • We may also collect Personally Identifiable Information and/or Personal Health Information when you provide such information to us in surveys on our clinical research study Sites which solicit patients' concerns and opinions about their clinical research experience (such surveys referred to herein as "Research Feedback Surveys"). We use information included in your responses in the Research Feedback Surveys to assist sponsors and contract research organizations with whom we work to create a more patient-focused research experience, and we disclose such information to those sponsors and contract research organizations in summary analytics form (i.e., in a form which does not identify you) for the same purpose.

We will not use or disclose Personally Identifiable Information or Personal Health Information of users of our clinical research study Sites for any purpose other than those described in this Privacy Policy or in other applicable privacy policies or notices that are made accessible to you on such study websites. If purposes for using Personally Identifiable Information or Personal Health Information change at any time, we will update applicable privacy policies and/or notices. In addition to the uses of Personally Identifiable Information and Personal Health Information described above, we also use and disclose Personally Identifiable Information and Personal Health Information obtained from users in the following ways:

  • Communication With Regard to Study Referral Pre-Qualification and/or Other Study-Related Purposes. Personally Identifiable Information will be used by SplashBIO to follow-up with the clinical study site about your pre-qualification for and participation in the study and may be shared with the clinical study site for its assessment of your qualification for and participation in a study.
  • Agents and Service Providers Supporting Study Recruitment Efforts. We sometimes employ web hosting companies to maintain our clinical study Sites and data collected through those Sites on our behalf in support of our study recruitment efforts. We may share your personal information, such as your name, disease or condition, home address, telephone number, email address, date of birth, and any other information that is linked to this identifying information, with these hosting companies so that they may perform such web hosting services for us. We also engage service providers that assist with operating call centers in order to verify and/or collect information needed to determine study eligibility. Your Personally Identifiable Information and/or Personal Health Information may be shared with those service providers assisting with call center operation. With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.
  • Medical Providers Supporting Study Recruitment Efforts. We sometimes employ medical providers to facilitate medical records requests, medical test requests, and telehealth support for study recruitment efforts. Personally Identifiable Information and/or Personal Health Information may be shared with these service providers assisting with supporting study recruitment efforts.
  • Digital Health Technologies Supporting Study Enrollment Efforts. We also engage Digital Health Technology service providers that assist with Digital Assessments of Bio-markers, Digital tests, and collecting real world data in order to verify information needed to determine study eligibility. Your Personally Identifiable Information and/or Personal Health Information may be shared with these service providers assisting with supporting study recruitment efforts. With respect to those companies and individuals with whom we share your personal information, we use commercially reasonable efforts to ensure that those companies and individuals adhere to this Privacy Policy or privacy practices similar to those indicated in this Privacy Policy.

We may also be required to disclose Personally Identifiable Information and Personal Health Information to comply with a law or regulation, in response to a search warrant, subpoena, court order, or other valid legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you, unless doing so would violate the law or be inconsistent with our legal obligations.

We may also disclose Personally Identifiable Information or Personal Health Information in any of the following circumstances, in each case as permitted by applicable laws and regulations: (a) to protect our legal rights or the rights of users of our Site, (b) to protect the security or integrity of our Site, (c) to take precautions against liability, (d) to enforce this Privacy Policy, (e) if SplashBIO undergoes any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, (f) to detect, prevent, or otherwise address fraud, (g) pursuant to your explicit approval, or (h) during emergencies if physical safety is believed to be at risk.

Aggregate Data

We will combine the information you provide with information from other visitors to our Site to create Aggregate Data which does not contain any uniquely identifying information. We will share this Aggregate Data with the sponsors of our Site, and/or their consultants. We will periodically analyze this Aggregate Data and use what we learn to make improvements to our Site. We may also share this Aggregate Data with our partners to assist them in better designing their websites.

Children's Privacy

We are committed to protecting the privacy of children. Neither SplashBIO, nor any of its Sites or services, are designed or intended to attract children under the age of 13. We do not collect, solicit, or use Personally Identifiable Information from any person we actually know is under the age of 13. If we learn that we collected Personally Identifiable Information from any child under the age of 13, we will endeavor to delete that information as soon as possible. Please contact SplashBIO at privacy@splash-bio.com or phone number (414)-443-3280 if you have reason to suspect that we have collected Personally Identifiable Information of any child under the age of 13.

Data Security

We maintain generally accepted industry standard technical, physical, and organizational procedures to safeguard Personally Identifiable Information and Personal Health Information against unauthorized or unlawful processing and against accidental loss, alteration, disclosure and access. Please note, however, that there are inherent risks in transmission of information over the Internet and electronic storage of information, and we cannot guarantee that unauthorized access or use of your Personally Identifiable Information or Personal Health Information will never occur.

Links to Other Websites

Our Site may contain links to other websites which are not operated or controlled by SplashBIO. Please keep in mind when you access websites operated by other parties, whether through links on our Site or otherwise, that we do not control what happens on those websites. You should always check the privacy policy of the website you are visiting in order to be sure you know how the operator of that website will collect information from you and what the operator of that website will do with the information.

Internet Transmission Risks

We acknowledge that no internet transmission is ever 100% secure or error free. It is your responsibility to ensure that the computer or device you use is adequately secured and protected against malicious software, Trojan horses, computer viruses and worm programs. Without adequate security measures on a computer or other device, there is a risk that the information you provide could be disclosed to unauthorized third parties. Similarly, despite SplashBIO's efforts to protect your Personally Identifiable Information and Personal Health Information, as noted above, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.

Rights to Access, Amend, and Delete Information

SplashBIO acknowledges under certain laws and regulations, individuals have rights to access, amend and/or delete their personal data. To the extent such laws or regulations apply to SplashBIO, you may request that we provide you with access to, amendment of, or deletion of your personal data. You may do so by contacting the Privacy Contact as set forth below, and we will respond within a reasonable timeframe and as required by applicable laws and regulations.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@splash-bio.com.

Changes to this Privacy Policy

As privacy laws and regulations evolve or in other circumstances as deemed necessary in our discretion, we may revise or update our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by referring to the "Effective Date" of this policy. Your use of our Site constitutes your acceptance of the terms of the revised Privacy Policy, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms.

Retention of Personally Identifiable Information and Personal Health Information

We will only maintain Personally Identifiable Information and Personal Health Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it was collected or processed. We will delete Personally Identifiable Information and Personal Health Information when such time period has ended.

International Transfers

We may transfer Personally Identifiable Information and/or Personal Health Information about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws and regulations. Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country. Accordingly, with respect to an international transfer, your Personally Identifiable Information or Personal Health Information may be subject to different protections depending on the laws and regulations of the country to which such information is transferred. In all cases, we will seek to apply reasonable safeguards to protect Personally Identifiable Information and Personal Health Information which we transfer internationally.

In compliance with the United States Federal Trade Commission, SplashBIO attests to the following:

  • We are subject to the oversight and enforcement authority of the United States Federal Trade Commission.
  • We may be required to release personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.

Individuals with inquiries or complaints should first contact SplashBIO at:

SplashBIO, Inc.
Attn: Privacy Officer
10361 W Innovation Drive
Wauwatosa, WI  53226
USA
privacy@splash-bio.com

U.S. State Consumer Privacy Laws Notice

SplashBIO acts as a service provider to organizations that sponsor clinical research studies and contract research organizations that support the conduct of clinical research studies (each such organization referred to hereunder as a "Sponsor"). The notice below describes the Consumer Personal Data (as defined below) that SplashBIO collects, uses, discloses and processes on behalf of Sponsors subject to U.S. state consumer privacy laws and explains the rights that may be exercised by individuals pursuant to such laws. As used herein, "Consumer Personal Data" means information that is linked or linkable to an identified or identifiable individual who is a resident of a U.S. state having an applicable consumer privacy law. Such laws include, without limitation, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), the Colorado Privacy Act ("CPA"), the Virginia Consumer Data Protection Act ("VCDPA") and the Connecticut Data Privacy Act ("CTDPA").

Categories of Consumer Personal Data Processed; Recipients of Consumer Personal Data; Purposes of Processing

SplashBIO collects, uses and discloses (collectively, "processes") Consumer Personal Data on behalf of Sponsors as follows:

  • Categories of Consumer Personal Data Collected: SplashBIO collects individuals' names, postal addresses, email addresses, phone numbers, month and year of birth, and health-related information (including without limitation, information relating to individuals' health diagnoses, conditions and treatment).
  • Source from which such Consumer Personal Data is Collected: The categories of Consumer Personal Data listed in the bullet point above are collected by SplashBIO directly from individuals who are the subjects of the Consumer Personal Data (each, a "Consumer").
  • Third Parties to which SplashBIO Discloses such Consumer Personal Data: SplashBIO discloses the categories of Consumer Personal Data listed in the bullet point above to the following third parties:
    • Clinical trial sites involved in conducting clinical trials for which SplashBIO recruits trial participants;
    • Medical Providers supporting study recruitment efforts;
    • Digital Health Technology service providers supporting study enrollment efforts;
    • Web hosting companies that maintain clinical trial websites on SplashBIO's behalf; and
    • Call centers that assist SplashBIO with trial participant recruitment efforts
  • Purposes of Processing such Consumer Personal Data: SplashBIO processes the categories of Consumer Personal Data listed in the bullet point above for the following purposes:
    • SplashBIO collects such Consumer Personal Data from Consumers and uses such Consumer Personal Data to perform clinical trial recruitment services and gain insight about Consumers' clinical research experiences to create a more patient-focused research experience;
    • SplashBIO discloses such Consumer Personal Data to clinical trial sites so that they may determine Consumers' eligibility to participate in clinical trials, communicate with Consumers about clinical trial participation and otherwise perform functions related to qualifying and enrolling Consumers in clinical trials;
    • SplashBIO discloses such Consumer Personal Data to third parties that are medical providers on SplashBIO's behalf so that such third parties may assist SplashBIO with clinical trial participant recruitment efforts.
    • SplashBIO discloses such Consumer Personal Data to third parties that are Digital Health Technology service providers so that they may assist SplashBIO to verify information needed to determine study eligibility.
    • SplashBIO discloses such Consumer Personal Data to web hosting companies so that they may assist SplashBIO in maintaining clinical trial websites and Consumer Personal Data collected through such websites in furtherance of SplashBIO's clinical trial recruitment services and its services related to creating a more patient-focused research experience; and
    • SplashBIO discloses such Consumer Personal Data to third parties that operate call centers on SplashBIO's behalf so that such third parties may assist SplashBIO with clinical trial participant recruitment efforts
  • Categories of Consumer Personal Data Collected: SplashBIO collects professional and employment-related information, including information which may be included on Consumers' curriculum vitae (CV), such as names, postal addresses, email addresses and phone numbers.
  • Sources from which such Consumer Personal Data are Collected: The categories of Consumer Personal Data listed in the bullet point above are collected by SplashBIO directly from Consumers, Medical Providers, Digital Health Technology service providers, and from Sponsors with which SplashBIO works.
  • Third Parties to which SplashBIO Discloses such Consumer Personal Data: SplashBIO discloses the categories of Consumer Personal Data listed in the bullet point above to the web hosting companies that maintain clinical trial websites of SplashBIO's behalf.
  • Purposes of Processing such Consumer Personal Data: SplashBIO processes the categories of Consumer Personal Data listed in the bullet point above for the following purposes:
    • SplashBIO collects such Consumer Personal Data from Consumers, Medical Providers, Digital Health Technology service providers, and Sponsors to perform clinical trial recruitment services;
    • SplashBIO collects and maintains such Consumer Personal Data to enable Consumers, Medical Providers, Digital Health Technology service providers, who are healthcare providers and other personnel employed by or affiliated with clinical trial sites to register on and use SplashBIO's clinical trial websites; and
    • SplashBIO discloses such Consumer Personal Data to web hosting companies so that they may assist SplashBIO in maintaining clinical trial websites and Consumer Personal Data collected through such websites in furtherance of SplashBIO's clinical trial recruitment services

Please be advised that SplashBIO does not sell any Consumer Personal Data nor does it share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, any Consumer Personal Data to any third party for cross-context behavioral advertising. Please also be advised that SplashBIO does not use or disclose sensitive Consumer Personal Data (such as health data) other than to perform the services reasonably expected by an average Consumer who requests those services.

Consumer Rights

Under U.S. state consumer privacy laws, Consumers have certain rights with regard to their Consumer Personal Data. Consumers may:

  • confirm whether their Consumer Personal Data are being processed and request access their Consumer Personal Data;
  • request correction of inaccuracies in their Consumer Personal Data;
  • request deletion of their Consumer Personal Data;
  • if Consumer Personal Data is available in a digital format, request to obtain a copy of the Consumer Personal Data that the Consumer previously provided in a portable and, to the extent technically feasible, readily usable format that allows the Consumer to transmit the data to another person/entity that determines purposes and means of processing the Consumer Personal Data ("Controller") without hindrance; and
  • request to opt out of the processing of the Consumer Personal Data for purposes of: (A) targeted advertising; (B) the sale of Consumer Personal Data; or (C) automated processing of the Consumer Personal Data to evaluate, analyze or predict personal aspects relating to the Consumer's health, personal preferences, interests or behavior ("Profiling") in furtherance of a decision that produces a legal or similarly significant effect concerning the Consumer.

If you are a Consumer who would like to make any of the requests noted above, please contact SplashBIO at privacy@splash-bio.com.

If you submit any of the requests noted above and your request is denied in whole or in part, you have the right to appeal that denial. If you would like to appeal any such denial, please contact SplashBIO at privacy@splash-bio.com. To help SplashBIO ensure that it considers information pertinent to your appeal, please include in your appeal request the detailed reasons why you believe your request should be approved. Not later than 60 days after SplashBIO's receipt of your appeal, you will receive a response in writing describing any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you will be notified of a method through which you may contact the attorney general to submit a complaint.

Please be aware that Consumers have the right to not receive discriminatory treatment for the exercise of their privacy rights under consumer privacy laws; this includes without limitation, the right of a Consumer who is an employee, applicant, or independent contractor not to be retaliated against for the exercise of their consumer privacy rights. SplashBIO will not discriminate against any Consumer for the exercise of those rights.

In addition to all of the Consumer rights mentioned above, Consumers who reside in the State of California ("CA Consumers") also have the right to know what Consumer Personal Data a business has collected about the CA Consumer, including the categories of Consumer Personal Data, the categories of sources from which the Consumer Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Consumer Personal Data, the categories of third parties to whom a business discloses Consumer Personal Data, and the specific pieces of Consumer Personal Data a business has collected about the CA Consumer. CA Consumers wishing to make any request noted in this paragraph should submit a request to SplashBIO at privacy@splash-bio.com.

Verification of Consumer Requests

Consistent with applicable consumer privacy laws, upon receiving a Consumer request, SplashBIO attempts to verify that a Consumer submitting a request is the Consumer about whom SplashBIO has collected Consumer Personal Data. SplashBIO generally attempts to perform such verification by matching data points provided by a Consumer with data points that SplashBIO already maintains about that Consumer. In certain cases, SplashBIO may request certain additional information from a Consumer for purposes of performing verification.

Agents of Consumers

A Consumer may use an agent to submit any of the Consumer requests described above on the Consumer's behalf. The agent must follow the same process as Consumers for submitting such requests (as described above). As permitted by applicable consumer privacy laws, SplashBIO may request a Consumer who uses an agent to verify the Consumer's own identity directly with SplashBIO and/or may request the Consumer to directly confirm with SplashBIO that the Consumer provided the agent permission to submit the request.

Any Consumer having questions or concerns about the above-mentioned privacy policies or information practices may contact SplashBIO using the privacy contact information noted below.

Privacy Contact Information

Questions or comments regarding this Privacy Policy or our privacy practices should be submitted to:

SplashBIO, Inc.
Attn: Privacy Officer
10361 W Innovation Drive
Wauwatosa, WI  53226
USA
privacy@splash-bio.com