Privacy Policy

Effective Date: November 7, 2025

3rt Labs LLC (based in Massachusetts, USA) is committed to protecting your privacy. This Privacy Policy explains how our Trialsights application ("App") collects, uses, and safeguards information on both the participant side and the staff side.

We follow industry best practices and applicable privacy laws to ensure your data is handled responsibly and transparently. If you have any questions or concerns about this policy, please contact us at [email protected].

Information We Collect

We design Trialsights with data minimization in mind – meaning we only collect what is necessary for the app's functionality and nothing more. Notably, the participant side of our App does not require you to provide any personally identifying information such as name, email, address, or phone number.

No Personal Identifiers

We do not ask participants for names, contact details, or any direct personal identifiers. Your use of the participant-side App remains anonymous by design. Each participant may be identified only by a participant ID or code (if provided by a clinical trial sponsor), which we cannot link to your real identity.

Medication Photos

When you use the App to take a picture of your pills, that image is collected to document medication adherence. Before any image leaves your device, our App uses on-device AI processing to detect and remove or blur any personally identifiable information (PII) – such as faces, ID cards, prescription labels, or documents that might appear in the photo. Only the de-identified medication photo is then securely uploaded to our servers.

Medication Log Entries

We collect the data you enter about your medication schedule and adherence, including the time and date you took your medication, or indications if you missed a dose. These entries help the trial staff monitor compliance and are stored without any direct personal identifiers attached.

Technical & Diagnostic Data

To ensure the App works reliably, we collect limited technical information automatically, including device information (such as device type, operating system version), usage logs, and error reports. We only use this information to diagnose issues and improve the app's performance. We do not use it to identify you.

Staff User Information

If you are a staff user (such as a researcher or trial coordinator), we may collect personal information for your account login and usage, including your name, work email, and credentials. This staff data is used strictly for authentication, authorization, and communication related to the trial.

How We Use Your Information

We use the collected information to provide and improve the Trialsights service in support of clinical trials:

  • ✓ Medication Adherence Monitoring: Participant medication photos and log entries are used to confirm whether medications are taken as scheduled and made available to authorized staff.
  • ✓ Maintaining Participant Anonymity: We design our processes so that your identity remains unknown to us. The participant-side data is indexed by codes or IDs rather than personal details.
  • ✓ App Functionality: We may use your medication schedule data to enable in-app features like dose history or reminders. All such features use your data solely to assist you in the trial.
  • ✓ Improving the App: Technical diagnostic data is used by our development team to fix bugs, enhance security, and refine user experience.
  • ✓ Legal Compliance: We may use and retain certain data as necessary to comply with legal requirements or regulatory obligations tied to clinical trials.

Important: We do not use participant or staff data for advertising, profiling, or selling of services. We do not send marketing emails or unrelated communications.

How We Share and Disclose Data

Your privacy is paramount. We do not sell or rent your personal data to anyone, and we avoid disclosing your information except as described below. We do not use third-party analytics or advertising services that track you.

Clinical Trial Sponsor and Investigators

Your de-identified adherence data (photos and logs) will be shared with the sponsor of the trial and the authorized study staff. They will see your data only in the context of the trial and associated with your participant ID (not your name).

Service Providers (Limited Use)

We operate our own secure servers and infrastructure. If we use trusted third-party service providers, they act under our instructions and do not get to use your information for their own purposes.

Legal Requirements

We may disclose information if compelled by law or if a valid legal request is issued. We will only provide the minimum data necessary to comply with the law.

Business Transfers

If 3rt Labs LLC is involved in a merger, acquisition, or sale of assets, user information may be transferred to the successor entity. We will ensure the new owner continues to honor our privacy commitments.

Data Security

We take extensive measures to protect your data and maintain its confidentiality, integrity, and availability. Given the sensitive nature of health-related data, we treat security as a top priority.

Encryption

All data transmitted between your device and our servers is encrypted using industry-standard protocols (HTTPS/TLS). Data at rest is also encrypted.

Access Controls

We strictly limit who can access the data you provide. Only authorized personnel have access on a need-to-know basis.

Physical Safeguards

Our servers are hosted in secure data centers with robust physical security, firewalls, intrusion detection, and continuous monitoring.

Privacy by Design

Features like local AI processing of images to strip out PII minimize the exposure of personal data to our servers.

While we employ commercially reasonable and state-of-the-art security measures, no system can be 100% secure. We actively maintain and update our security practices to adapt to new threats.

Data Storage and Retention

Your data is stored on secure servers operated by 3rt Labs (or its infrastructure providers) in the United States. We retain data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by applicable laws.

  • • Medication photos and logs are generally kept for the duration of the trial and as required by regulatory requirements.
  • • Technical diagnostic data is retained only long enough to analyze and fix issues.
  • • Staff account information is retained as long as your account is active.
  • • Aggregated or anonymized data may be retained indefinitely for statistical purposes.

International Users and Data Transfers

If you are accessing the App from outside the United States, please be aware that your data will be transferred to and stored on servers located in the U.S. The data protection laws in the U.S. might differ from those in your home country.

We implement standard contractual data protection clauses or rely on other lawful transfer mechanisms as required by the GDPR and other international laws. By using the Trialsights App, you consent to this transfer of your data to the United States.

Your Rights and Choices

Depending on your jurisdiction and applicable laws, you may have some or all of the following privacy rights:

Access & Correction

Request a copy of your data and corrections of any inaccuracies.

Deletion

Request that we delete personal data we hold about you.

Objection or Restriction

Object to or restrict processing of your data.

Data Portability

Request a copy of your data in a machine-readable format.

California Residents: We do not sell your personal information and operate in accordance with the California Consumer Privacy Act (CCPA).

To exercise any of your rights, please contact us at [email protected].

Children's Privacy

Trialsights is generally intended for use by adult participants. We do not knowingly collect personal information from anyone under the age of 13 without parental consent. If the App is used in a pediatric clinical trial, such use would only occur with explicit parental or guardian consent. If you believe your child is using Trialsights outside of a proper consented trial context, please contact us immediately.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will update the Effective Date at the top of the policy.

Your continued use of the Trialsights App after any changes will signify your acceptance of the updated terms. If you do not agree with any updates, you should discontinue use of the App.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us.

3rt Labs LLC (Trialsights Privacy Team)

[email protected]