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NEURELIS PRIVACY POLICY

Last Revised on July 13, 2020

This Privacy Policy for Neurelis (“Neurelis”, “we”, “us”, “our”) describes how we collect, use and disclose information about (1) visitors to the Neurelis websites (www.neurelis.com, valtoco.com, myneurelis.com, letstalkseizures.com, and other Neurelis-owned websites) (the “Sites”), as well as (2) clinical trials, products and services (collectively, the website and other Neurelis services are referred to as the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Neurelis may provide additional privacy notices to individuals at the time we collect their data. For example, we will provide a specific privacy notice to clinical trial participants in connection with conducting the clinical trial. This privacy notice will govern how we may process the information provided at that time.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING, ACCESSING, OR DOWNLOADING ANY OF THE SERVICES, YOU AGREE TO THE USE OF YOUR INFORMATION IT DESCRIBES AND TO THE OTHER TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE THE SERVICES.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. If you have provided an email address, you may be notified by email at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT ACCEPT AND AGREE TO THIS PRIVACY POLICY, INCLUDING ANY CHANGES, THEN YOU MUST NOT ACCESS OR USE THE SERVICES.

2. INFORMATION WE COLLECT

In order to provide you with particular services, we may ask you to provide us with certain details or information about you. We or our advertising partners may also automatically collect information through the use of cookies and other tracking technologies (see Section 8 below). Information that we collect through the Service includes:

  • Basic identifiers, such as:

    • Information you submit through inquiries or messages to us, including your name, email, phone number, mailing address, emergency contact information, and any other information you choose to include in a message.

    • IP address, device identifiers, etc.

    • Other types of basic identifiers (name, contact information, patient/care partner/HCP, other types of IDs, date of birth, age, gender, marital status, etc.) collected online or offline

  • Internet and network activity, such as

    • Analytic data related to use of the Services

    • Clickstream data, browsing history, ad or other site interactions

  • Protected classifications, such as health and medical (see detail below), race, ethnicity, or similar data

  • Health and medical information, such as medical insurance details, information about health conditions and diagnoses, treatments, family medical history, and medications you may take that we collect in connection with managing clinical trials, conducting research, providing patient support programs, and tracking adverse event reporting

  • Commercial information, such as tax identification and financial account information, etc.

  • Geolocation data, such as GPS data, precise location

  • Professional or employment information, such as job history, references, etc.

  • Education information, such as your institutions attended, transcripts, certificates, etc.

  • Inferences about you, such as inferences about your preferences, predictions about your characteristics or behavior, or similar information

3. HOW WE USE YOUR INFORMATION

We may use the above categories of information for a number of purposes, including:

  • To operate, maintain and enhance the features of the Sites, including monitoring and analyzing the effectiveness of the content on the Sites, monitor aggregate site usage data and track other usage of the Sites.

  • Providing you with the Services and any related features or functions.

  • Providing you with a tailored and user-friendly experience as you navigate our website and other Services.

  • Promoting the Services and providing any campaigns or promotions.

  • Communicating with you for administrative and other business purposes, including providing you information that you have requested.

  • We may conduct research on users’ demographics, interests, and behavior based upon information you provide during use of our Sites. We may combine your information with information collected from other individuals to produce anonymous, aggregated statistical information that will not include personally identifiable information. We may use this aggregated information for our business purposes. We may also share this anonymous, aggregated information with third parties, or allow third parties to collect anonymous, aggregated information through our website. We do not have total control over these third parties or which methods they may use to collect information.

  • Complying with any applicable legal obligations.

  • Enforcing any applicable terms.

  • Protecting and ensuring the safety and security of our Services and users.

4. HOW WE SHARE YOUR INFORMATION

We may share the above categories of information with outside entities in certain circumstances or for certain purposes, including:

  • For business purposes. We may share your information with vendors and other service providers, including our data hosting and data storage partners, analytics providers, customer service (including our medical information line) and patient support providers (including for product quality and adverse event reporting, patient co-pay assistance, etc.), recruiting services, event planning and travel organizations that help facilitate our programs, technology services and support and any data security vendors. We may also share information with professional advisors, such as auditors, law firms, or accounting firms.

  • With your direction or consent. We may share your information with third parties if you request or direct us to do so. This includes your use of social media widgets on our website.

  • With affiliates within our corporate group. We may share your information with any subsidiaries within our corporate group.

  • Compliance with law. We may share your information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.

  • In the context of a transaction. We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

  • For other business reasons. We may also share your information to enforce any applicable terms of service, and to ensure the safety and security of the Services and/or our users.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Our Services are not configured to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools → Internet Options→ Browsing History→ Delete to view manual and automatic options.

The Services also use certain analytic services, including Google Analytics.

We may also use Flash cookies (also known as “persistent identification elements” or “local shared objects”) on certain pages. Because Flash cookies cannot be controlled through your browser settings, you may click here to adjust your preferences. You can also identify Flash cookies running on your computer by visiting the Flash Player folder. Flash cookies, or LSO files, are typically stored with a “.SOL” extension. Please note that if you block cookies, some functions otherwise available on the Services may be unavailable, and we may not be able to present you with personally-tailored content.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

6. SOCIAL FEATURES

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access Neurelis’ pages on certain third-party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Neurelis and the third party may have access to information about you and your use of both the Services and the third-party service.

7. THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

8. INFORMATION USED FOR ADVERTISING

We may use independent advertising companies to provide ads on our behalf across the Internet (“advertising company”). These advertising companies also help us analyze our advertising campaigns and the general usage patterns of visitors to our web sites. This is primarily accomplished through the use of cookies, and Internet tags (web beacons, pixel tags, clear GIF (Graphics Interchange Format) images and invisible GIFs). Such companies may place these tags on our web sites or on other web sites. Used in conjunction with cookies, Internet tags are programmed by the advertising company to collect certain non-personally identifiable information about visitors to our web site and other web sites. This information may be used to provide ads about goods and services of potential interest to you, or to improve your web site experience. The advertising company does not know the names, addresses, e-mail addresses or telephone numbers of web site visitors, and does not link online actions to an identifiable person. The advertising company reports the non-identifiable data that it collects on our behalf back to us without identifying specific web site visits (other than to our own web sites). We use this information to improve our web sites and our advertising. In order to deliver more relevant content or advertising, or to connect with you via other methods, from time to time we may link the information we receive to your personal information. If we do link such data, it is treated under Neurelis’ privacy notice as personal information. If you would like more information about this practice, or if you want to prevent an independent advertising company from sending and reading cookies or action tags on your computer, you can visit the advertising company’s web site and opt-out or read below for information on how to contact Neurelis.

The Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).

9. CHILDREN’S PRIVACY

We do not seek or knowingly collect any personal information about children under 13 years of age through the website. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

10. DATA SECURITY

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

11. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you have the right to request certain information about our disclosure of your information to third parties for their own direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year.

12. INTERNATIONAL USERS

The Services are designed for users in the United States only. Please do not use the Services if you are outside the United States.

13. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at info@neurelis.com or contact us at 3430 Carmel Mountain Road, Suite 300, San Diego, CA 92121 and/or 1-858-251-2100.