Privacy Policy

This Privacy Policy describes how Orbit Technologies, Inc. ("Orbit Clinical," "we," "us," or "our") collects, uses, and protects your personal information when you visit our website or interact with our services, including our SMS text messaging program.

1. Information We Collect

The information we collect depends on which form you complete:

• Participant list (general sign-up). When you join our participant list, we collect basic contact information — your name, email address, and mobile phone number — together with coarse, non-sensitive eligibility details such as your age range, your time zone, the best time to reach you, and whether you can attend in-person visits in Charlestown, MA. We do not ask for health information at this stage.
• Study questionnaires (pre-screeners). When you complete the questionnaire for a specific research study, we collect the answers to that study's pre-screening questions. For some studies these answers include health-related information that is necessary to check your preliminary eligibility and safety for that study, along with the contact details needed to follow up with you.
• Referrals. If you refer a friend through our referral program, we collect the name and phone number you provide for them so we can invite them to apply, and we record who referred whom for referral rewards. Please make sure the person you refer knows you are sharing their contact information with us. If you were referred, we record who referred you.

We collect health-related information only within a specific study's questionnaire, and only for the limited purpose of assessing your eligibility and safety for that study. Providing it is voluntary, and you choose to submit it when you complete and send the form.

2. How We Use Your Information

We use the information we collect to:

• Contact you about research studies you may be eligible for, and respond to your inquiries;
• Assess your preliminary eligibility for a specific study, where you have completed that study's questionnaire, and manage your involvement if you choose to take part;
• Send you appointment reminders, scheduling updates, onboarding instructions, and service-related alerts via SMS where you have opted in; and
• Provide participant support.

You can ask to be removed from our participant list, or to have your information deleted, at any time by contacting us at participants@orbitclinical.com.

3. SMS Text Messaging

Message frequency: Message frequency varies based on your interaction with our services. You may receive messages related to scheduled appointments, program updates, and account or service activity.

Message and data rates: Message and data rates may apply. Your mobile carrier's standard message and data rates apply to all SMS messages you send to or receive from us. Please contact your wireless provider for details about your plan.

Opt-out (STOP): You can cancel the SMS service at any time by texting STOP to the number from which you received messages. After you send the message "STOP," we will send you a reply message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to rejoin, you can opt back in by signing up again as you did initially.

Help (HELP): If you are experiencing issues with the messaging program, reply with the keyword HELP for more assistance, or contact us directly at participants@orbitclinical.com.

4. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Consistent with Massachusetts 201 CMR 17.00, we maintain a written information security program, collect only the information we need, restrict access to those who need it, and protect personal information in transit and at rest. Contact information and study responses are held in access-controlled, encrypted systems — never in unsecured spreadsheets or email.

5. Sharing of Information

We do not sell your personal data to third parties or lead buyers. We share the information you submit — your contact details and, where applicable, your study questionnaire responses — with Orbit Clinical's research team and study personnel so they can assess your eligibility and contact you about relevant studies. We may also share information with trusted service providers who process it on our behalf, solely to the extent necessary to provide their services and subject to confidentiality obligations. These providers fall into the following categories: secure database and application hosting, SMS delivery, email delivery, electronic signature, calendar and scheduling, payment and reimbursement disbursement, background job processing, product analytics, and AI model providers that assist our team with scheduling and messaging (under API terms that prohibit training on our data). We may also disclose information where required by law.

6. Your Rights

You have the right to access, correct, or delete your personal information. You may opt out of future communications at any time, including by texting STOP to our SMS messages or by contacting us using the details below.

7. Applying to the Participant Pool (orbitclinical.com/apply)

This section applies when you use our online application at orbitclinical.com/apply, usually after tapping one of our ads. It is effective as of July 2, 2026, and we will post any changes to it on this page.

What we collect. When you use the application, we collect:

• Your contact details — first and last name, email address, and mobile phone number;
• Your answers to the screening questions;
• Whether your phone number was verified by the one-time text code;
• How far you progressed through the application, including if you leave partway through;
• Your approximate location — the city, state or region, and country our hosting provider estimates from your internet connection when you begin the application. It is approximate, is often only accurate to the region, and helps us know whether you are near our Charlestown, MA site before we call you. We do not store your IP address in your application record, and we do not use your device’s GPS or ask your browser for your precise location; and
• Ad-attribution details from the link you clicked — for example, which ad campaign brought you to the page (utm parameters and similar identifiers).

Why we collect it. We use this information to assess your eligibility for current studies, to contact you about future research studies you may qualify for, to schedule and manage your participation if you take part, and to measure which of our ads reach genuinely eligible people.

Partial submissions. If you leave the application before finishing, we retain the answers you gave so we can understand and improve the application experience (for example, seeing where people stop). We do not contact people who never submitted and verified their contact information.

What we never do. We never sell your data. We never share your individual screening or health answers with advertisers. And we never enroll you in any study without a separate, IRB-overseen informed-consent process.

Storage & protection. Your contact information and answers are stored in Orbit's secured participant-management system, and access is limited to the research team, consistent with the security practices described in Section 4.

Your rights. You may request access to, correction of, or deletion of your information at any time by emailing participants@orbitclinical.com. Deletion requests are honored except where research regulations require us to retain records for people who enrolled in a study.

Eligibility. The participant pool is for adults 18 and older. Please do not submit an application on someone else's behalf.

8. If You Enroll in a Study

If you go on to enroll in a research study, additional information is collected under that study's IRB-approved informed-consent process, which you will review and sign before anything is collected. This includes:

• Study and research data — the measurements the study collects (for example EEG headband recordings, temperature-sensor readings, and task performance), which are keyed to a study subject ID rather than your name and are governed by the informed-consent form you sign;
• Signed documents — your consent forms and study documents, together with their electronic-signature audit trails, which research regulations require us to retain;
• Payment information — your payout history, and receipt images you submit for reimbursement (please crop or redact any card numbers before submitting). Your name and email are shared with our payment-disbursement providers to deliver your payment; any tax forms are handled by those providers, and we do not store Social Security numbers, driver's-license numbers, or full payment-card numbers in our systems.

Retention. Recruiting information for people who never enroll is deleted on request. Research records for enrolled participants are retained for the period required by research regulations, after which they are disposed of securely.

9. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at participants@orbitclinical.com.