Vital Connections Privacy Policy

Effective Date: August 20, 2026

1. Overview

At Vital Connections, respecting privacy is an important part of our commitment to research participants, panel members, and the general public. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, and the choices and rights available to you.

This policy applies to all our operations, including the websites operated by Vital Connections (i.e. vitalconnections.ca and sharperinsights.com).

Vital Connections is a Canadian market research company. Our personal information management practices are designed to comply with the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") and the substantially similar provincial laws. In addition, Vital Connections is committed to complying with applicable privacy laws in any jurisdiction in which it operates.

Vital Connections is a member of the Insights Association, which sets industry standards that members must adhere to and which also protect your privacy.

2. Who We Are

This policy is issued by:

Vital Connections

662 Sheppard Ave. East, Suite 304C

North York, Ontario M2K 3E6

Canada

Responsibility for compliance with this policy rests with the Vital Connections Privacy Officer, who can be reached at andrew@vitalconnections.ca or by mail at the address above. Other individuals within Vital Connections may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and processing of personal information.

3. What Personal Information We Collect

"Personal information" means information about an identifiable individual.

We collect only the personal information that is reasonably necessary for the purposes described in this Privacy Policy and the specific research study in which you choose to participate, and we collect it by fair and lawful means. Providing personal information to us is always voluntary; however, if you choose not to provide certain information, we may be unable to include you in a given study or process an honorarium payment.

Research participants and panel members

Depending on the study and your relationship with us, we may collect:

Healthcare professionals contacted for recruitment

We may collect professional contact information for healthcare professionals (such as name, professional designation, practice address, professional email address, telephone or fax number) from publicly available sources and reputable commercial data providers, including professional directories, licensing bodies, and business contact databases, for the purpose of inviting participation in research.

Website visitors

When you visit our websites, we may collect:

Our websites may use analytics tools to help us understand how visitors use our websites and to improve their performance.

Cookies

Our websites may use cookies and similar technologies for functionality and analytics. Vitalconnections.ca uses Google Analytics cookies to help us understand how visitors use the website and to improve its performance. These analytics cookies may collect information such as pages viewed, interactions with the website, device and browser information, and general usage information. You may opt out of analytics cookies through the cookie controls available on our website. Most browsers also allow you to refuse or delete cookies; disabling cookies may limit some website functionality.

4. Why We Collect and Use Personal Information

Vital Connections collects and uses personal information only for the following purposes:

We identify these purposes at or before the time information is collected. If we ever wish to use or disclose your personal information for a new purpose not previously identified, we will identify the new purpose and obtain your consent before doing so, unless the new use is permitted or required by law.

5. Consent and Research Confidentiality

Participation in survey research is always voluntary. When you agree to participate in a survey, you consent to the interview by participating. You are always free to choose whether or not to participate, free to decline to answer any specific question, and free to discontinue participation at any time.

Your individual responses are kept confidential and are never linked to your personal identifying information without your express permission. Your personal identifying information will never be sold to anyone.

To conduct a study, Vital Connections discloses your identifying and contact information — such as your name, email address, telephone number, and relevant professional details — to the market research firm conducting or administering that study. This is our primary disclosure of personal information, and it is necessary for you to be scheduled into and take part in the research.

The market research firm conducting the study typically carries out the research on behalf of a sponsoring organization, which is often a pharmaceutical or medical device company. Except where you expressly consent otherwise, or where necessary for the conduct of a particular study, information that directly identifies you is not disclosed to the sponsoring organization. Where a study is designed so that the sponsoring organization would receive information identifying you, we will tell you this at the time we invite you to participate and obtain your permission before making that disclosure.

To conduct a study, Vital Connections discloses your identifying and contact information — such as your name, email address, telephone number, and relevant professional details — to the market research firm conducting or administering that study. This disclosure is necessary for you to be scheduled into and take part in the research.

The market research firm conducting the study typically carries out the research on behalf of a sponsoring organization, which is often a pharmaceutical or medical device company. Vital Connections’ agreements with research firms require them to use participant information only for the purposes of conducting or administering the applicable research study and to protect the confidentiality of participant information.

Except where you expressly consent otherwise, or where necessary for the conduct of a particular research study, information that directly identifies you is not disclosed to the sponsoring organization. Where a study is designed so that the sponsoring organization would receive information identifying you, we will tell you this at the time we invite you to participate and obtain your permission before making that disclosure.

The research firm is responsible for conducting the research and preparing or reporting research findings in accordance with its obligations to Vital Connections and the sponsoring organization. Vital Connections does not authorize the research firm to use participant information for unrelated purposes.

Occasionally, a client sponsoring a research project may wish to contact respondents directly. In these cases, Vital Connections always explains the reason for the disclosure and obtains your express permission before making any such disclosure.

In determining the appropriate form of consent, we take into account the sensitivity of the information and the reasonable expectations of our respondents. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by ending your participation in the project(s) and/or by contacting our Privacy Officer.

6. Email and Fax Communications; Opting Out

Where applicable, Vital Connections complies with Canada's Anti-Spam Legislation (CASL), the U.S. CAN-SPAM Act, and other applicable communications laws. Our research invitations identify Vital Connections, include our mailing address, and provide a functioning unsubscribe mechanism where appropriate.

You may opt out of future research invitations at any time by:

Opt-out requests are recorded on a suppression list and honoured promptly, and in any event within 10 business days. We retain suppression-list entries as long as necessary to ensure your opt-out continues to be respected.

7. Use and Disclosure of Personal Information

We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. We may disclose personal information to:

Only Vital Connections employees and contractors with a business need to know are granted access to personal information about respondents, and all are required to respect its confidentiality.

8. Service Providers

We engage third-party service providers to perform functions on our behalf, including website hosting, communications and email delivery, scheduling, transcription and note-taking, incentive payment processing, and IT services. These providers may have access to personal information only to the extent needed to perform those functions for us, and may use it only for that purpose.

We take steps to ensure that our service providers are subject to appropriate contractual or other commitments to protect personal information, having regard to the sensitivity of the information involved and the nature of the services they provide.

This section applies to providers we engage to support our own operations. It does not apply to the market research firms that engage us to recruit participants; disclosure of personal information to those firms is described in Section 5.

9. Cross-Border Transfers

Vital Connections operates in Canada and conducts research with respondents in Canada and the United States. Personal information may be stored or processed on servers located in Canada or the United States.

In connection with a research study, personal information may be transferred to or accessed by the market research firm conducting or administering the study, or by service providers involved in the study, including where those organizations are located outside Canada. The same principles regarding disclosure described in Section 5 apply regardless of where the market research firm or sponsoring organization is located.

While personal information is outside your home jurisdiction, it is subject to the laws of the jurisdiction in which it is held and may be accessible to courts, law enforcement, and national security authorities of that jurisdiction. Where personal information is transferred outside Canada, we take appropriate measures designed to protect it in accordance with applicable privacy laws.

10. Retention

We keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Where a respondent may need to be re-contacted to clarify responses or seek additional responses, we retain the information for a period reasonably sufficient to allow this re-contact. We maintain reasonable and systematic controls, schedules, and practices for records retention and destruction. Information that is no longer required is destroyed or erased.

11. Security Safeguards

We protect personal information with reasonable security safeguards appropriate to its sensitivity, guarding against loss or theft and unauthorized access, disclosure, copying, use, modification, or destruction, regardless of the format in which it is held. These safeguards include physical, organizational, contractual, and technical measures designed to protect personal information, and all staff and contractors with access to personal information are bound by confidentiality obligations.

12. Your Rights: Access and Correction

Upon written request to the Privacy Officer, Vital Connections will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. You may challenge the accuracy and completeness of the information and have it amended as appropriate. We will promptly correct or complete any personal information found to be inaccurate or incomplete, and, where appropriate, transmit the amended information to third parties having access to it.

In certain situations, we may not be able to provide access to all the personal information we hold — for example, where doing so would reveal personal information about a third party, could reasonably be expected to threaten the life or security of another individual, or would reveal confidential commercial information. To safeguard your information, we may require sufficient identification before providing access; any such identification information is used only for that purpose.

Residents of certain U.S. states may have additional rights under applicable law. Requests may be submitted to our Privacy Officer using the contact details in Section 2. We will not discriminate against you for exercising your privacy rights.

13. Children

Our websites and research activities are generally directed toward adults, including healthcare professionals. We do not knowingly collect personal information from children under 13 without parental consent. If you believe a child has provided us personal information, please contact our Privacy Officer and we will delete it.

14. Third-Party Websites

Our websites or communications may contain links to websites operated by third parties, including survey platforms operated by our clients or partners. Those sites are outside our control, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

15. If You Have Questions

You may ask questions concerning our privacy management program by contacting our Privacy Officer as set out in Section 2 above. Vital Connections maintains procedures for addressing and responding to all inquiries and complaints regarding our handling of personal information, and will inform you of these procedures on written request. We investigate all complaints; if a complaint is found to be justified, we will take appropriate measures to resolve it, including amending our policies and procedures if necessary, and will inform you of the outcome.

16. Changes to This Policy

We review this policy periodically to ensure it remains current with changing industry standards, technologies, and laws, and we may update it from time to time by publishing a new version on our website. The effective date at the top of this policy indicates when it was last revised. We encourage you to review this page occasionally.

17. Contact Us

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

Privacy Officer

Vital Connections

662 Sheppard Ave. East, Suite 304C

North York, Ontario M2K 3E6

Canada

Email: andrew@vitalconnections.ca