Working policy

Privacy notice

Structure covers

The decisions this working policy must make clear.

Profiles and contact
What is collected, why it is used, and how a person can manage it.
Research operations
How screening, participation, client review, support, and payment records are handled.
Website and support
Which technical, inquiry, preference, and rights-request information enters the operation.

1. Who is responsible

The final notice must name the legal entity or entities responsible for Relevane client, professional, transition, website, recruiting, screening, payment, and support data. It must explain the relationship with Focus Crossroads and any service providers.

2. Information collected

Expected categories include account and contact details, professional profile information, project screeners, scheduling and participation records, communications, payment administration, consent and preference records, website technical data, and support or rights requests.

The final inventory must be derived from the implemented systems and data flows. It must not promise minimization or deletion behavior that the operation cannot deliver.

3. Why information is used

Purposes may include creating and maintaining profiles, identifying potentially relevant studies, recruiting and qualification, client selection, scheduling and research participation, payments, fraud and duplicate controls, support, legal obligations, and service improvement.

4. Sharing and disclosures

The final notice must explain what profile and screening information may be shared with research clients, which vendors process data, when legal disclosures may occur, and whether information moves across borders.

5. Retention and security

Approved retention periods and deletion rules are required for prospects, members, screeners, project records, payment records, suppression lists, transition records, logs, and backups. Security language must describe current controls without creating unsupported guarantees.

6. Choices and rights

The final notice must explain communication preferences and applicable access, correction, deletion, restriction, objection, portability, appeal, and complaint rights, including identity verification and response timing.

7. Optional website analytics and session replay

The proposed services are Google Analytics 4 for website usage measurement and Microsoft Clarity for session replay and heatmaps, managed through Google Tag Manager. Each requires a separate opt-in and is limited to eligible public information pages. Inquiry, professional-profile, privacy-request, transition, and policy pages are excluded. These permissions are separate from research participation, profile submissions, and marketing communications.

The final notice must explain what Google and Microsoft receive, including cookie identifiers, page visits, device and browser information, and network information. The proposed Google page-view configuration omits query strings, fragments, referrers, form contents, and user IDs. Clarity can record clicks, scrolling, page structure, and interaction timing. The proposed Balanced masking configuration leaves ordinary public page text visible while masking numbers and email addresses; Clarity masks inputs and dropdowns in every mode. Cookie preference controls are explicitly masked. Excluded pages retain full masking as an additional precaution. Actual project settings and recordings must be verified. Masking does not remove all URL or technical information.

Clarity is blocked on pages with query strings or fragments and when a supplied referrer is not a clean, approved public page on this site. Advertising consent stays denied. The proposed setup does not link Clarity to Google Analytics or send custom visitor identifiers, profile details, or form contents. Published tags, outgoing requests, and recordings must be verified before these limits become final public promises.

The final notice must identify the responsible Relevane entity, relevant Google and Microsoft entities and roles, purposes and applicable legal bases, data sharing, international transfers and safeguards, cookie lifetimes, analytics and recording retention, access controls, and rights-request handling. The cookie notice describes the proposed inventory, including Microsoft's different retention periods for ordinary and saved recordings.

Visitors can reject both services or change each choice through Cookie preferences in the footer. Both remain off while Global Privacy Control is active. Withdrawal disables the selected service and reloads a page where tracking has loaded; it cannot recall data already sent or requests in progress. The final notice must explain the separate process for applicable deletion requests.

8. Cloudflare Web Analytics

We plan to use Cloudflare Web Analytics to understand website traffic and page performance. When enabled, it measures page views, referral sources, page-loading times, and Core Web Vitals. Reports can include hostname and page path, country, device type, browser, and operating system.

Cloudflare states that Web Analytics does not use cookies or local storage, fingerprint visitors, or track individuals across customer websites. It measures visits and performance rather than recording sessions. Cloudflare also states that it does not log URL query strings. These descriptions concern Web Analytics; hosting, security, and Turnstile have separate data practices.

Cloudflare Web Analytics operates separately from the Google Analytics and Microsoft Clarity choices in Cookie preferences. When enabled through our hosting provider, it can run before a cookie choice and on pages excluded from those two services. Their consent, browser-signal, and page restrictions do not automatically apply to Cloudflare Web Analytics.

The final notice must reflect the enabled Cloudflare configuration, applicable processing roles and legal basis, international transfers, retention, and rights handling. Cloudflare currently describes access to Web Analytics reports for the previous six months; that reporting window is not a promise that all underlying data is deleted at that point.

9. Contact

Publish an operational privacy address, mailing address, and any required regulator or representative details. Placeholder .example addresses must not remain at launch.

Provider privacy information: Google privacy policy, Microsoft privacy statement, and Cloudflare privacy policy. See also Cloudflare Web Analytics privacy information and our cookie notice.