Data Protection & Healthcare Advertising Disclaimer

BBK Marketing Solutions LLC (“BBK Marketing,” “BBK,” “we,” “us,” or “our”) provides specialized marketing and participant recruitment services for Clinical Research organizations.

BBK Research Participant Solutions (“BBK RPS”) is a branded participant recruitment platform and service operated by BBK Marketing Solutions LLC.

This notice explains how BBK approaches participant recruitment, health-related information, advertising technologies, preliminary pre-screening, and data protection.

1. Our Role in Clinical Research Recruitment

BBK may support Clinical Research recruitment through services that include:

• recruitment advertising;
• participant registration;
• participant engagement;
• preliminary pre-screening;
• communication and follow-up;
• recruitment workflow management;
• structured referral of potential participants to authorized Research Sites.

BBK does not practice medicine, diagnose medical conditions, provide medical treatment, determine final clinical eligibility, obtain Study informed consent, or enroll or randomize participants into clinical trials.

Final Study-specific screening, medical verification, informed consent, eligibility determination, and enrollment remain the responsibility of the applicable Research Site and research team.

2. Information We May Collect

Depending on the recruitment program, BBK RPS may collect information directly from prospective participants or their authorized parent/legal guardian, including:

• name and contact information;
• age or date-of-birth information when required;
• ZIP code or general recruitment location;
• preferred language and communication preferences;
• self-reported health conditions or diagnosis information;
• responses to approved preliminary pre-screening questions;
• research interests;
• participant permissions and consent records;
• campaign and referral information.

BBK RPS is designed to collect only information reasonably necessary for recruitment, preliminary pre-screening, participant communication, and referral activities.

BBK does not routinely request complete medical records, laboratory reports, diagnostic images, insurance records, Social Security numbers, or other information that is unnecessary for the preliminary recruitment process.

3. Participant-Reported Health Information

Information provided through BBK RPS is generally self-reported by the participant or their authorized representative.

The collection of this information does not constitute medical diagnosis, medical verification, or clinical screening by BBK.

Where verification of diagnosis, treatment history, laboratory values, medical records, or other clinical information is required for a particular Study, that verification is performed by the applicable Research Site unless otherwise expressly established through an approved workflow.

4. Preliminary Pre-Screening

BBK RPS may use Study-specific preliminary questions to help organize participant referrals and determine whether additional follow-up may be appropriate.

Preliminary pre-screening does not establish Study eligibility.

A participant who completes a BBK RPS pre-screening process may still be determined ineligible by the Research Site following final Study-specific screening.

5. Participant Data Access

Participant information is not made available to arbitrary Research Organizations.

Payment for BBK recruitment services does not provide a Research Organization with access to BBK’s general participant network or participant database.

Participant-level information is made available only through an authorized recruitment or referral workflow and only to the Research Organization or Site associated with that referral, subject to the participant’s applicable permissions and the requirements of the recruitment program.

6. Future Research Opportunities

Participants may be offered the option to receive information regarding future Clinical Research opportunities that may be relevant to their profile.

Participation in future-opportunity matching is voluntary.

Where BBK offers this feature, the participant’s preference is recorded separately and may be changed or withdrawn through available account or support channels.

Declining future research communications does not affect a participant’s ability to complete an existing recruitment process.

7. Advertising Platforms and Sensitive Information

BBK may use advertising platforms such as Meta, Google, or similar services to promote approved Clinical Research recruitment campaigns.

BBK seeks to minimize the collection of sensitive health information directly within third-party advertising environments.

Detailed health-related questions and preliminary pre-screening are intended to occur within the controlled BBK RPS participant environment whenever practical.

BBK does not intentionally transmit participant health-profile responses, diagnosis information, or detailed pre-screening answers to advertising platforms for behavioral advertising purposes.

Public advertising and website analytics are operationally separated from authenticated participant health-profile workflows where appropriate.

8. Communications

Subject to the participant’s applicable permissions and preferences, BBK RPS may communicate through:

• email;
• SMS;
• telephone;
• WhatsApp;
• platform notifications;
• other approved communication channels.

Communications may include registration assistance, reminders, preliminary pre-screening support, administrative information, and referral coordination.

Participants may change communication preferences or opt out of applicable communications through the methods provided in the message, platform, or by contacting BBK.

9. Parents, Guardians, and Pediatric Recruitment

BBK RPS does not permit children to independently create participant accounts where a parent or legal guardian is required.

For pediatric research opportunities, the parent or legal guardian manages the account and provides information on behalf of the potential participant.

The Research Site remains responsible for Study-specific parental permission, assent when applicable, informed consent, and clinical eligibility procedures.

10. Data Security

BBK uses reasonable administrative, technical, and organizational safeguards designed to protect participant and client information against unauthorized access, alteration, disclosure, loss, or misuse.

Safeguards may include:

• access controls;
• role-based permissions;
• authentication controls;
• encrypted network communications;
• audit logging;
• restricted participant-data access;
• controlled storage;
• backup and recovery practices;
• security monitoring;
• vendor and access management.

No electronic system can be guaranteed to be completely secure.

11. HIPAA and Other Health Privacy Requirements

Health-related information may be subject to different federal or state privacy requirements depending on how the information is collected, used, disclosed, and the relationship between the parties involved.

BBK does not rely on a blanket representation that all information handled through BBK RPS is, or is not, Protected Health Information under HIPAA.

Where HIPAA or another applicable health-privacy requirement applies to a particular workflow or relationship, BBK will address the applicable requirements through the appropriate operational and contractual framework.

Regardless of the legal classification of a particular data element, BBK treats identifiable participant health information as sensitive information and applies controlled-access and data-protection practices to its handling.

12. Data Retention

BBK retains participant and recruitment information only as reasonably necessary for:

• active recruitment activities;
• participant account functionality;
• authorized future research opportunities;
• referral documentation;
• legal, regulatory, audit, security, or contractual requirements.

Retention periods may vary depending on the type of information, the applicable recruitment program, participant preferences, and legal obligations.

Information may be deleted, de-identified, restricted, or archived when it is no longer required for an authorized purpose.

13. Security Incidents and Breach Response

BBK maintains procedures for evaluating suspected unauthorized access, disclosure, loss, or misuse of participant information.

Where applicable law requires notification of an incident or breach, BBK will provide the required notifications in accordance with the applicable legal framework.

14. No Sale of Participant Information

BBK does not sell participant medical or health information.

BBK’s clients purchase recruitment and related professional services.

They do not purchase unrestricted access to participant profiles or BBK’s participant network.

15. Questions and Contact

Questions regarding participant privacy, health-related information, or data protection may be directed to:

BBK Marketing Solutions LLC
9990 Coconut Road, Unit 3502, Estero, FL 34135, United States
Email: privacy@bbk-marketing.com
Website: www.bbk-marketing.com

BBK Research Participant Solutions:
www.bbk-rps.com