The VALUE Trial Privacy Policy

Last update and effective starting on [2026-07-27]

Overview

Alira Health SAS (“Alira Health”, “we”, or “our”) has partnered with Image Bloom (hereafter “Image Bloom”) together the “Vendors” a company with an office at 21750 Hardy Oak Blvd., Ste 104, San Antonio, TX 78258, United States for the delivering of innovative marketing and patient recruitment solutions by providing a platform able to maximize patient recruitment.

This Privacy Policy describes the processing of Personal Data collected through the Patient Landing Page (thevaluetrial.com) (hereinafter “the Website”), aiming to facilitate patient recruitment for specific clinical trials sponsored by MediWound (“Sponsor”). We want to explain how we keep your personal information safe, and when, with whom, and why we might share it.

Sources of Personal Data

“Personal Data” is any information relating to an identified or identifiable natural person.

We may collect Personal Data about you from the following sources:

Directly from you. We may collect Personal Data you provide to us directly, such as when you complete an online form through the Website, speak with us over the phone, or send your information via email. This may include information provided on your behalf by a family member, caregiver, or other person you authorize.
Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies when you interact with our Website. This may include information about how you use and interact with our Website, information about your device, and internet usage information.
Third parties. We may also receive information about you from advertising and social media platforms (such as Google Ads) used to reach potential participants, and if you have previously registered interest in clinical trial opportunities through Image Bloom or Alira Health for a different study, from a recruitment base where your existing profile may be matched with the specific eligibility criteria.

We may combine and use information and make inferences from information that we receive from the various sources described in this Privacy Notice. We may also use or disclose the combined information and inferences for the purposes identified below.

Types of Personal Data We Collect

We may collect the following types of Personal Data:

Identifiers. Such as name, phone number, email address, zip code, or other similar identifiers (e.g., cookie IDs and IP address).
Protected class and demographic information. Such as race, ethnicity, age, gender, medical condition.
Internet or other electronic network activity information. Such as browsing history, search history, information on a consumer’s interaction with the Website. For more information about cookies and other device data, please see the cookie notice.
Non-precise geolocation data. Such as approximate location based on your IP address.
Sensitive Personal Data. We may collect:
1. Account log-in, or credentials allowing access to an account.
1. Precise geolocation.
1. Racial or ethnic origin.
1. Information about your health.
1. Photographs or images of your wound or medical condition, if you provide them as part of the eligibility assessment.

How We Use Personal Data

We may use Personal Data for the following purposes:

For potential participant – Trial matching. To assist potential participants in finding current or future opportunities to participate in clinical trials and/or to help find our Clients participants for clinical trials, which may include qualification, pre-screening, enrollment, and communication between sites or other parties involved trial activities on behalf of clinical trial sponsor regarding your eligibility and/or enrollment.
Safety and adverse event reporting. If, during our contact with you, you report a health concern or adverse event, we may be required to share that information with the Sponsor’s drug safety team for regulatory reporting purposes, consistent with applicable pharmacovigilance obligations.
Aggregate recruitment reporting. We may use and share Personal Data in an aggregated, de-identified form to report on recruitment performance to the Sponsor and to clinical trial sites (for example, the number of potential participants identified per site), without identifying you individually.
Website and campaign performance. We may use information collected automatically (see Section 1.B above) to analyze and improve the Website and our recruitment campaigns, and to measure the effectiveness of our advertising.
Legal compliance and safety. We may use Personal Data as necessary to comply with applicable law, respond to legal process, and protect the rights, safety, and security of participants, our clients, and others.

How We Disclose Personal Data

We may disclose to third parties, including the categories of recipient described below:

only in an aggregated anonymized form with the Sponsor or /and the Vendors who manage the clinical trial (Clinical Research Organization) or the purpose of monitoring recruitment leads for site and overall recruitment metrics.
Service providers. Such as those who work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers
Professional consultants. Such as accountants, lawyers, financial advisors, and audit firms.
Law enforcement, government agencies, and other recipients for legal, security of safety purposes. Such as when we share information to comply with legal requirements to enforce or apply Terms of Use or other agreements or policies, a subpoena, court order, or other valid legal process, or in connection with a merger, acquisition, or sale of company assets.
Clinical trial sites. Unlike the aggregate disclosure described in Item A above, we disclose your identifiable information (such as contact details and eligibility responses) to the specific clinical trial site handling your candidacy, so that site staff can contact you directly about participating.
Advertising and analytics platforms. We may share limited identifiers (such as hashed email address) with advertising platforms (e.g. Google) to measure and improve the performance of our recruitment campaigns.
Affiliates. We may share Personal Data with our corporate affiliates, who will be subject to this Privacy Notice.

Depending on the activity, the parties named in this Notice may act in different capacities. The “Controller” or “Business” is the party that decides why and how personal information is processed and is primarily responsible for that processing. The “Processor” or “Service Provider” is the party that processes personal information only on behalf of, and under the instructions of the Sponsor, without deciding its own purposes for that processing. The table below shows which role applies to each processing activity described in this Notice.

Party	Role	Processing Activity
Vendors	Processor/Service Provider	Handling requests and complaints about the Website’s functioning
Vendors	Processor/Service Provider	Use of cookies for the Website’s functioning and management
Vendors	Processor/Service Provider	Statistical analysis to generate anonymous, aggregated results for monitoring clinical trial recruitment efficiency
Vendors	Processor/Service Provider	Collecting and processing personal data submitted through the eligibility form
Vendors	Processor/Service Provider	Concierge phone screening to verify eligibility
Vendors	Processor/Service Provider	Disclosing your identifiable contact/eligibility details to the relevant clinical trial site
Vendors	Processor/Service Provider	Forwarding any reported health concern/adverse event to the Sponsor’s drug safety team
Vendors	Processor/Service Provider	Matching/retargeting your profile against other trials
Sponsor	Controller/Business	Patient eligibility assessment via questionnaire
Sponsor	Controller/Business	Clinical trial enrollment assessment

Sponsor	Controller/Business	Receiving aggregated/anonymized recruitment reporting
Sponsor	Controller/Business	Pharmacovigilance review and regulatory safety reporting

Protection of your Personal Information

The Vendors, the Sponsor, and any organization acting on their behalf treat your personal information confidentially and maintain an adequate and appropriate level of protection for it. Your personal information is held behind secured networks and is accessible only to a limited number of individuals who have specific access rights and are required to keep it confidential.

Retention Period

Depending on the purpose for which we process it, we may need to retain your personal information for a period of time. We will not retain it for longer than necessary to fulfill the purposes for which it was collected, however we might retain personal information to meet any applicable legal requirements.

Data sharing

We do not sell or trade your personal data to outside parties. However, our use of advertising and analytics cookies (including Meta Ads-based tools used to reach potential participants) may constitute a “sale” or “share” of personal information under some U.S. state privacy laws. You can opt out of this use at any time through our cookie settings, or by enabling a recognized opt-out preference signal (such as Global Privacy Control) in your browser, which we will honor.

Your Rights in the United States

Depending on your state of residency, you may have additional rights under U.S. state privacy laws. These rights are provided by states with a comprehensive privacy framework, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia and any other that might enact comprehensive privacy legislation.

You may contact us if you wish to exercise the following rights:

Right to know. You may request access to the personal information we have collected about you and how it is used and shared, free of charge. We will respond within 45 days and, if requested, provide a copy of the personal information we hold about you. This includes:
1. the categories of personal information collected;
1. the categories of sensitive personal information collected;

the categories of sources from which personal information or sensitive personal information is collected;
1. the business purpose for collecting, sharing, or selling it;
1. the categories of third parties to whom personal information or sensitive personal information is disclosed;
1. the specific pieces of personal information collected; and
1. the length of time we intend to retain each category of personal information and sensitive personal information.
Right to deletion. You can request deletion of your personal information, subject to certain conditions, by contacting our Privacy Officer.
Right to portability. You can request that your personal information be provided to you in a common, portable file format.
Right to opt out of sale or sharing. We do not sell your personal information for money. However, certain advertising-related data uses — such as cross-context behavioral advertising through Google Ads — may be considered a “share” under some state laws. You can opt out of this sharing, and of targeted advertising generally, using the methods described in this Notice.
Right to opt out of profiling and targeted advertising. You can direct us not to process your personal information for profiling or targeted advertising purposes.
Right to consent to sensitive data processing. We will only process your sensitive personal information with your consent.
Right against automated decision-making. We will not make decisions about you based solely on automated processing, without human involvement.
Right to non-discrimination. We will not deny you any goods or services, charge you different prices or rates, or provide a different level or quality of goods or services because you exercised any of your privacy rights.

California additional rights

If you are a California resident, we comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and the California Online Privacy Protection Act of 2003 (“CalOPPA”). In addition to the rights described above

including the right to know, the right to opt out of sale or sharing, and the right to non-discrimination, described above — California law provides the following:

“Shine the Light” and “Eraser” laws. You may request a list of all third parties to which we have disclosed your personal information for those third parties’ own direct marketing purposes in the preceding calendar year.
1. Right to correct. You may request that we correct inaccurate personal information we maintain about you.
1. Right to limit use of sensitive personal information. Unlike the states described above, California does not require your opt-in consent before we process your sensitive personal information. Instead, you may direct us to limit our use of your sensitive personal information to what is necessary to perform the services you requested.

Right to opt out of sale or sharing. You may use the methods described earlier in this Notice, or a “Do Not Sell or Share My Personal Information” link where provided, to opt out of the sale or sharing of your personal information.

Do Not Track (“DNT”) requests

Some web browsers offer a “do-not-track” signal indicating that a visitor doesn’t want their online activity tracked. As of October 2023, not all browsers support DNT, and DNT signals are not yet standardized. For this reason, Alira, like many other digital service operators, does not currently respond to DNT signals. If you don’t want to be tracked, please use the refuse button on our Cookies Banner, or set your preference in the cookie settings. For more information on DNT signals, visit allaboutdnt.com.

Global Privacy Control (“GPC”)

Unlike DNT, GPC is a recognized opt-out preference signal under the CCPA/CPRA and several other state privacy laws. Where legally required, we honor a GPC signal sent by your browser as a valid request to opt-out of the sale/sharing of your personal information and of targeted advertising for that browser or device.

Consumer Health Data

Because this Website is used to reach potential participants based on their health condition, some of the personal information described in this Notice may be considered “Consumer Health Data” under state laws that regulate this category specifically — including Washington’s My Health My Data Act, Nevada’s consumer health data law, Connecticut’s Data Privacy Act, Virginia’s Consumer Protection Act, California’s consumer health data protections, and any other state that enacts a similar law. This section supplements, and does not replace, the rest of this Notice.

What we collect: information about your medical condition and health history provided through the eligibility questionnaire or Concierge screening, including any photographs of your wound or medical condition you provide (see “Types of Personal Data We Collect” above).
Consent: we obtain your consent before collecting Consumer Health Data, and separately before sharing it, except where the sharing is necessary to provide a product or service you have requested.
No sale without authorization: we do not sell Consumer Health Data without your valid, signed authorization.
No geofencing: we do not use geofencing technology around healthcare facilities to identify, track, collect data from, or send messages to consumers regarding their Consumer Health Data.
Your rights: you may confirm whether we hold Consumer Health Data about you, access it, withdraw your consent to its collection or sharing, and request its deletion, by contacting us using the details in the “Contacts” section below.

If you are not satisfied with our response, you may file a complaint with your state Attorney General using the contact details in the “Authorities and Complaints” section below (for example, Washington residents may contact the Washington State Attorney General at www.atg.wa.gov/file-complaint).

General Warning

By accessing the Website, you fully and unconditionally accept this Privacy Notice (the “Notice”), along with the Website’s general Terms of Use and Cookies Notice.

You acknowledge that you have read the information in this Notice and authorize Image Bloom and the Sponsor to process, in accordance with this Notice, the personal data you provide through the Website.

This Notice applies only to pages hosted on the Website. It does not apply to third-party pages the Website may link to, whose privacy practices may differ. The Vendors is not responsible for any information processed on, or by, those third-party websites.

Authorities and Complaints

You also have the right to lodge a complaint if you believe your personal information has not been processed in accordance with the privacy laws applicable in your state.

United States

A. California:

California Privacy Protection Agency: info@cppa.ca.gov Attorney General website: https://oag.ca.gov/contact

B. Colorado:

Attorney General website: https://complaints.coag.gov/s/contact-us

C. Connecticut:

Attorney General website: https://portal.ct.gov/AG/Contact-the-Attorney-Generals-Office/Contact-the-Attorney-Generals-Office

D. Kentucky:

Attorney General website: https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Pages/Consumer-Complaints.aspx

E. Maryland:

Attorney General website: https://www.marylandattorneygeneral.gov/Pages/CPD/complaint.aspx

F. Minnesota:

Attorney General website: https://www.ag.state.mn.us/Office/Complaint.asp

G. Nebraska:

Attorney General website: https://ago.nebraska.gov/consumer-protection

H. New Hampshire:

Attorney General website: https://www.doj.nh.gov/consumer/complaints

I. New Jersey:

Attorney General website: https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx

J. Oregon:

Attorney General website: https://www.doj.state.or.us/consumer-protection/contact-us/

K. Rhode Island:

Attorney General website: https://riag.ri.gov/consumer-protection/file-complaint

L. Texas:

Attorney General website: https://www.texasattorneygeneral.gov/contact-us

M. Utah:

Attorney General website: https://www.attorneygeneral.utah.gov/contact/complaint-form/

N. Virginia:

Attorney General website: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

Changes to this Privacy Notice

This Notice is effective as of the date stated at the top of this page. We may change this Notice from time to time. Please refer to this Notice on a regular basis.

Contacts

Although the Sponsor acts as the business responsible for the personal data collected through the eligibility form, the Sponsor does not have access to your name or contact details at this stage. For questions or requests specifically about the Sponsor’s own processing activities (for example, once you are enrolled in the trial), please refer to the Sponsor’s own privacy notice.

You may contact Alira Health / Image Bloom, who will, if required, contact their Privacy Contact, using the details below:

Alira Health Boston

1 Grant St 4th Floor Suite 400, Framingham, MA 01702, United States Alirahealth.dpo@mydata-trust.info