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Privacy Policy

This "Privacy Policy" describes the privacy practices of Yuzu Labs Public Benefit Corporation and StudyPages (collectively, "Yuzu Labs", "StudyPages", "we", "us", or "our"). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information from users of our websites (including and and related services, (collectively, our "Services") and explains the rights and choices available to individuals with respect to their information. This Privacy Policy governs any of the Services on which the Privacy Policy is posted. It applies to the users of our Services ("Users"), research participants, academic institutions, and our business customers "Customers." This Privacy Policy does not apply to "Customer Data", as defined below.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Customer Data Exclusion

As part of our Services, our Customer's employees and authorized users may enter information from or about their authorized users, employees, and clinical trial subjects (collectively, "Customer Data"), into our servers.

This Privacy Policy does not apply to Customer Data, and we are not responsible for our Customers' handling of Customer Data. Our Customers are the controllers of Customer Data and they have their own policies regarding the collection, use and disclosure of your personal information. Our use of this Customer Data is subject to the written agreement between Yuzu Labs and the Customer. Yuzu Labs' responsibility under that agreement is the obligation to keep Customer Data safe and secure. To learn about how a particular Customer handles your personal information, we encourage you to read that Customer's privacy statement or contact that Customer.

For purposes of the GDPR, the Customer is the controller of Customer Data. Yuzu Labs is not the controller of and does not have ownership of Customer Data. Please direct any questions regarding Customer Data to the Customer for which you work or which collected your information using a Yuzu Labs platform or application.

Personal Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide To Us

  • Personal and Business Contact Information. If you request a demonstration, or interact with our business team, we may request information such as your first name, last name, postal address, email address, telephone number, job title, and employer name.

  • Qualification Information. If you sign up to participate in clinical trials, we will collect the responses you provide through the Services such as answers to eligibility questions relating to clinical trials, which may include your gender, date of birth, health information, genetic information, medical records, location information, demographic information, living situation, education, or employment information. These questions will vary based on the specific clinical trial.

  • Registration and Profile Information. If you sign up for an account, register to use our Services, sign up for notifications or updates, or participate in our surveys, we may ask you for your first and last name, username and password, email address, telephone number, organization or institution name, department name, industry, interests, and preferences.** **

  • Medical Information. If you choose to upload your medical records to our Services, we will receive the contents of the medical or health related information.

  • Feedback and Correspondence. If you contact us directly, we may receive additional information about you, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

B. Information Automatically Collected

Location Information. We may infer your general location information, for example by using your internet protocol (IP) address.

Device Information. We may collect an IP address from visitors to our Services. We use IP addresses to help diagnose problems with our server(s), to administer the Services, and to monitor activities on and interactions with our Services.

We may also automatically log information about the device and software you use to access our Services. For example, we may log operating system name and version, device manufacturer and model, browser type, browser language, screen resolution, application installations, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services such as the pages or other content you view, the website you visited before browsing to our Services, the searches you conduct, your comments, any content you post, how long you spent on a page, access times and information about your use of and actions on our Services.

Information from Cookies and Similar Technologies. We and our third party partners collect information about you using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Please refer to the Cookies and Similar Technologies section for more details.

C. Information We Receive From Third Parties

Information from third party services. If you choose to link our Services to a third party account, we may receive information about you, including your profile information and your photo, education information, genetic information, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.

Medical Records. With your permission and at your direction, or at the request of a study site for a clinical trial in which you are participating, we may receive your electronic medical records from third parties such as a hospital, doctor, or other health facility. If your medical records are provided solely at the request of a study site for a clinical trial in which you are participating, our use of those records is in accordance with the informed consent for the clinical trial and the privacy policy of that study site.

Public Information. We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.

Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

How We Use Your Personal Information

To Provide Our Services

We use the information we collect to :

  • Operate, maintain, administer, enhance and improve our Services;

  • Communicate with you regarding our Services, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages. We may also send you messages regarding your Studypages Account, if you have one;

  • Process and manage registrations you make through our Services, including to track and administer trainings or events you have registered for and attended;

  • Understand and analyze your needs, and interests, how you use our Services to develop new products, services, features, and functionality;

  • Personalize your experience on our Services, such as by providing tailored content and recommendations;

  • Send you text messages;

  • Provide support and maintenance for our Services; and

  • Respond to your service-related requests, questions and feedback.

To Communicate with You

We use the information we collect to communicate with you, provide you updates and other information relating to our Services, provide information that you request, respond to comments, feedback and questions, and otherwise provide customer support.

If you request information from us, register on our Services, or participate in our surveys, promotions or events, we may send you StudyPages-related marketing communications as permitted by law. You will have the ability to opt out of such communications. Please see the Your Choices section below for more details on how to opt out of marketing communications.

For Marketing and Advertising Purposes

With your consent or as permitted by applicable law and consistent with this notice, we may use your information for marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant valuable or otherwise of interest to you.

To Comply with Law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With Your Consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Services, you instruct us to take a specific action with respect to your personal information, you opt in to marketing communications, or as otherwise described in this Privacy Notice. We may also use the information we collect for other purposes for which we provide specific notice at the time the information is collected.

To Create Anonymous Data for Analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, so that it is no longer reasonably possible to ever use the data to identify you. We may use this anonymized data for lawful business purposes, such as improving our Services.

For Research Purposes

We may use aggregate, de-identified information for research purposes, to generate, or to disclose to academic institutions.

For Compliance, Fraud Prevention and Safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our Services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Your Personal Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We disclose personal information to third parties under the following circumstances:

  • Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery and database management services).

  • Customers. We may share the information we collect, including analytics or insights based on personal information with our current or prospective Customers consistent with this Privacy Policy;

  • User-Generated Content. If you choose to post testimonials or upload other content on our Services ("User-Generated Content"), your User-Generated Content will be displayed on the Services and viewable by others by default. To learn more about how to update or remove a testimonial, please see the "Your Choices" of this Privacy Policy section below. We are not responsible for other users' use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Services.

  • Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.

  • Analytics Partners. We use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, your comments, any content you post, and the dates and times of your visits.

  • Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative ( or the Digital Advertising Alliance ( If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

  • Researchers and Academic Institutions. We may disclose aggregate, de-identified information to researchers or academic institutions for research purposes.

  • Study Teams. If you request an eligibility assessment, we may disclose your information, including portions of your medical records with select Study Teams.

  • Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us;

  • Compliance with Laws and Law Enforcement; Protection and Safety. We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services;

  • Business Transfers. We may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

  • Consent. We may also disclose your information with your permission.

Your Choices

Access, Update, Correct or Delete Your Information

All Studypages Account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Studypages Account holders may also contact us at to accomplish the foregoing or if you have additional requests or questions.

Changes To Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at

Marketing Communications

You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at Even if you opt out of receiving marketing-related emails from us, you may continue to receive service-related and other administrative emails from us.


If you gave us consent to post a testimonial on our Services, but wish to update or delete it, please contact

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in our Services or through other appropriate means.

Cookies and Similar Technologies

What Are Cookies?

We may collect information using "cookies." Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies We Use

Our Services use the following types of cookies for the purposes set out below:

  • Essential Cookies. These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These are primarily used by our employees and contractors.

  • Functionality Cookies. These cookies allow our Services to remember choices you make when you use our Services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences or re-enter information every time you visit our Services.

  • Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered may include the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day and duration they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.

Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the "settings," "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings. Please review your web browser's "Help" file to learn the proper way to modify your cookie settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit

Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. In addition, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Tracking Tags

We may also use tracking tags (which are also known as web beacons) on our Services to track the actions of users while on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, tracking tags are embedded on webpages. Tags compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using tracking tags is not linked to our users' personal data.

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no accepted standard on how to respond to "Do Not Track" signals, and we do not respond to such signals. To find out more about "Do Not Track," please visit


The security of your personal information is important to us. We make reasonable efforts to protect your information by using a number of organizational, technical and physical measures designed to improve the security of the information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security or privacy of your information.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at

***International Data Transfer ***

Yuzu Labs is headquartered in the United States. If you choose to use the Services from the European Union or other regions of the world with governing data collection and use that may differ from U.S. law, than please note that your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European Union users should read the important information provided in this Privacy Policy about transfer of personal information outside of the European Economic Area.

Other Sites and Services

Our Services may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User-Generated Content

We may make available on our Services, or link to, features that allow you to share information online (e.g., on message boards, testimonials, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via the contact information you have provided to us or another manner that we believe reasonably likely to reach you. This may include posting a specific announcement on our Services.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at, or write to us at:

2673 Suisun Ave
San Jose, CA 95121 USA
Attention: Data Protection Officer

Additional Information for European Union Users

Personal Information

References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by European data protection legislation.

Controller and Data Protection Officer

Yuzu Labs is the controller of your personal information for purposes of European data protection legislation. Our Data Protection Officer can be reached at See the "Contact Us" section above for additional contact details.

Legal Bases For Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the list below. If you have questions about the legal basis of how we process your personal information, contact us at

  • To provide the Services. Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

  • To communicate with you;

  • To create anonymous data for analytics; and for compliance, fraud prevention and safety. These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • To comply with law. Processing is necessary to comply with our legal obligations.

  • With your consent. Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at

Use For New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.


We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our Customers (including Contact, Identity, Financial and Transaction Information) for seven years after they cease being Customers for financial and tax purposes.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your Rights

For individuals located within the European Economic Area ("EEA"), European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails;

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information;

  • Correct. Update or correct inaccuracies in your personal information;

  • Delete. Delete your personal information;

  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice;

  • Restrict. Restrict the processing of your personal information;

  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

  • Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.

  • For transfers to third parties in the United States, ensuring they participate in the EU-US Privacy Shield Framework.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

EU-U.S. Privacy Shield and Swiss-US Privacy Shield

Yuzu Labs complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

As a participant in the Privacy Shield, Yuzu Labs is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Our accountability for personal information we receive in the United States under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal information on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Yuzu Labs commits to resolve complaints about our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact Yuzu Labs at:

Yuzu Labs has selected a third party to serve as its independent recourse mechanism (IRM) for dispute resolution arising from certain transfers or processing of Personal Information (non-HR data) under Privacy Shield. Yuzu Labs has further committed to refer unresolved Privacy Shield complaints under the EU-US and Swiss-US Privacy Shield Principles to the EU Data Protection Authorities (DPAs). If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact your National DPA at for more information or to file a complaint. The services of DPAs are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Effective: 2021/05/24