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Draft published for transparency. Pending attorney review.

Last updated October 22, 2026

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Kyros Trials Consumer Health Data Privacy Policy

The short version

  • This policy explains what happens to the health-related answers you give on a study prescreen page or prescreen chat hosted on Kyros Trials, before you consent to and enroll in a study.
  • The research site running the study decides what it asks and what it does with your answers. Kyros Trials runs the software for the site and may only use your answers to provide that service.
  • We ask for your consent before we collect your answers, and we ask separately before your answers are shared with the research site.
  • Your health data is never sold, never used for advertising, and never used to train AI. We do not use geofencing.
  • If you are not enrolled, contact the research site for its retention schedule. Agreeing to future-study contact is optional.
  • You can ask to see or delete your data, withdraw consent, and appeal if we say no. Contact privacy@kyrostrials.com or the research site.
  • The prescreen is an automated assistant. It is not medical advice and it does not decide whether you qualify. Only study staff decide.

1. Who this policy applies to

1.1 This policy applies to Consumer Health Data collected through public study prescreen pages, prescreen questionnaires and the prescreen chat assistant hosted on Kyros Trials (each, a "Prescreen"), from people who have not yet signed an informed consent form for the study (each, a "Prescreen Respondent," "you").

1.2 Roles.

  • The Research Site named on the Prescreen page (the clinical research site or site network that runs the study) decides which questions are asked, what happens to your answers, and whether to contact you. It is the "regulated entity" under applicable consumer health data laws.
  • Kyros Trials (Bordano Tissue, LLC, doing business as Kyros Trials, "Kyros Trials," "we") provides the Kyros Trials software the Research Site uses. Kyros Trials acts as the Research Site's processor. Kyros Trials may use your Consumer Health Data only to provide the Prescreen service to the Research Site, under a written contract (RCW 19.373.060).

1.3 When this policy stops applying. Once you sign the study's informed consent form and enroll, your information becomes part of the research record. It is then governed by the consent form, the Research Site's privacy notices (including any HIPAA authorization), and applicable research regulations, not by this policy.

1.4 Definitions. "Consumer Health Data" means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status, as defined in RCW 19.373.010(8), NRS 603A.414 and Conn. Gen. Stat. § 42-515, and includes inferences drawn from such information.

2. Categories of Consumer Health Data we collect

Depending on the study and the questions the Research Site configures, a Prescreen may collect:

CategoryExamples
Health conditions and diagnosesDiagnosed conditions, symptoms, severity, duration, prior diagnoses
Treatments and medicationsCurrent and past medications, procedures, surgeries, therapies
MeasurementsAge range or date of birth, height, weight, BMI, self-reported lab values
Reproductive or sexual healthPregnancy status, contraception use; only where the protocol requires it
Behavioral informationTobacco, alcohol or substance use, where relevant to eligibility
Prescreen outcomeWhether your answers suggest you "may be a match for screening" (an inference)
Contact details linked to the aboveName, phone, email, ZIP code, preferred contact method and time
Technical dataIP address and session identifiers used only for security and to prevent abuse

We do not collect precise geolocation, biometric data or genetic data through Prescreens. We do not use geofencing.

3. Sources

We collect Consumer Health Data directly from you (or from your parent or legal guardian, for pediatric studies) when you answer Prescreen questions or chat with the Prescreen assistant. Technical data is collected automatically from your browser. We do not buy data about you or combine it with data from data brokers.

4. Why we collect and use it

Your Consumer Health Data is collected and used only to:

  1. show you whether you may be a match for screening for the study you are viewing;
  2. pass your answers and contact details to the Research Site, with your separate consent, so study staff can contact you and decide whether you can be screened;
  3. if you separately agree, let the Research Site contact you about future studies;
  4. keep the Prescreen secure, prevent spam and abuse, and keep records that show you gave consent; and
  5. comply with law.

We never: sell your Consumer Health Data; use it for advertising or marketing unrelated to the study; use it to train AI models; or use it to make a final decision about your eligibility. AI features use a third-party model provider; the current provider is listed in our subprocessor notice on request. See our AI Use Policy summary.

5. Your consent

5.1 Consent to collect. Before you answer health questions, the Prescreen asks for your consent to collect your Consumer Health Data for the purposes in Section 4. You can decline and close the page; nothing is saved.

5.2 Separate consent to share. Before your answers and contact details are sent to the Research Site, the Prescreen asks for your separate consent to share them with that named Research Site. If you do not give it, do not submit your health answers or contact details. You can close the prescreen and contact the research site directly.

5.3 Optional consent for future studies. You may separately agree to be contacted about future studies. This is optional and does not affect your current Prescreen.

5.4 Withdrawing consent. You can withdraw consent at any time by emailing privacy@kyrostrials.com, contacting the Research Site, or replying to a message from your study team. Withdrawing consent stops further collection and sharing; we will then delete your data as described in Section 8.

5.5 Consent requests are clear, separate from other terms, and never pre-ticked. We keep a record of what you agreed to and when.

6. Who we share it with

With your consent, your Consumer Health Data is shared only with:

RecipientWhy
The Research Site named on the Prescreen page (and its study staff)To review your answers and contact you about screening
Service providers operating on behalf of Kyros Trials; the current subprocessor notice is available on request at privacy@kyrostrials.comTo operate the prescreen and deliver messages you requested, subject to applicable agreements and your consent
Government authoritiesOnly where required by law, after we notify the Research Site where permitted

Kyros Trials does not share your Consumer Health Data with any affiliate. Sponsors of the study do not receive your identifiable Prescreen answers from Kyros Trials. On request, we will provide a list of all third parties and affiliates with whom your Consumer Health Data was shared, with an active email address or other contact for each (RCW 19.373.040(1)(a)).

7. Your rights

You have the right to:

  • confirm whether we or the Research Site collect, share or sell your Consumer Health Data;
  • access your Consumer Health Data, and get a list of every third party and affiliate it was shared with;
  • withdraw consent to collection and sharing;
  • delete your Consumer Health Data. When we delete, we also tell each processor and third party that received it to delete it, and we delete it from archives and backups within six months (RCW 19.373.040(1)(c));
  • appeal a refusal to act on your request; and
  • not be discriminated against for exercising these rights.

How to ask. Email privacy@kyrostrials.com. You can also contact the Research Site. Because Kyros Trials acts for the Research Site, we will route your request to it and help it respond; where a law requires Kyros Trials to act directly, we will. We will verify your identity using the contact details you gave in the Prescreen. We respond within 45 days, which may be extended once by another 45 days when reasonably necessary, with notice to you. We will not charge you for up to two requests in a 12-month period.

Appeals. If your request is refused, you may appeal by replying to our response or emailing privacy@kyrostrials.com with the subject "Appeal." We will respond in writing within 45 days with an explanation. If the appeal is denied, you may contact the Washington Attorney General (https://www.atg.wa.gov), the Nevada Attorney General, the Connecticut Attorney General, or the attorney general of your state.

8. How long we keep it

The Research Site determines how long prescreen answers are needed for screening and any separately agreed future-study contact, subject to applicable law. Contact the Research Site or privacy@kyrostrials.com for its retention schedule or to withdraw consent. If you enroll, information that becomes part of the research record is subject to the study consent and applicable record-retention requirements. Deletion requests are handled under applicable consumer health data law, including its requirements for processors and backups.

9. Security

Consumer Health Data is encrypted in transit and at rest, access is restricted to the Research Site's authorized staff and to named, trained Kyros Trials personnel who need access to support the Research Site or meet a legal requirement, and all such access is logged. See our Security Overview.

10. No tracking, no geofencing

Prescreen pages contain no advertising pixels, social-media trackers, session replay or third-party analytics. We do not implement any virtual boundary around a health care facility to identify, track, collect data from, or send notifications or messages to people who enter or leave it (RCW 19.373.080; NRS 603A.540; Conn. Gen. Stat. § 42-526a).

11. Children

Prescreens for pediatric studies must be completed by a parent or legal guardian. Prescreens are not directed to children under 13, and children should not complete them directly.

12. Changes

If we change this policy in a way that would allow new uses or new sharing of Consumer Health Data, we will ask for your consent again before doing so.

13. Contact

Bordano Tissue, LLC, doing business as Kyros Trials, Attn: Consumer Health Data Privacy · privacy@kyrostrials.com

This policy is linked from the Kyros Trials homepage and from every Prescreen page. See also our general Privacy Policy.

Reader guidance, separate from the document

This section explains how to review health-answer privacy. It does not amend the policy or supply missing contract terms. Read the published document above and request the current full agreement where the page is a summary. Your organization should confirm that the wording addresses the intended use before relying on it.

Begin with a list of prescreen permission, rights requests, sharing and retention. Identify who at the site owns each question and what evidence is needed. A general product description cannot answer every contractual or study-specific issue. Keep unanswered questions in the review record rather than treating silence as a favorable term.

Review the workflow and the evidence

The practical responsibility is your consent choices and your research site’s study process. Ask what record would show that the process was followed and who can review it. A demonstration with sample data can clarify the workflow without disclosing participant information. It does not replace your legal or operational assessment.

For electronic research records, inspect the responsible user, dates, status, record linkage and change history. For public website interactions, review the information requested and the stated purpose. These are different contexts; a business-contact form should not be used to submit source data or confidential study documents.

Keep access and communication specific

Use individual accounts and the access appropriate to the person’s role. A shared login prevents a reliable link between an action and its responsible user. When inviting a reviewer, check the study and access period rather than assuming that a broad organization role is necessary.

For a question about this document, contact legal@kyrostrials.com. For privacy rights or handling concerns, contact privacy@kyrostrials.com. For a technical barrier or service problem, contact support@kyrostrials.com. Include business contact details, the page and the question, but do not paste participant names, health information, credentials or signed study documents into ordinary email.

Plan review before sensitive use

Request the current security summary, provider information and relevant agreement status before transferring sensitive records. Public summaries do not establish BAA execution, a particular vendor arrangement, an uptime guarantee or a certification. If a requirement is unresolved, document it and obtain an answer instead of inferring readiness from a feature being visible.

Your site’s procedures should explain who approves the system’s intended use, how staff are trained and how exceptions are handled. Keep the review proportionate to the study and data involved. A software control supports the procedure; it does not replace investigator responsibility or participant-facing obligations.

Retain context when records move

Before importing or exporting study information, identify the original records, signature evidence and audit histories that must remain available. A spreadsheet can carry values and dates without reproducing the source system’s historical events. Keep source exports and reconcile sample records so a later reviewer can understand the transition.

Review the trust hub for related policies and summaries and the switching guide for a sample migration review plan. Contract-specific archive or exit terms need the full agreement. Customer data is not deleted for non-payment, but your organization still needs to plan record retention and access under the applicable research rules.