Privacy Policy

This Privacy Policy describes how JMAC Partners LLC (“JMAC Partners” or “JMAC”) collects and uses the personal information you provide us. It also describes your choices regarding use, access and correction of your personal information. JMAC Partners is a marketing consulting organization that assists global pharmaceutical companies in recruiting and retaining subjects for their clinical research studies. Individuals entrust us with information of a personal and confidential nature, so we have adopted this Privacy Policy (“Policy”) to inform you about our practices in collecting, using and protecting such information. By using JMAC Partners services, you acknowledge your understanding of and assent to this Privacy Policy. If you do not accept this Policy, you are not permitted to use our services.

To the extent that the services are available to individuals located in the European Economic Area and the United Kingdom, we are bound by and act in compliance with the General Data Protection Regulation (“GDPR”).

Children Under 13

We are committed to protecting the privacy of children. JMAC Partners services are not designed for or directed to children under the age of 13, and we do not collect personal information from any person we actually know is under the age of 13. We may collect information about children from their parents or guardians, and any such information will be held in accordance with this Privacy Policy.

Information Covered by this Policy

This Policy applies to any personally identifiable information about you (“personal information”) that you may provide to JMAC Partners when:
  • Using any of our websites and applications or sending us information by email;
  • Speaking with one of our representatives on the phone; or
  • Providing information in writing.

Information We Collect and How We Collect It

In the course of providing our services, we may collect or receive your personal information in a few different ways. Often, you choose what information to provide, but sometimes we require certain information in order for you to use, and for us to provide you, the services.

We will collect personal information from you if you voluntarily submit the information to us through any mechanism (including online and offline channels), such as when you register for an account, provide responses to questionnaires, or submit inquiries to us. We also will have access to any personal and other information that you choose to share through our services.
  • Registration and Account Setup: For those services that require registration, you may need to provide us information including your name, country of residence, and email address. Additional information, such as a telephone number, address, demographic information (for example, age, profession, gender, current location and other geolocation information, zip code, birth date, or year of birth), travel-related identification information (for example, passports, visas and other government-issued identification), and other information pertinent to the needs of the relevant clinical trial may also be required to enable us to provide you a particular service.
  • Medical and Other Sensitive Information: To learn whether you satisfy the criteria for a particular clinical trial, we may request certain personal medical information, which is provided by you voluntarily if you are interested is possibly participating in a clinical study. If you meet the prequalification criteria for the trial, and grant JMAC Partners explicit permission to do so, your information may be forwarded to a study site in your area for further evaluation. The study site will be under strict constraints by laws governing the disclosure of your personal information.
    If we collect information from you specifying medical or health conditions, racial or ethnic origin, political opinions, religious, ideological, or philosophical beliefs, trade union membership, social security measures, administrative or criminal proceedings or sanctions (which are treated outside pending proceedings), or information with respect to personal sexuality (collectively, “Sensitive Information”), we will not disclose such Sensitive Information to a third party or use such Sensitive Information for a purpose other than those for which it was originally collected or subsequently authorized by you without obtaining your affirmative “opt-in” (unless we believe in good faith that we are required to do so in order to comply with an applicable statute, a regulation, a rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process).
  • Information from Third Parties: We may receive personal and other information about you from third parties in performance of services for those third parties. This may include personal information received from a clinical study site. Any personal information received from third parties will be used only for purposes of providing services directly to you or to those third parties.
  • Service Usage: Depending on which service(s) you choose to use, information may be required to use the service(s). The information may include Internet Protocol (IP) addresses, browser types, information relating to your device, domain names, and other statistical data involving the use of the service, your consents, preferences and self-identifying feedback may be necessary in order for us to provide a particular service. Such information may be combined, directly or indirectly, with any health information about you, including but not limited to, health information that JMAC Partners may receive from sources other than you.
  • Automated Information: We may automatically collect device-specific information when you install, access, or use our services. This information may include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see Our Cookies and Similar Technologies Policy section below.
  • Choice: You may choose not to provide us with certain personal information, or elect to not provide us with any personal information. In such events, you may still access and use some of our services. You will not be able to access and use those portions of our services that require your personal information.

Use of Your Personal information

Except as otherwise stated in this Policy or as authorized by you, JMAC Partners does not use personal information for any purpose(s) other than the purpose(s) for which the information was originally supplied, or the purpose(s) described in this Policy, unless we have obtained your consent to do so.

Pursuant to the GDPR, we rely on the following legal bases for processing your personal information:
  • Where you have given consent to the processing;
  • Where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the services or otherwise);
  • Where it is necessary for compliance with a legal obligation to which we are subject; and/or
  • Where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those legitimate interests.

Where your personal information comprises special categories of personal data under the GDPR (in particular, health information), we process your personal data only when you have given your explicit consent for us to do so

Where we process your information for the purposes of our legitimate interests, we do so as follows:
  • Providing and Improving Our Services: In general, we use your personal information and other information to deliver services you have requested, to help us understand who uses our services, for internal operations such as to improve certain service(s), to facilitate delivery of advertising (including but not limited to, location-based advertising) by us and third parties, to communicate with you generally, to survey you on your satisfaction with our service(s), and to send certain mandatory services-related communications. We also may contact individuals interested in clinical study participation about future opportunities. Except as provided herein or as authorized by you, we do not share, rent, or sell any personal information provided to us.
  • Use in Clinical Studies: We may use the personal information volunteered by a person interested in participating in a clinical study to screen for likely study eligibility, to locate a convenient study site, to refer that person to a site for enrollment, and/or to conduct follow-up communications to ensure that the person has been contacted by the study site and received the information he or she requested, and to monitor the quality of the contact with potential clinical study participants and to survey participants concerning their study participation experience. When we refer an individual to a study site, we transmit to the site the personal information volunteered by the individual to facilitate their enrollment or administer study-related services. If asked to do so, we may share personal information with government health officials and regulatory entities overseeing the clinical study and/or with the study sponsor or the sponsor's agents. We may also use information about groups rather than individuals to track and analyze study enrollment for various studies, or to show demographic trends, geographic groupings, or other aggregate statistics. These aggregate statistics may be disclosed to parties outside the study.
  • Opt Out Requests: If you submit to us a request to opt out of receiving information or being contacted, we will retain and use some of your information to avoid further contact with you. We may also retain your information to the extent it has previously been incorporated in anonymized data and as necessary for us to meet legal requirements and defend claims against us. Your personal information may have been disclosed to third parties, as described within the terms of this Policy, prior to our receipt of your notification. We will notify relevant third parties of any change or deletion of personal information or restrictions on processing, unless this proves impossible or involves disproportionate effort.

Disclosure of Your Personal Information

Service Providers: We may employ independent contractors, consultants, vendors, and suppliers, such as a call center, mail house, transportation provider, or any other third party (collectively, "Service Providers"), who may need to receive or handle personal information on our behalf in connection with the performance of services. We require these Service Providers to agree in writing to provide at least the same level of privacy protection with respect to your personal information as is required by this Privacy Policy and not to use your personal information for any purpose other than the purpose for which we retained it.

Third Parties: We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of our service(s). We may also provide personal information to third parties. The third parties to which we may provide personally identifiable and non-personally identifiable information may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers, and other similar parties.

Affiliates: We may disclose personal information about you to our affiliates. For purposes of this Privacy Policy, affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with us, whether by ownership or otherwise, or who has a shared or vested interest in JMAC Partners and/or our programs. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.

Business Reorganization: JMAC Partners expressly reserves the right to transfer, sell, or assign information concerning your use of the services including, without limitation, personal information to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, discontinuation of business or liquidation of JMAC Partners or in the event that we file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that express, written commitment is provided to use the data only for authorized purposes and the parties agree to adhere to the terms of this Privacy Policy.

Legal Compliance: We may disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Accessing and Correcting Your and Your Child’s Personal information and “Opting Out”

Upon request, JMAC Partners will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please contact us at inquiries@JMACP.com.

You may correct, update your or your child’s personal information, modify your contact preferences, or completely opt out of our services at any time.

You can update your or your child’s information, correct inaccuracies, or delete some or all of your or your child’s data by emailing us at inquiries@JMACP.com. In order to protect your privacy, we will take reasonable action to verify your identity before changing or deleting your information. We will respond to your request to access within 30 business days.

We sometimes refer to your consent to be contacted, to be included in a clinical trial, or to other use of your personal information as “opting in.” You may revoke your consent (i.e., “opt out”) at any time. To completely opt out of our services, please send a request:
  • In email to inquiries@JMACP.com
  • By fax to (877) 848-7967, Attn: Privacy Officer
  • By regular mail to JMAC Partners, Inc., Attn: Privacy Officer, 4501 Cartwright Road, Suite 606, Missouri City, TX 77459

We will retain your information for as long as your account is active or as needed to provide you services. Please note that we may retain and use your information as necessary to comply with our legal obligations, when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or similar legal process, resolve disputes, and enforce our agreements. Your personal information may have been disclosed to third parties, as described within the terms of this Policy, prior to our receipt of your notification. We will notify relevant third parties of any change or deletion of personal information or restrictions on processing, unless this proves impossible or involves disproportionate effort.

To the extent the GDPR applies, and in certain circumstances, you have the following rights relating to your and your child’s personal information:
  • To access and review the information that you have supplied to us;
  • To request that we correct any errors, outdated information, or omissions in information that you have supplied to us;
  • To request that your information not be used to contact you;
  • To request that your information be deleted from our records, where there is no good reason for us continuing to process it;
  • To object to us processing your personal information, where we are relying on a legitimate interest (or that of a third party);
  • To request the restriction of processing of your personal information;
  • To request the transfer of your personal information to another party; and
  • To the extent that we process personal information relating to individuals in the European Economic Area and the United Kingdom, to lodge a complaint with the relevant supervisory authority as defined in the GDPR within your country.

Cookies and Similar Technologies

JMAC Partners and our affiliates and service providers use cookies or similar technologies to analyze trends, administer websites and applications, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

“Cookies” are small text files that are placed on your computer or mobile device in order to identify your web browser and the activities of your computer or mobile device when using the service. Cookies are used to personalize your experience (such as dynamically generating content on webpages specifically designed for you), to assist you in using the service (such as saving time by not having to reenter your name each time you use the service), and to allow us to statistically monitor how you are using the service to help us improve our offerings.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.
As is true of most websites and applications, we gather certain non-personally identifiable information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve analytics and site functionality.

Third parties may also use their own cookies when you click on their link to their services or services on or from the service. Our Privacy Policy does not govern the use by such third-party services or services or providers of third-party advertising.

We use data analytics to ensure site functionality and improve our services. For example, we use mobile analytics software to allow us to understand the functionality of our apps on your phone. This software may record information such as how often you use the apps, what happens within the apps, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from. We do not link the information we store within the analytics software to any personal information that you submit within the mobile application.

Information Security

We maintain information security safeguards to protect your personal information. The personal information you provide is stored in a secure electronic database that has access limited to only those who have a legitimate need to know your information. All secure electronic databases contain physical, electronic and supervisory procedures in place to protect your information. We protect all personal information you provide using encryption, and utilize firewalls to protect our computer network from hackers. JMAC Partners additionally has internal policies in place, including mandatory trainings, to ensure personal information is not disclosed to any party not authorized or required to have the information. We take all reasonable steps designed to prevent destruction, loss, and unauthorized access, use, disclosure and alteration of personal information. Notwithstanding the above commitments, be aware that there is always some risk involved in transmitting information over the internet. There is also some risk that others could find a way to circumvent our security systems. As a result, while we strive to protect your personal information, we cannot completely ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

Our services may contain links to other websites or online services not owned or operated by JMAC Partners. We are not responsible for the privacy practices of such third-party websites or services. We encourage you to be aware when you link to other websites or services. You should read the privacy policies or statements of such websites and services. This Privacy Policy applies solely to information collected through use of our services.

Data Protection Laws

In jurisdictions with data protection laws, we will ensure that individuals can exercise all relevant informational rights regarding their personal information we process, including the rights of access and correction, to prevent direct marketing, block processing, and erase data.

When JMAC Partners serves as a processor or sub-processor of data on behalf of an organization based in the EU, JMAC does so under the written instructions of that organization, and the transfer of personal information is subject to the Standard Contractual Clauses approved by the European Commission.

JMAC Partners is not a covered entity according to the Health Insurance Portability and Accountability Act (HIPAA), and HIPAA does not apply to the individually identifiable information that a person interested in participating in a clinical study has voluntarily provided to a call center or website. Any personal information voluntarily provided is the equivalent of a survey rather than a medical record. We understand that information supplied may be of a sensitive nature and that the study sites we work with must comply with HIPAA guidelines. Therefore, the confidentiality of the personally identifiable information is vigilantly maintained and secured and we do abide by the rules set forth under HIPAA.

Inquiries, Complaints, and Requests to Exercise Rights

Any questions, concerns or complaints regarding the use of your personal information should be directed to JMAC Partners using the contact information below. JMAC Partners will make all reasonable attempts to resolve any dispute or complaint relating to the misuse or improper disclosure of personal information by investigating it in accordance with the principles contained in this Privacy Policy. Appropriate corrective and preventive action will be implemented and follow-up on such action will be conducted to verify that the expressed concern or complaint has been resolved.

All communications, queries, requests to exercise informational rights, including those rights under GDPR, (e.g. access to data) or complaints should be addressed:
  • In email to inquiries@JMACP.com
  • By fax to (877) 848-7967, Attn: Privacy Officer
  • By regular mail to JMAC Partners, Inc., Attn: Privacy Officer, 4501 Cartwright Road, Suite 606, Missouri City, TX 77459

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority, or EU Data Protection Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Transfer of Data to the United States

JMAC Partners services are global and your personal information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country of residence. JMAC Partners will take all reasonable and necessary measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Privacy Policy (see below section EU-U.S. and Swiss-U.S. Privacy Shield Frameworks for further information). In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. To the extent that we process personal information of individuals located in the European Economic Area or the United Kingdom, we are bound by and act in compliance with the GDPR.

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

JMAC Partners participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (including Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. JMAC Partners has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. 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: https://www.Privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, JMAC Partners is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to inquiries@JMACP.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice 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 inquiries@JMACP.com.

In certain situations, JMAC Partners may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

JMAC Partners is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. JMAC Partners complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

JMAC Partners has put in place measures to ensure that adequate protection is provided to the data where legally mandated.

In compliance with the Privacy Shield Principles, JMAC Partners commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact JMAC Partners:
  • In email to inquiries@JMACP.com
  • By fax to (877) 848-7967, Attn: Privacy Officer
  • By regular mail to JMAC Partners, Inc., Attn: Privacy Officer, 4501 Cartwright Road, Suite 606, Missouri City, TX 77459

JMAC Partners has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The following subsidiaries are included in JMAC Partners Privacy Shield Certification:
  • PilotPay

Changes to the Policy

We regularly review our Privacy 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 and as required by law. We will post the date of the most recent revisions on this page. Please check back here from time to time to make sure that you are current and up-to-date on our Policy. Please keep in mind that your use of our website means that you accept our Privacy and Security Policy. If we make a material change to this Policy, we will notify you here, by email, or by means of a notice on our home page prior to the changes taking effect. By continuing to use our services, you agree to our current Privacy Policy.