Effective date: June 1, 2022
This Privacy Policy describes the privacy practices of Ceretype Neuromedicine, Inc. (“Ceretype”, “we”, “us”, or “our”) and how we handle personal
information that we collect through our website, through any other website that we own or control and which links to this Privacy Policy, and through
other interactions and correspondence with you (collectively, the “Services”).
Ceretype may provide additional or supplemental privacy notices to individuals for specific products or services that we offer at the time we collect the
personal information, for example, in connection with our clinical trials. These supplemental privacy policies govern how we may process your
information in those contexts.
Personal Information We Collect
Information you provide. Personal information you may provide to us through the Service or otherwise may include:
• Contact information, such as your first and last name, phone number, job title, and email and mailing addresses.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise
correspond with us online.
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content
you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.
• Marketing information, such as your preferences for receiving communications about our activities, clinical trials, events, and publications as well
as details about how you engage with our communications.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
• Healthcare organizations, such as your healthcare providers, industry and patient groups / associations.
• Research organizations, such as clinical trial investigators or contract researchers.
• Social media information. We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party
platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and
their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and
we will treat such information in accordance with this Privacy Policy.
• Other Sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data
providers.
Automatic data collection. We, our advertising partners and our service providers may automatically log information about you, your computer or
mobile device, and your interaction over time with our Services, our communications and other online services, such as:
• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen
resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising
purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city,
state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between
pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our
marketing emails or clicked links within them.
We use the following tools for automatic data collection:
• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in
the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us
understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your
device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that
certain content was viewed or clicked.
How we use your personal information
To operate our Services:
• Provide, operate, maintain, secure and improve our Services.
• Provide information about our Services.
• Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative
messages.
• Resolve disputes, collect fees, and troubleshoot problems.
• Understand your needs and interests, and personalize your experience with our Services and our communications.
• Respond to your requests, questions and feedback.
Marketing and advertising. We and our advertising partners may collect and use your personal information collected on our website for marketing
and advertising purposes, including:
• Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law. You may opt out of our marketing
communications as described in the Opt out of marketing communications section below.
• Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to
display ads around the web. These companies may use cookies and similar technologies to collect information about your interaction (including the
data described in the Automatic data collection section above) over time across our Services, our communications and other online services, and
use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information
about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn
more about your choices for limiting interest-based advertising in the Online tracking opt-out section below.
Compliance and protection. We may use personal information to:
• Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
Research and development. We may create and use de-identified information for our business purposes, including to analyze the effectiveness of our
Services, to improve and add features to our Services, and to analyze the general behavior and characteristics of users of our Services. We may use this
anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes.
How we share your personal information
Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy
Policy.
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us
operate our Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, fraud detection, payment processing,
and database management).
Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising
purposes described above.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where
necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes
described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection
with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale
of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.
Your choices
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom
of the email. You may continue to receive service-related and other non-marketing emails.
Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we
have summarized below:
• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do
this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information
about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
Use the following links to learn more about how to control cookies and online tracking through your browser:
• Firefox; Chrome; Microsoft Edge; Safari
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID
associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy
features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third
party cookies/trackers.
• Google analytics. We use Google Analytics to help us better understand how people engage with the Services by collecting information and
creating reports about how users use our Services. For more information on Google Analytics, click here. For more information about Google’s
privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.
google.com/dlpage/gaoptout.
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based
advertising:
• Google
• Facebook
• Twitter
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by
participating companies:
• Digital Advertising Alliance
• Network Advertising Initiative
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every
browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not
respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Other sites, mobile applications and services
Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an
endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile
applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are
not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal
information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Security practices
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure,
alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely
secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
Children
Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services
from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
International users
By using our Services, you understand and acknowledge that your personal information will be transferred from your location to our or our service
providers’ facilities and servers in the United States.
Job Applicants
When you visit the “Careers” portion of our website or apply for a job, we collect the information that you provide to us in connection with your job
application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other
information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information
to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor
recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of our websites, and as
otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’
rights or property; and/or (c) to investigate or assist in preventing any violation or potential violation of the law or the terms governing our provision of
the Service.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of
this Privacy Policy and posting it on our Services. We may also provide notification of changes in another way as required by law.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our
Services (or as otherwise indicated at the time of posting).
How to contact us
Please direct any questions or comments about this Policy or privacy practices to info@ceretype.com.