Privacy Policy

1. About this policy

Hamilton Medical Research Group (“HMRG”, “we”, “us”, or “our”) is operated by 1140448 Ontario Ltd., a clinical research site located at 304 Victoria Ave N, Hamilton, Ontario, Canada. This Privacy Policy explains how we handle personal information collected in the course of operating our website and conducting clinical research, in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Health Information Protection Act (PHIPA), and other applicable Canadian privacy laws.

Personal health information collected as part of a specific clinical trial is governed primarily by the consent form signed for that trial and by the privacy practices of the trial’s sponsor. This policy describes our handling of personal information outside of, and in addition to, those study-specific frameworks.

2. Information we collect

Information you provide directly

• Contact details — your name, email address, phone number, and similar information when you contact us by email, through a form on this website, or in person.
• Email updates — your name, email address, and any optional details you choose to share when you sign up to receive occasional email updates from us, such as news about studies that are recruiting.
• Research participation information — information you provide when expressing interest in or enrolling in a clinical trial, including health information relevant to study eligibility.
• Talent network — your name, contact details, area of interest, and any optional details you choose to provide when you join our talent network to be considered for future employment. This may include a link to a resume or professional profile, or a resume file you choose to upload. Uploaded files are stored privately, outside the public website, and are kept and deleted on the same 24-month schedule described in Section 7.
• Employment and credentialing information — for staff, sub-investigators, and contractors working with us.

Information collected automatically when you visit our website

• Standard server logs — IP address, browser type, pages visited, referring page, date and time of visit. Used for security, troubleshooting, and aggregate site analytics.
• Analytics — we use Google Analytics 4 to understand site usage in aggregate. No personally identifiable information is shared with Google for advertising purposes.

Where information relates to a person under 18 — for example, a parent or guardian expressing interest on behalf of their child — we ask that a parent or guardian provide the information and act as the point of contact.

3. How we use your information

• To respond to inquiries and communicate with you about your interest in research participation.
• To screen for and conduct clinical trials, in accordance with the consent you provide for each trial.
• To send occasional email updates you have signed up for, such as notices about studies that are recruiting. Every such email identifies us and includes a way to unsubscribe.
• To send appointment reminders, study coordination messages, and other communications by email, phone, or text message (see Section 4).
• To contact talent-network members about employment opportunities that match their stated interests.
• To meet our regulatory and legal obligations as a clinical research site, including record-keeping required by Health Canada, the U.S. Food and Drug Administration (where applicable), and Research Ethics Boards.
• To operate, secure, and improve our website and operational systems.

4. Text message (SMS) communications

We use Zoom Phone to send and receive text messages with research participants and business contacts. Mobile telephone numbers are collected only when you provide them to us directly — most commonly during a verbal conversation with a study coordinator at the time of enrolment. We do not collect mobile telephone numbers through this website.

If you have provided your mobile number and consented to text-message communications, we may send you:

• Appointment reminders and confirmations for study visits;
• Coordination messages from your study coordinator;
• Reminders about study procedures, medications, or required materials;
• Notices that lab requisitions or other documents are ready for pickup.

You may opt out of text-message communications at any time by replying STOP to any message we send, or by contacting us at the details below. Standard message and data rates from your mobile carrier may apply.

5. How we share information

We do not sell personal information. We share personal information only as necessary to operate as a clinical research site and as permitted or required by law, including:

• Trial sponsors and Contract Research Organizations (CROs) — when you enrol in a clinical trial, study-related information is shared with the sponsor and CRO in accordance with the consent form for that trial.
• Regulatory authorities and Research Ethics Boards — Health Canada, the FDA, and other regulatory bodies, where required by law or by the protocol for a specific trial.
• Service providers — vendors who provide IT, communications, hosting, and similar services to us. These providers are contractually required to handle personal information consistently with this policy and applicable law.
• Legal requirements — where disclosure is required by court order, subpoena, or other legal process, or to protect the safety of individuals.

As stated in Section 4, mobile telephone numbers and SMS opt-in consent are excluded from any third-party sharing for marketing or promotional purposes.

6. Data security

We use administrative, physical, and technical safeguards to protect personal information, including encryption in transit, access controls, and Canadian-region data storage where reasonably available. Our principal technology platforms (Microsoft 365 and Zoom Phone) are configured to store recordings, transcripts, and similar content within Canada.

No system can be guaranteed completely secure. If we become aware of a privacy breach that creates a real risk of significant harm, we will notify affected individuals and the appropriate regulator in accordance with applicable law (including the Information and Privacy Commissioner of Ontario where required by PHIPA).

7. Data retention

Clinical trial records are retained for the period required by Health Canada, the FDA, the trial sponsor, and applicable Research Ethics Board policy — typically a minimum of 25 years for trials involving health products. Other personal information (such as general inquiries) is retained for as long as is reasonably necessary for the purposes for which it was collected, and then securely destroyed. Talent-network information — including any resume file uploaded with a submission — is kept for up to 24 months from the date of submission and is then securely deleted, unless the person asks us to remove it sooner.

8. Your rights

Subject to applicable law, you have the right to:

• Request access to the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Withdraw consent for non-essential processing (note: withdrawal of consent for clinical trial participation is governed by the trial’s consent form and may have implications for your continued participation);
• Opt out of text-message communications by replying STOP or contacting us;
• Unsubscribe from email updates at any time using the instructions included in any email we send, or by contacting us;
• Ask to be removed from our talent network at any time by emailing info@hmrg.org;
• File a complaint with the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario.

9. Contact us

For questions about this Privacy Policy or to exercise any of the rights above, contact:

10. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The “last updated” date below indicates when this policy was most recently revised. Material changes will be communicated through our website.

Last updated: August 26, 2026