Privacy Notice
Last Updated: Aug. 8th, 2025
RxTra Holdings LLC and its affiliated companies (“we,” “our,” or “us”) respect the privacy of all individuals. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”) and any transactions, interactions, or other engagements you might have with us (collectively, “Services”).For clarity, the term “Sites” does not include any sites owned or operated by third parties. Please read this Privacy Policy carefully. By using the Sites or Services, you consent to the collection and use of your information by us as set out in this Privacy Policy. This Privacy Policy forms a part of and is incorporated into our Terms of Service, and any capitalized terms used but not otherwise defined in this Privacy Policy will have the meanings given to them in the Terms of Service.
IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT PERMITTED TO USE OR ACCESS THE SITE.
ABOUT THIS PRIVACY POLICY
Privacy Policy Changes
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services.
If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide notice, such as by a posting on the Sites or an email to your last known email address, before using your Personal Information in the new way.
Conflict Between this Policy and Laws and Regulations
When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites and Services are subject to the laws of the United States of America and that your Personal Information will be processed in the United States and other jurisdictions.
The Sites and Services are intended for use by individuals in the United States.
INFORMATION WE COLLECT
Personal Information
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
Identifiers and Contact Information such as name, address, email address, phone number;
Protected Classification Characteristics such as age, marital status, gender, and veteran or military status;
Health Information such as a medical condition or diagnosis related to your request;
Commercial Information such as the products that you have used, considered, or purchased, financial information, and health insurance information;
Professional/employment Information such as employment status;
Education Information such as level of education; and
Internet and Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;
Some of the Personal Information listed above may be considered sensitive under relevant privacy laws. This includes health information. We refer to this type of Personal Information as “Sensitive Personal Information” in this Policy. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above. The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.
Business Information
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.
Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our Sites, we may automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your Internet Service Provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites.
If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.
Communication Recordings
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you explicitly consent to our recording and retention of communications. We do not use message content or mobile phone numbers for third‑party marketing and we do not sell or share mobile numbers, SMS/MMS consent status, or message content for third‑party marketing; such content is retained only for compliance, security, or support, subject to reasonable retention limits.
Text Messaging & Mobile Number Use (No Sale/Sharing for Marketing)
We use your mobile number and SMS/MMS opt‑in solely to send the messages you request (e.g., account or program updates, appointment reminders, and—only where you provide prior express written consent—our own marketing messages). We do not sell, rent, share, or otherwise disclose your mobile number, SMS/MMS opt‑in status, or related consent records to any third party for their own marketing or promotional purposes. Your opt‑in is not transferable or assignable and applies only to the specific program(s) and brand(s) you joined. We do not accept or use purchased, rented, or shared opt‑in lists. You can opt out at any time by replying STOP; reply HELP for help. Message frequency varies; message and data rates may apply.
HOW WE COLLECT INFORMATION
From You
We may ask you to provide us with Personal Information when you communicate with us (online or offline), use the Sites or Services, enter into a relationship with us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction.
Cookies and Other Automated Tools
We and third parties use cookies (small text files placed on your computer to identify your computer and browser) and other automated tools such as pixels and clear gifs (collectively, “cookies”) to track your interaction with our Sites and to improve the experience of our Sites and Services, such as saving your preferences from visit to visit to present you with a customized version of the Sites and tracking certain aspects about a user’s visit or engagement with an email or other communications.
Many web browsers are initially setup to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of our Sites may not work if you delete or disable cookies.
We use the following types of cookies:
Strictly Necessary: These cookies are essential to operate the Sites and provide you with services you have requested.
Functional: These cookies enable certain features or non-essential functionality on our Sites. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Sites so we can provide you with a more personalized experience.
Analytics Cookies: These cookies help us and third parties understand how our Sites are working and who is visiting our Sites.
User activity information collected by cookies may be associated with additional information about a user’s session and Personal Information, if provided by the user.
If you arrive at our Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to our Sites, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information.
We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.
Partners and Third Parties
We contract with publishers and other third parties that operate websites that may collect Personal Information about you (“Partners”). When you visit websites of our Partners, you may be redirected to our Sites. We may gather data directly from Partner websites, or our Partners may post data to our Sites or otherwise transfer data to us. This may occur via display ads, click listings, inquiry forms or telephonic transfers from our Partners.
We also may receive data from advertisers, advertising agencies, and other parties that our Sites and Services may direct you to in furtherance of your inquiries and requests for goods and services.
HOW WE USE AND SHARE INFORMATION
We generally use Personal Information to connect you with program partners/clinical trial providers that can provide you with information about the goods and services that you have expressed interest about. We may also use your Personal Information for internal purposes, including:
Processing Purpose & Personal Information Used
Connect you with advertisers that can provide you with information about the goods and services that you have expressed interest about
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Providing the Sites and Services
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Marketing and market research
Send our own marketing communications only where you have provided the required consent (e.g., prior express written consent for marketing texts); perform analytics to improve our programs. We do not disclose Personal Information (including mobile numbers) to third parties for their own marketing or cross‑context behavioral advertising.
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Other company communications
Such as to provide you with information that may be of interest
Identifiers and Contact Information
Protected Classification Characteristics
Health Information Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Business operations
Such as to evaluate, develop, and improve business operations, products and services offered, and perform business administration and other normal business activities
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Compliance
Such as to comply with applicable legal requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights or the rights of others
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Information security and fraud prevention
Such as to operate information security and anti-fraud programs
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
We also use Sensitive Personal Information for the following purposes:
Health Information – to provide the Services and to determine trial eligibility. We do not use this information for profiling or behavioral advertising.
We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.
Service Providers
We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including for:
Provision of the Sites and Services;
Facilitating marketing, non-marketing, and internal communications;
Business analytics (both marketing and non-marketing related);
Project management and collaboration;
IT and network administration such as data storage and management, website hosting, data security, mobile application development; and
Day-to-day business operations such as courier services, facilities management, electronic signatures, and document destruction.
We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf. You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure.
Service Providers are prohibited from using Personal Information for any purpose other than performing services for us under a written contract.
We may share any of the types of Personal Information collected with one or more Service Providers.
Third-Party Sharing/Selling
We do not sell or share Personal Information for third‑party marketing or cross‑context behavioral advertising. Any “sale” or “sharing” references in this section reflect broad legal definitions (e.g., under the California Consumer Privacy Act/CPRA) and may include certain disclosures that are not exchanges of money and are not for third‑party marketing. We do not sell or share mobile numbers, SMS/MMS opt‑in status, or message content for third‑party marketing.
Our providing information to our clinical trial providers, as described above, may constitute “selling” of Personal Information under certain laws, including the California Consumer Protection Act. In the past twelvemonths, we have sold or shared Personal Information with third parties who are not our Service Providers (“Third Parties”) as follows:
Category of Third Party
Advertisers (providers of consumer goods and services)
Sale or Sharing (as defined by applicable law)
Sale
Purpose of Sale or Sharing
To enable our clients to market and provide their goods and services
Categories of Personal Information Sold of Shared
Identifiers and Contact Information
Protected Classification Characteristics
Health Information
Commercial Information
Professional/employment Information
Education Information
Internet and Network Information
Other Third-Party Disclosures
We may occasionally disclose your Personal Information to Third Parties, for purposes such as:
To comply with the law;
To respond to legal requests (including court orders, investigative demands and subpoenas) if, in our discretion, we believe it is necessary or appropriate;
To prevent or stop any illegal, unethical, or legally actionable activity;
To protect the safety, property, or rights of ourselves, consumers, or any other third party;
If we are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of our assets and the disclosure is necessary to complete the transaction;
To businesses controlling, controlled by, or under common control with us; and
For additional purposes with your consent where such consent is required by law.
CHILDREN’S PRIVACY
We do not knowingly collect or solicit Personal Information from anyone under the age of 16. In the event that we learn that we have collected Personal Information from an individual under the age of 16, we will delete that information upon discovery.
ADDITIONAL STATE LAW CONSUMER RIGHTS
If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia, you have additional rights to access and control your Personal Information. Exemptions may apply.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purpose for which we collected your Personal Information; and (iv) the categories of third Parties with whom we shared or sold your Personal Information.
We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person. To protect consumers’ Personal Information, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
If you are an Oregon resident, you have the right to request once per 12-month period that we provide you with a list of specific third parties to whom we disclosed (a) your Personal Information or (b) any Personal Information. We have the discretion to determine which list to provide.
Right to Deletion
You have the right to request that we delete any Personal Information we collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity.
Right to Correction
You have the right to request that we correct any Personal Information that we have on file about you that you believe to be erroneous. When you make your request, please be sure to provide us the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration.
We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
Right to Opt-Out from the Sale or sharing of Personal Information
We do not sell or share Personal Information for third‑party marketing; “sale” and “sharing” are legal terms defined broadly by certain state privacy laws (e.g., CCPA/CPRA). You have the right to direct us not to sell or share your Personal Information to third parties. We will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law. Submitting a Request If you are a resident of a state that provides privacy rights and you would like to exercise your rights, you may submit a request by email to information@rxtraclinical.com or using this online form.
After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not be able to process certain requests without verifying your identity, so please respond promptly to our request.
Authorized Agent
If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof your identity. You may provide this documentation via email to information@rxtraclinical.com after submitting the request. We may contact you and the consumer on whose behalf you claim to act to verify your identity, the consumer’s identity, and your authorization to act on the consumer’s behalf.
Non-Discrimination Notice
We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.
DO NOT TRACK SIGNALS
Because there is not yet a consensus on how companies should respond to web browser-based or other “Do Not Track” mechanisms, we currently do not respond to web browser Do Not Track signals that provide a method to opt out of the collection of information about online activities over time and across third party websites or online services. We may revisit our policy on responding to these signals, in which case we will post a revised Privacy Policy on the Sites.
DATA RETENTION
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes but is not limited to retention to comply with our legal, regulatory, tax, and/or accounting obligations.
OTHER TRANSFERS
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of any of our assets, we may disclose or transfer Personal Information and Usage Data in connection there with.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your Personal Information. While we have taken reasonable steps to secure the Personal Information you provide to us, please be aware that despite our efforts no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.
Therefore, we cannot guarantee complete security if you provide Personal Information to us, and we encourage you to exercise discretion regarding the Personal Information you choose to disclose.
HOW TO CONTACT US
If you have any questions about our Sites, Services, or this Privacy Policy, please contact us using the information below.
RxTra Clinical
Attn: Privacy
609 N Hepburn Ave Suite 201
Jupiter, FL 33469
information@rxtraclinical.com
