Participant Privacy Policy Copy

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ThinkGen General Participant Privacy Notice

Last Updated: 24 September 2026

Gen., LLC (d/b/a ThinkGen) is a healthcare marketing research agency that bridges clinical and behavioral sciences to develop advances that result in distinct, actionable insights to our clients.

All references in this Privacy Notice to ThinkGen include ThinkGen and its parent, subsidiary and affiliated companies. All references to “us” or “we” refer to ThinkGen.

This Participant Privacy Notice (“Privacy Notice”) describes the types of information we collect, how we collect and use the information (including Personal Data as defined herein), how we share or disclose the information, how we store the information, and your choices regarding the use and processing of the information.

We protect your privacy

ThinkGen is committed to protecting the privacy and security of all personal data (“Personal Data”) that we have collected or received. We define Personal Data as any identifiable data relating to a natural person that is directly or indirectly collected, by us or a third party.

ThinkGen strives to conform its privacy practices to applicable laws, codes, and regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation: ESOMAR (www.esomar.org), the Insights Association (www.insightsassociation.org), Intellus Worldwide (www.intellus.org), BHBIA (www.bhbia.org.uk) and EPHMRA (www.ephmra.org).

Why We Collect and Process Personal Data

Depending on the research activity and your relationship with us or our authorized service providers, the personal data we and our authorized service providers may collect may include:

identification and contact information, such as your name, email address, telephone number, mailing address or participant identifier to invite you to surveys or other research programs or to respond to any requests that you may send to us;
demographic and profiling information, such as age, gender, geographic location, household characteristics and other information used to determine eligibility for market research;
professional information, such as occupation, employer type, professional qualifications, specialty or practice information where relevant to the market research being performed;
survey, interview, focus-group and other research responses, including opinions, preferences and experiences;
health-related or other sensitive information where relevant to healthcare research;
information required to administer incentives or payments;
research participation history and information used to validate eligibility or prevent duplicate or fraudulent participation and violation of applicable terms; and
technical and device information, including IP address, browser type, operating system, device identifiers, cookie identifiers, log information and other information collected through technologies described below.

We will also collect and process Personal Data:

to respond to duly authorized information requests of governmental authorities or where required by law;
in connection with the sale, assignment, or other transfer of our business, in which case ThinkGen will make commercially reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Notice; or
as otherwise authorized by you.

In addition to the above, ThinkGen may use the information it collects or receives as set forth in this Privacy Notice.

Please note that receiving email communications from us and/or our authorized service providers may be a requirement of your participation in our surveys or other market research programs. You can opt out from receiving these emails by directly unsubscribing from surveys or other market research programs conducted by our authorized service providers on behalf of us or our clients, or by contacting us using the contact information in the Contact Us section below.

ThinkGen processes Personal Data only where we have an appropriate legal basis under applicable law. The legal basis that applies depends on the purpose of the processing and the jurisdiction in which you reside.

Where the EU General Data Protection Regulation ("GDPR") or UK GDPR applies, we may rely on one or more of the following legal bases:

your consent (Article 6(1)(a));
processing necessary to perform a contract with you or to take steps at your request before entering into a contract (Article 6(1)(b));
processing necessary to comply with a legal obligation applicable to ThinkGen (Article 6(1)(c)); and
processing necessary for our legitimate interests or those of a third party (Article 6(1)(f)), including preventing fraud, maintaining the integrity of market research, protecting our systems, and administering our research activities, provided those interests are not overridden by your interests or fundamental rights and freedoms.

Where we rely on consent, you may withdraw your consent at any time.

Sensitive Personal Data and Health Information

Because ThinkGen conducts healthcare-related market research, some research activities may ask you to provide information concerning your health, medical conditions, diagnoses, treatments, disabilities or healthcare experiences. Depending on the market research and applicable law, we may also collect other information considered sensitive or "special category" Personal Data, such as information concerning racial or ethnic origin, religious beliefs, sexual orientation or other legally protected characteristics.

We will inform you when a research activity seeks to collect sensitive Personal Data and, where required by applicable law, obtain your explicit consent or otherwise identify an applicable legal basis before processing that information. Unless we tell you otherwise, you may decline to answer individual research questions requesting sensitive Personal Data, although doing so may affect your eligibility for, or ability to complete, a particular research activity.

Where the GDPR or UK GDPR applies and we process special categories of Personal Data, including data concerning health, we will rely on an applicable condition under Article 9(2), such as your explicit consent under Article 9(2)(a), or another condition where permitted by applicable law.

How We Collect and Use Your Personal Data

We generally collect your Personal Data on a voluntary basis (please see the section titled “Why We Collect Personal Data” above).

Personal Data provided by you:

We collect information (including Personal Data) submitted or provided by you through or in connection with:

surveys and other market research programs;
our websites; and
telephone calls, emails and/or other forms of communication or media.

In addition to information we collect directly from you, we may obtain Personal Data from third parties. Depending on the particular research activity, these sources may include:

our clients;
market-research panels and participant recruitment providers;
research fieldwork and other authorized service providers;
professional or healthcare-professional databases;
referral or recruitment sources;
publicly available or professional sources; and
information generated from your previous interactions or participation in ThinkGen’s research activities.

The types of information obtained from these sources may include contact details, demographic or professional information, research eligibility criteria, participant identifiers, previous research participation information and other information needed to recruit participants, determine research eligibility, administer studies or protect research integrity.

Where required by applicable law, we will provide additional information regarding the source of Personal Data that we did not obtain directly from you.

Information collected via automated methods:

Cookies
Our websites or the websites of our authorized service providers may use “cookies.” Cookies are small text files that a website transfers to your computer’s hard drive. We may use cookies to measure traffic patterns, personalize content, control security and to help us make our site more useful. Cookies and similar technologies may collect or generate information that constitutes Personal Data under applicable law, including online identifiers, IP addresses, device information and information about how you interact with our websites or research platforms.

We use cookies and similar technologies for purposes such as operating and securing our websites, preventing fraud, remembering preferences, measuring website usage and, where applicable, conducting analytics. Where required by applicable law, we obtain consent before storing or accessing non-essential cookies or similar technologies on your device.

Web Beacons
A web beacon (also known as a tag, clear gif or 1 x pixel) consists of a small string of code that is embedded within a web page or email. They may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

ThinkGen or its authorized service providers may use web beacons in our email messages to help determine whether email or other electronic messages are opened and to verify any clicks through to links within an email or other electronic message to determine if a participant has viewed ads or other online content that ThinkGen is measuring.

Geo-Location Data
ThinkGen or its authorized service providers may collect geo-location information from your computer or device. ThinkGen or its service providers may use your geo-location data for fraud prevention or for market research purposes.

Digital Fingerprinting
ThinkGen and its authorized service providers may use device-identification or digital-fingerprinting technologies for research-integrity, security and fraud-prevention purposes. These technologies may collect information such as your browser type and version, operating system, device characteristics and other technical attributes and use that information to create or associate a unique device identifier.

We may use this identifier to detect duplicate or fraudulent participation, verify compliance with eligibility requirements, protect research quality and prevent misuse of our research programs.

Depending on applicable law, information generated through these technologies may constitute Personal Data even where it does not directly identify you by name.

Log Files
Our websites or the websites of our authorized service providers may automatically gather and store certain information in log files, including, without limitation, data available from your web browser, including, without limitation: IP address, browser type, Internet Service Provider, referring/exiting pages, operating system, date/time stamp and click stream data.

Google Analytics
Our websites or the websites of our authorized service providers may use a tool called “Google Analytics” to collect information about use of our site. Google Analytics collects information such as how often users visit this site, what pages they visited, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site.

Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

For more information about Google Analytics, see:
http://www.google.com/analytics/terms/us.html
http://www.google.com/policies/privacy/

Google reCAPTCHA
Our primary goal is to provide an experience that is as secure and protected as possible. One of the ways we or our authorized service providers do this is to use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA). With reCAPTCHA we or our authorized service providers can confirm if a user is a real person instead of a robot or other automated system. Google reCAPTCHA may request that you complete a puzzle, or it may simply ask you to tick a box to confirm that you are not a robot. With the invisible reCAPTCHA version, you will not even have to tick a box.

The IP address and other Personal Data required by Google for the CAPTCHA service will be sent to Google’s servers. The types of data transferred to and processed by Google include:

IP address;
referrer URL (the address of the website from which you came);
user Google account information (if you are logged into a Google service such as Gmail);
user behavior, including scrolling on a page, moving a mouse, clicking on links, the amount of time spent completing forms and typing patterns;
screen resolution (the number of pixels consisted in the image);
browser history;
CSS information;
browser plug-ins;
JavaScript objects (JavaScript is a programming language that allows for collected data); and
cookies.

Your Personal Data will be transferred to Google’s servers.

How We Share Your Personal Data

ThinkGen may disclose Personal Data to the categories of recipients described below, where permitted by applicable law and as necessary for the purposes described in this Privacy Notice. Where consent is legally required for a particular disclosure, we will obtain that consent before making the disclosure.

If a survey or other market research program or other activity includes making Personal Data available to a third party, ThinkGen will only share your Personal Data with your consent. If data collected is used for statistical modeling to better understand trends and preferences amongst specific groups or audiences within the general population, only limited Personal Data shared will be used only for market research purposes and again only with your consent.

We may share your Personal Data as follows:

with research clients, where necessary for the applicable research project with your consent;
with research panel, recruitment and fieldwork providers;
with survey, interview, hosting and technology-platform providers;
with incentive, payment and fulfillment providers;
with fraud-prevention, identity/device-verification and research-quality providers;
with cloud hosting, analytics, security and other technology service providers;
with professional advisers, auditors and insurers where reasonably necessary;
with governmental, regulatory, judicial or law-enforcement authorities where required or permitted by applicable law;
when ThinkGen believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity;
with a purchaser, successor or other relevant party in connection with an actual or proposed merger, acquisition, financing, reorganization or transfer of all or part of our business; or
as otherwise authorized by you.

If a research activity involves disclosure of information that directly identifies you to a client or another third party, we will inform you before that disclosure and obtain consent where required.

ThinkGen will require others who acquire or provide Personal Data to us, including those engaged to provide support services, to adopt and comply with the principles in this Privacy Notice. ThinkGen acknowledges its potential liability in cases of onward transfers to third parties.

We or our authorized service providers may maintain Personal Data or machine identifiable information (like an IP address) in order to satisfy your requests and/or ThinkGen’s business requirements. Service providers processing Personal Data on our behalf are contractually restricted from using the Personal Data for purposes other than providing the applicable services, except where otherwise permitted or required by law.

How Long We Keep Personal Data

We retain Personal Data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including conducting and administering research, maintaining research integrity, fulfilling incentives, preventing fraud, responding to participant requests, complying with contractual requirements, and satisfying applicable legal, accounting and regulatory obligations.

Retention periods may vary according to the type of information and research activity. In determining the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Data; the purposes for which it is processed; whether those purposes can be achieved through other means; applicable client or research requirements; potential risks to individuals; and applicable legal requirements.

Where practicable, Personal Data will be deleted, anonymized or de-identified when it is no longer required for these purposes. Aggregated or anonymized research information that no longer identifies an individual may be retained for longer periods.

Your Privacy Rights

Depending on where you reside and applicable law, you may have rights concerning your Personal Data. These may include the right to:

request access to Personal Data we hold about you;
request correction of inaccurate or incomplete Personal Data;
request deletion of your Personal Data;
request restriction of certain processing;
object to certain processing, including processing based on legitimate interests;
receive certain Personal Data in a portable format;
withdraw consent where processing is based on your consent; and
submit a complaint to an applicable data-protection or privacy supervisory authority.

These rights are not absolute and may be subject to conditions, limitations or exemptions under applicable law.

Where we process Personal Data based on your consent, withdrawing consent will not affect the lawfulness of processing carried out before withdrawal.

You may submit a privacy-rights request using the contact information in the "Contact Us" section below. We may take reasonable steps to verify your identity before fulfilling a request. Where permitted by applicable law, you may also use an authorized agent to submit a request on your behalf.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

International Transfers of Personal Data

ThinkGen is based in the United States, and Personal Data we collect may be stored or processed in the United States.

Where applicable law requires safeguards for international transfers of Personal Data, ThinkGen uses an appropriate transfer mechanism. For transfers subject to the GDPR or UK GDPR, these safeguards may include an applicable adequacy decision or framework, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another legally recognized transfer mechanism, as applicable.

Where required, we also assess whether additional safeguards are appropriate in light of the circumstances of the transfer. You may contact us using the information below for additional information regarding the safeguards applicable to your Personal Data.

Additional Information for Residents of Certain U.S. States

Residents of certain U.S. states may have additional rights under applicable comprehensive state privacy laws. Depending on the law that applies and ThinkGen’s role in processing your Personal Data, these may include rights to access, correct or delete Personal Data; obtain a portable copy of certain Personal Data; opt out of certain sales, sharing, targeted advertising or profiling activities; limit certain uses or disclosures of sensitive Personal Data; and appeal ThinkGen’s decision concerning a privacy-rights request.

ThinkGen will honor these rights where required by applicable law.

Children

ThinkGen does not knowingly collect Personal Data from children below the age where parental consent is required or as otherwise restricted by applicable law. If we become aware that we have inadvertently collected Personal Data from a child below the age where parental consent is required or as otherwise restricted by applicable law, we will delete such Personal Data as soon as possible.

Security Measures ThinkGen Has Implemented

ThinkGen maintains appropriate technical, administrative and physical safeguards to protect information received or collected. We review, monitor and evaluate our privacy practices and protection systems on a regular basis. Notwithstanding the foregoing, transmissions over the Internet and/or a mobile network are not one hundred percent (100%) secure and we do not guarantee the security of transmissions. ThinkGen is not responsible for any errors by individuals in submitting Personal Data to us.

Links to Other Websites

This website may contain links to other websites. ThinkGen is not responsible for the privacy practices or the content of other websites. To ensure the protection of your privacy, always review the Privacy Notice of the websites you visit by linking from this website.

If you wish to exercise your rights or have any requests, questions or complaints regarding ThinkGen’s privacy practices and/or this Participant Privacy Notice, please contact us by:

Email to: privacy@think-gen.com

Regular mail to:

333 Lancaster Ave #314
Wynnewood, PA 19096
Attn: Privacy Compliance Officer

Acceptance and Updates to this Privacy Notice

This Privacy Notice describes ThinkGen’s processing of Personal Data. Where not addressed in this Privacy Notice, where your consent is required for a particular processing activity, ThinkGen will request that consent separately in an appropriate manner.

We may update this Privacy Notice periodically to reflect changes in our practices, technologies or legal requirements. The "Last Updated" date above indicates when this Privacy Notice was most recently revised. Where required by applicable law, we will provide additional notice of material changes and obtain consent where the change requires consent.

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