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Privacy Policy

Last Updated: July 7th 2022

This Privacy Policy describes how Neuroglee Therapeutics, Inc. or its affiliates (“Neuroglee”, “we”,“our”or“us”)collect, use, and share information about you throug hour website (“Site”), mobile or desktop application (“App”), and any other online services that link to this Privacy Policy (collectively, the “Services”) and in email, text, and other electronic messages between you and the Services and written documents, phone calls and other offline activities between you and Neuroglee.

Please read this notice carefully to understand how we use, disclose, and otherwise manage the personal information we collect about you. If you do not understand any aspects of this Privacy Policy, please feel free to contact us (our contact information is at the end of this Privacy Policy). This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We are constantly updating and improving our Services and may need to change this Privacy Policy from time to time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. If we make material changes to this Privacy Policy, we may provide additional notice, such as by posting a notice on our Site, the App/ account sign-in pages, or via the email address we have on file for you. Your use of the Services after changes to this Privacy Policy means you have accepted the changes.

A Note About Protected Health Information

If you use our Services as a patient of one of our healthcare provider partners (“Provider”) or a care partner to a patient (“you”), we may collect Protected Health Information about you or your patient that is governed by HIPAA, either directly from you or from or on behalf of your Provider. Where this is the case, we act as a “business associate” to your Provider, and your Provider’s Notice of Privacy Practices and our agreements with your Provider govern the use of your Protected Health Information, not this Privacy Policy. If you have any questions about the use and disclosure of your Protected Health Information, please contact your Provider.

Information We Collect

Information You Provide to Us. We collect the information you or your care partner provides to us through the Services and offline, for example when you create or modify your account, register to use our Services, request products or services from us, request information from us, contact customer support, fill out any form through the Services, or otherwise communicate with us.

This information may include:

• Name
• Address
• Email address
• Telephone number
• Date of birth
• Gender
• Username and password
• Photographs, videos, or sound recordings
• Any other information requested or provided through a contact form, registration form, email, text, or any other messages through the Services.

Information We Collect Automatically. Whenever you interact with our Services, we automatically receive and record information from your browser or device using cookies or similar technologies. This information may include your IP address, geolocation data, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. To learn more about the cookies and other technologies we use, please see our Statement on Cookies and Similar Technologies below.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Track Application issues and crash logs.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Recognize you when you return to the Services.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of a Service, and we can use that knowledge to make the Services more helpful to as many users as possible.

How We Use Your Information

We use your information to:
• present our Services and their contents to you
• provide you with information, products, or other services that you request from us
• fulfill any other purpose for which you provide it
• register and service your online account
• enforce our Terms or other legal rights and remedies
• notify you about changes to our Services or any products we offer or provide
• fulfill any other purposes disclosed to you at the time we collect your information or pursuant to your consent
• if you consent, discuss your condition with your care partner.

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others, in accordance with applicable laws and regulations.

How We Share Your Information

Vendors and Service Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Services and deliver products and Services that you purchase through us. These vendors and service providers will have access to your personal information in order to provide these services.

Third-Party Analytics. We use selected third parties to collect data about how you interact with the Services. This information may be used to, among other things, improve the functionality of our Services.

With Your Consent. In addition to the sharing described elsewhere in this Privacy Policy, we will share personal information with companies, organizations, or individuals, including your care partner, when we have your consent to do so.

Legal Proceedings. We will share personal information with third-party companies, organizations, or individuals if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

• meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request;
• enforce applicable Terms, including investigation of potential violations;
• meet any applicable law, regulation, subpoena, legal process or enforceable governmental request;
• enforce applicable Terms, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security, or technical issues; or
• protect against harm to the rights, property, or safety of Neuroglee, our users, customers, or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Services to a third party, such as by merger, acquisition, bankruptcy proceeding, or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy.

Statement on Cookies and Similar Technologies

Our Services use cookies and other data collection technologies described in this section.

Cookies. A cookie is a small file placed on your computer’s hard drive that collects and stores information about your equipment, preferences, and browsing patterns. We use cookies to analyze web page traffic and usage patterns to tailor our Services to your individual interests. You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience our Services. For more information about cookies, visit allaboutcookies.org.

Web Beacons. A web beacon (also referred to as clear gif, pixel tag, or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity, and for similar statistical measures.

Google Analytics. Google Analytics, a web analytics service provided by Google, Inc. (“Google”), uses cookies to help us analyze how users use certain Services. The information generated by the cookies about your use of those Services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of certain Services, compiling reports about activity on those Services for us, and providing other services relating to your activity on those Services and your internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google or by us.

Do Not Track. Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit allaboutdnt.com.

Choices You Have Regarding Your Information

Accessing and Updating Your Information. You may review and request certain changes to the information we have collected about you by contacting us (our contact information is at the end of this Privacy Policy).

Marketing Communications. You may choose to stop receiving marketing, promotional, reminder, or notification emails from us. You can opt out of these messages by following the instruction contained in the message or by contacting us and requesting to opt out (our contact information is at the end of this Privacy Policy).

Retention of Your Information

As a general matter, we will keep your personal information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your personal information as necessary to protect our legal rights.

Security of Your Information

We maintain safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, we cannot and do not ensure or warrant the security of your information.

Children’s Privacy

We do not knowingly collect information from children under the age of majority. If you are a parent or guardian of a child under the age of majority and believe he or she has disclosed personal information to us, you may contact us to request that we delete and stop the use of that information (our contact information is at the end of this Privacy Policy). If we learn that we have received any information directly from a child under the age of majority without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.

We will then subsequently delete that child’s information.

Links to Other Websites

Our Services may contain links to other websites and those websites may not follow the same privacy practices as Neuroglee. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of such third parties to learn more about their privacy practices.

Information for Users from Outside of the United States

The Services are intended for use only in the United States. If you use the Services or contact us from outside of the United States, please be advised that (1) any information you provide to us or that we automatically collect will be transferred to the United States; and (2) by using the Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

Shine the Light (California Residents)

California residents may also request information from us once per calendar year about any personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us (our contact information is at the end of this Privacy Policy). Your inquiry must specify “California Privacy Rights Request” in the subject line of the email, and you must include your name, street address, city, state, and ZIP code.

Neuroglee does not share personal information with third parties for their own marketing purposes.

Contact Us

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, please do so by emailing us at privacy@neuroglee.com