GoodLab Privacy Policy

Effective [5TH Jan 2026]

Scope of This Policy

ITS Limited (“GoodLab,” “we,” “us,” “our”) respects your privacy and values your trust. The purpose of this Privacy Policy is to inform you of the treatment and handling of personal information that we may learn about you from using our websites at goodlabgroup.com (the “Sites”), from using our mobile application (the “App”), from engaging with our content, or by use of any of our services (collectively, the “Service”). If you have any questions regarding this information or our privacy practices, please contact us via the methods set out in the How to Contact Us section at the end of this Privacy Policy.

Agreement to Terms

By using or accessing our Service in any manner, you acknowledge that you accept the practices and policies outlined below and the policies outlined in our Terms of Use, and you hereby consent that we may collect, use, and disclose your personal information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and our Terms of Use, then you should immediately discontinue use of the Service without providing us with any personal information.

Information We Collect

We may collect the following categories of personal information (a) directly from you (such as when you interact with the Service or fill out our registration forms), (b) from the device and browser that you use to access the Service, and (c) from cookies and similar technologies.

Identifiers

We may collect your first name, last name, mailing address, zip code, and email address.

User-generated Content

We collect the information and content of communications that you share through the Service. This may include the information you choose to provide when you fill out a registration form or contact us.

Demographics and Characteristics

We may collect your date of birth, gender or gender identity, and any information you provide in a registration form concerning your health information. This information is used to provide the Service and identify clinical studies for which you may be eligible.

Device Information

We may collect device information when you interact with the Service. Device information may include your device type, browser type, online and/or unique identifiers, IP address, and geolocation information.

Internet Activity

We may collect information concerning your interaction with the Service, including when you access the Sites or App and your browsing activity on the Sites or App (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by the Sites’ host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Service.

Participation in Studies sponsored by GoodLab’s Clients

In some instances, GoodLab acts as a Patient Recruitment Organization that provides services to support clinical trials and medical research studies. GoodLab may process your personal information as a service provider to our clinical research partners and in accordance with contracts with and instructions from these partners. GoodLab may also, to the extent necessary, process personal data relating to study participants’ spouses, partners, care givers, and relatives if they are involved in the participants’ participation in a study (e.g., parents or legal guardians involved in decision making on behalf of child participants or spouses involved in the care of an incapacitated participant). In relation to GoodLab’s delivery of Patient Recruitment services to partners, the partner is in control of how and why your personal data is processed.

Health Data

GoodLab is not a covered entity under the Health Insurance Portability and Accountability Act of 1966 (“HIPAA”) and does not provide medical treatment or healthcare services. Any health-related information submitted by you or collected through your use of the Service is voluntarily provided and not protected under HIPAA. GoodLab does not verify the privacy practices, security measures, or HIPAA compliance of any sponsor or other third-party organization conducting clinical trials (each a “Third-Party Provider”) listed on its Service.

To the extent GoodLab collects protected health information on behalf of a Patient Recruitment Organization that is a HIPAA covered entity, GoodLab will enter into appropriate business associate agreements with such covered entity, and any data shared in that context will be managed in accordance with the terms of the business associate agreement and applicable HIPAA requirements.

You are not required to provide all personal information identified in this Privacy Policy to use our Service or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able respond to your requests or pair you with clinical trials.

Cookies

We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on the Sites are generally divided into the following categories:

Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Service. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including personal information) may be provided to us by you or derived from the usage patterns of particular users on the Service and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Service. To accomplish this, we or our service providers and advertising partners may deliver cookies, including a file (known as a “web beacon” or “pixel”) from an ad network to you through the Service. Web beacons and pixels allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. They also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons and pixels allow ad networks to view, edit or set their own cookies on your browser, just as if you had requested a web page from their site.

You may opt-out or change your preferences for each of these services as detailed below:

You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Sites, however, you might not be able to access or use important functions or features of our Sites.

Do-Not-Track Signals

We follow the Global Privacy Control to honor Do Not Track (“DNT”) browser settings.

Children’s Privacy

The Service is not intended for users under the age of 13 and GoodLab does not knowingly collect personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Service without permission, please notify us immediately by contacting us as detailed in the How to Contact Us section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.

Our Use of Personal Information

We collect and use your personal information for the following purposes:

Our Disclosure of Personal Information

We may share your personal information with the following third parties:

Your Privacy Choices

If you no longer want to receive our emails, or other marketing communications, you may unsubscribe at any time by following the unsubscribe options in the communication itself or by emailing us at the contact information below under How to Contact Us.

To opt-out of text messages, you may text “STOP” in reply to any GoodLab marketing text message.

Please note that you cannot unsubscribe from certain correspondence from us, including informational messages relating directly to your use of the Service.

Security

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

Additional Disclosures Required by State Privacy Laws

This section applies only to residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

For residents of these states, this section describes how we collect, use, and disclose, and/or “sell” (as defined under certain state privacy laws) the personal information of state residents, and the rights you may have under your state’s privacy law. These disclosures are intended to supplement this Privacy Policy with information required by state law.

To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section Information We Collect above.

We collect this personal information, as further described in the Our Use of Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.

We may disclose personal information to the categories of third parties listed above in the section Our Disclosure of Personal Information. Below, we have provided more detail regarding the two ways we share your personal information: (a) general disclosures of information for a business or commercial purpose, and (b) sales of personal information.

Disclosure of Information for a Business or Commercial Purpose:

To manage our business and provide services to you, we sometimes disclose personal information to third parties. These third parties cannot further collect, sell, or use the personal information we share with them except as necessary to perform our business or commercial purposes, as instructed by us.

In the past 12 months, we may have disclosed the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

CategoryRecipients / Third Parties
IdentifiersService providers; Advertising partners; Business reorganization; Mandatory disclosures and legal rights
User-generated ContentService providers; Business reorganization; Mandatory disclosures and legal rights
Device InformationService providers; Advertising partners; Business reorganization; Mandatory disclosures and legal rights
Internet ActivityService providers; Advertising partners; Business reorganization; Mandatory disclosures and legal rights

Sales of Personal Information:

With your consent, which you may revoke at any time, we may sell your personal information to certain trusted third-party data analytics and data licensing partners in exchange for monetary consideration.

Additionally, the laws of certain states, includingWe have marked “sales” in quotation marks because the laws of California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, and Texas define “sale” broadly to include any disclosure of information in return for any type of value. The value does not need to be monetary, like in a traditional sale. GoodLab uses cookies and similar technologies to analyze website usage and assist in marketing efforts (including targeted advertising) and we may share personal information derived from these cookies with advertising partners to market to you and to provide advertisements on other websites that we or these entities believe will be of interest to you. In some cases, the disclosures of the information collected by these cookies may be considered a sale under applicable law.

In the past 12 months, we may have sold the following categories of personal information to the following third parties:

CategoryRecipients / Third Parties
IdentifiersData Analytics and Data Licensing Partners
Demographics and CharacteristicsData Analytics and Data Licensing Partners
Health DataData Analytics and Data Licensing Partners
Device InformationAdvertising Networks
Internet ActivityAdvertising Networks

We do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

Your Rights:

Under certain state privacy laws, you have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. We have provided this notice through this Privacy Policy.

In addition, residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have the following rights, subject to certain limitations:

Additional Rights for California Residents:

In addition to the rights listed above, California residents also have the following rights:

Additional Rights for Residents of Iowa and Utah:

In addition to the rights listed above, residents of Iowa and Utah also have the following right:

Additional Rights for Maryland Residents:

In addition to the rights listed above, Maryland residents also have the following right:

Additional Rights for Rhode Island Residents:

In addition to the rights listed above, Rhode Island residents also have the following right:

Rights for Nevada Residents:

Nevada residents have the following right:

Exercising Your Rights:

You or your authorized agent may exercise your rights to access, correct, transfer, or delete your personal information by emailing us at webmaster@goodlabgroup.com, with the subject line “U.S. Privacy Rights” so that we may direct your email to the right team. Once we receive a request, we will take steps to verify your request, including by asking you to provide information that is reasonable in light of the nature of your request. We will respond to your request consistent with applicable law.

You can exercise your right to opt-out of “sales” or the “sharing” or your personal information for purposes of targeted advertising by clicking the “Opt-out Preferences” link at the bottom of the Sites. We also recognize the Global Privacy Control (“GPC”) as a valid consumer request to opt out of marketing cookies for the browser that you use to access the Sites.

Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you (e.g., name, email, address), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you, we may not be able to respond to your request.

To use an authorized agent to make a request on your behalf, we may need the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request on your behalf. We may also require you to verify your identity directly with us.

Appealing a Denial of Your Privacy Rights Request:

If you are a resident of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia and we refuse to take action on your privacy rights request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must: (a) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request; and (b) provide a description of the basis of your appeal. Please note that your appeal will be subject to the rights and obligations afforded to you under applicable law. We will respond to your appeal in accordance with applicable law.

You may appeal our decision using the following methods:

Data Retention

We retain personal information about you for as long as necessary to provide you with the Service or to perform our business or commercial purposes for collecting your personal information. When establishing a retention period for specific categories of information, we consider the source of the collected personal information, our need for personal information, why we collected the personal information, and the sensitivity of the personal information. In some cases, we retain personal information for a longer period, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Effective Date and Changes to This Privacy Policy

This Privacy Policy is effective as of the date at the top of this policy. GoodLab has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Policy, we will provide a message through our website or via email informing you of the change.

How to Contact Us

If you have any questions about this Privacy Policy or our Service, please contact us at:

Email:

webmaster@goodlabgroup.com

Address:

ITS Limited

P.O. Box 348

Road Town, Tortola

British Virgin Islands