Neurotech Pharmaceuticals, Inc., and its subsidiaries (collectively, “Neurotech”, “our,” “us,” or “we”) are committed to respecting and protecting the privacy of individuals. It is important to us that we provide transparency regarding our collection, use, and disclosure of your personal information and the steps we take to protect your information from unauthorized use or disclosure. “Personal Information” includes, without limitation, any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
This Privacy Policy applies to our website, as well as online or digital services, social media accounts, electronic mail, and mobile applications that link or reference this Privacy Policy (collectively, “Websites”) and, where applicable, to all Personal Information we obtain and process through other means in the course of doing business (the “Services”).
This Privacy Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain Websites may contain Privacy Notices providing more details about the information we collect on those platforms, why we need that information, and choices you may have about the ways we use that information.
We may also provide separate notices for particular programs. For example, we may provide notices to individuals who participate in patient support and assistance programs sponsored by Neurotech in order to provide additional or more specific information to participants about the processing of their Personal Information related to such programs. We may also provide specific notices and obtain specific consents from clinical trial participants.
In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business. Residents of certain jurisdictions may be entitled to additional disclosures regarding their personal information under the laws of those jurisdictions. Please refer to the section titled “Additional Information for California Residents” below for information specific to California residents as well as our “Consumer Health Data Privacy Notice” for information specific to Washington and Nevada residents. To the extent there is a conflict with this Privacy Policy, the additional or supplemental notice will control, where applicable, with respect to the Personal Information subject to such notice.
By using our Websites, including your choices regarding cookie settings, or using the Services, you are acknowledging and agreeing to the collection, use, disclosure, and transfer of your information as described in this Privacy Policy (and any additional Privacy Notices that apply to you). If you do not agree to the collection, use, disclosure, and transfer of your information as described in this Privacy Policy (and any Privacy Notices that apply to you), you may not use our Websites or Services.
This Privacy Policy describes how we use, share, and protect Personal Information. It also describes your rights and choices regarding the use, access to, and correction of Personal Information. If you have questions about this Privacy Policy, or any Privacy Notice, please contact us using the information provided below. Where any of your Personal Information is processed based on your consent, you may revoke your consent to the collection, use, disclosure, and transfer of your information as described in this Privacy Policy at any time (and any Privacy Notices that apply to you) by contacting us through the contact information provided at the end of this Privacy Policy.
The Websites are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.
The following is a non-exhaustive list of sources from which we may collect and process voluntarily
submitted Personal Information:
We collect Personal Information and other data that you voluntarily submit to us, including when you enter information into forms or data fields on our Websites, as well as Personal Information about you that is provided on your behalf (such as by your authorized representative, legal guardian, healthcare provider, and others with whom you interact related to our Services).
For example, if you request information about a product or service from us via our “Contact Us” form on our website, information such as your name, email address, phone number, and other contents of your message will be collected. This includes any text characters and any audio, video, and graphic information formats included in the message. If you voluntarily submit Personal Information to us that is sensitive in nature (e.g., health information), that will also be collected and processed for the purposes set out below. When you submit information through our contact page or participate in one of our market research or educational programs, we may collect any contact information that you choose to give us, including your name, title, company, phone number, and email and physical addresses, which we will use to communicate with you and otherwise fulfill the purpose of the contact submission or participation. If you submit a job application with Neurotech online, we will collect Personal Information including your contact details, work history, employment needs, and interests, and anything you submit in connection with the job for which you are applying. We may combine this information with information we collect or receive about you from other publicly and commercially available sources, such as LinkedIn and other social media platforms. We may combine all the information we receive about you and use or disclose it in the manner described in this Privacy Policy.
The following are the categories and specific types of Personal Information that we collect:
| CATEGORIES OF PERSONAL INFORMATION | TYPES OF PERSONAL INFORMATION |
| Personal Identifiers | Full name, address, email, phone number, date of birth, username, signature, social media handles, or other similar identifiers, and other contact information and contact preferences for individuals and (as applicable) their authorized representatives or parent or guardian |
| Government Identifiers | Including your driver’s license number, social security number, or other similar government-issued identifiers in the event you are hired as an employee or contractor of Neurotech. |
| Customer Records | Such as username and password that you may select in connection with establishing an account on our websites or mobile apps, account number, and records of communications and other requests you submit to Neurotech |
| Professional Information | Including information about current and former employment and positions, credentials, resume, business contact information, and professional membership. |
| Educational Information | Including educational history relating to attended schools, degrees obtained, and related dates for those degrees. |
| Health and Medical Information | Including information you choose to provide regarding eye conditions, symptoms, diagnoses, or medications, as well as information you choose to provide about physical and mental health conditions and diagnoses; treatments for medical conditions; genetic information; family medical history; medications an individual may take, including the dosage, timing, and frequency; and information about an individual’s healthcare providers that we may collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs, and tracking adverse event reports. |
| Financial Information | Financial information and transaction data, including purchase history (such as billing, payment and other transactional information, income, eligibility information to determine eligibility for patient assistance programs, and information collected as part of our clinical trial investigator onboarding) and other financial and payment-related data (such as information that we are required to collect and maintain related to payments and financial interactions that we engage in with both businesses and individuals) |
| Audio, visual and other electronic data | Including electronic or visual information, such as your photograph, digital or electronic signature, call recordings, and webinar and social media handle. |
| Sensitive Personal Information | Including, of the information described above, information pertaining to sexual orientation, race or ethnicity, Personal Information concerning a consumer’s health, financial information, Social Security number, passport number, and other government identifiers. |
| Device Information and Other Unique Identifiers | Including device identifiers, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers. |
| Internet or Other Network Activity | Including browsing history and information about your interactions with our Websites. |
| Demographic Data | Including age, gender, race, ethnicity, some of which may include characteristics of protected classifications under state or federal law. |
| Employee and Job Applicant Information | Including employment information (such as education and employment history) and any other information you provide in connection with applying for employment with Neurotech, bank account information, insurance policy information, information obtained in connection with administering employee benefit plans, salary information, passport number and information, drivers license or state identification number, disability and medical leave application information. |
We may also collect Personal Information on our Websites at other points that explicitly state that Personal Information is being collected from you through a Privacy Notice. In these circumstances, Neurotech will disclose the purpose of collecting your Personal Information and will only use it for the purposes stated.
If you are a healthcare professional, we may also collect or have collected in the prior 12 months:
Like many companies, Neurotech and its third-party service providers use a variety of tracking technologies such as cookies, embedded web links, pixel tags, Flash cookies, and web beacons, to passively collect certain information about your use of and visits to our Websites. For example, we may collect your Internet Protocol (IP) address, your authentication information, the type of device used, the web browser and operating system used to access our Websites, the time and duration of your visits, your search queries, and information about the content and webpages you view and the features you access on a Websites. This information helps us better understand the use and effectiveness of our Websites and is in a form that does not, on its own, permit direct association with any specific individual, however, much of this information is considered Personal Information as defined above.
Here is more information about some of tracking technologies, cookies, and how they work: A cookie is a file containing an identifier that is sent by a web server to a browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may not contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. To the extent that cookies that are not strictly necessary for the provision of the Websites, we will ask you to consent to such use of cookies when you first visit the websites.
We use cookies for the following purposes:
One of the third-party services that we use to track your activity and understand your behavior on our Websites is Google Analytics. Information that we collect may be combined with other information about you using Google Analytics or other services. We use these technologies, alone or in combination, to understand user behavior (by tracking unique user IDs), and to target and measure the effectiveness of advertisements, help diagnose problems, and facilitate your access to, and use of, the services offered on our Websites. Where applicable, we will collect your consent using a cookie banner on the front page of our website prior to using any non-essential cookies.
Neurotech also uses Google AdWords, which uses a conversion tracking cookie (also called a “conversion pixel”) whenever you click on a Neurotech ad delivered by Google. These cookies become ineffective after 30 days and are not used for personal identification. If you visit specific pages of our website, Google, and Neurotech can track whether you were forwarded to that page by clicking on one of our ads.
Data obtained through use of conversion cookies are used for statistical reporting only: these statistics tellus the number of users who clicked on the ad delivered by Google and opened a webpage having a conversion tracking tag. We do not, however, receive any information allowing personal identification of users from Google. We are unable to cross- reference the data obtained to any specific user. Information about how to opt out of Google AdWords can be found on the Google Ads Settings web page.
We make available several ways for you to manage your preferences regarding targeted advertising and
cookies on our websites as described below:
Neurotech may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud.
Information collected through cookies, pixels, and similar tracking technologies on our Services may be shared with advertising partners for retargeting so our advertisements may appear on other websites and mobile applications you visit. You can opt out of targeted advertising to you by submitting an opt-out request to us as set forth below.
We may also use and disclose aggregate, anonymous, and other non-identifiable data, and in some cases de-identified data, related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal
or household device) we will maintain and use the information in de-identified form and not attempt to reidentify the information, except in accordance with applicable laws (e.g., to test that our deidentification procedures function appropriately).
We use the Personal Information that we collect and receive for the following purposes:
In addition to the purposes listed above, we use Personal Information of healthcare professionals for the
following purposes:
We may also use Personal Information for other purposes which will be described at the time of collection.
We will not disclose any Personal Information we collect from you to any third parties except as indicated
below:
We retain Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
The security of your information is important to us. We employ commercially reasonable security controls to protect the Personal Information submitted to us from unauthorized access, loss, interference, misuse, disclosure, alteration, or destruction, both during transmission and once we receive it. Neurotech employees who have access to Personal Information are made aware of and trained on the importance of
keeping it confidential.
We care about the security of Personal Information and use various administrative and technological safeguards to preserve the integrity and security of all Personal Information collected through our Websites. These safeguards vary based on the sensitivity of the Personal Information that we collect, process, and store, and the current state of technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we make commercially reasonable efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or
security measures contained on our Websites. If you have any questions about data security and integrity
on our Websites, you can contact us using the details in the “How to Contact Us” section below.
You may have certain rights relating to your Personal Information which depend on Neurotech’s reason for processing, local laws, and exceptions to those laws in your jurisdiction as described in this Section. Please refer to the section titled “Additional Information for California Residents” below for information specific to California residents as well as our “Consumer Health Data Privacy Notice” for information
specific to Washington and Nevada residents.
You may exercise these rights by emailing us at NTDataPrivacyOfficer@neurotechusa.com or as described in the How To Contact Us section below. Please note that many of the above rights are subject to exceptions and limitations. Additionally, the rights described above are not absolute, and we reserve all rights available to us in this regard. Your rights and our responses will vary based on the circumstances
of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.
You may review and update the Personal Information we have collected, including your name, phone number, email, and postal address, and other information by which you can be personally identified. You may update your Personal Information and your communication preferences in several ways and depending upon the nature of your relationship with us:
In addition, residents of certain jurisdictions may be entitled to additional rights under the laws of those jurisdictions; please refer to the section titled “Additional Information for California Residents” below for information specific to California residents as well as our “Consumer Health Data Privacy Notice” for information specific to Washington and Nevada residents. We will not restrict or deny you access to our
Services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver the Services.
As Neurotech is a global organization, the Personal Information you provide may be transferred to Neurotech or a third party in the United States, whose laws may not provide the same level of data protection for your Personal Information as in your country; however, Neurotech implements appropriate safeguards to protect personal information, such as entering into contracts that contain standard data protection clauses. By using our Websites and Services and providing us with your Personal Information, where applicable law permits, you consent to such transfers, as well as the processing, and storage of such information outside your country of residence.
Our Websites may contain links or references to third-party owned or operated websites or online services. Neurotech is not responsible for the collection of Personal Information or the security or privacy of any such third-party sites or services. Likewise, Neurotech is not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of any other app developer,
app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any information you disclose to such other organizations through or in connection with our social media pages, any mobile sites, applications, widgets, and other mobile interactive features. We encourage you to review the privacy policies posted on the websites you visit.
You will only receive information about our products and services and special offers from us if you specifically request it. At any time after making such a request, you can let us know that you no longer wish to receive such information by contacting us using the details in the “How to Contact Us” section below. If you are emailing us, please place “Opt-Out Request” in your email subject line.
Our Websites and Services are intended to be used by adults and corporate entities interested in Neurotech. It is not intended for children, and Neurotech does not knowingly collect or store Personal Information about anyone under the age of 18. without proper consent, such as the consent of their parent or guardian. If we discover that a child under 13 has provided us with personal information, we will delete
such information from our systems. All Neurotech relationships that support children are directed to and are communicated with parents and guardians only. In such instances, we may collect, use, disclose, or sell Personal Information about children only with parental or guardian consent.
California law permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you would like more information, please submit a written request to us, and as required by California state law, we will either (a) respond with a confirmation that we have not disclosed any Personal Information to third parties fordirect marketing purposes in the previous calendar year, or (b) if our practices have changed, we will provide the categories of Personal Information that have been shared for direct marketing purposes in the past twelve (12) months and categories of third parties to whom such Personal Information was disclosed for such purposes, whichever is relevant.
We conduct, sponsor, and support clinical research. This Privacy Policy does not apply to participants in a clinical trial, clinical study, or research project (“Clinical Research”). Clinical Research participants should review the notice provided at the time they enrolled in the Clinical Research to understand how Neurotech uses their Personal Information. When supporting a clinical trial, Neurotech is neither a
covered entity nor a business associate under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations, as amended (HIPAA). If your use of the Services requires an authorization under HIPAA from you, Neurotech or your clinical trial sponsor will request a HIPAA authorization prior to such disclosure. If you have more questions about the use of Personal Information
collected during Clinical Research, please contact us at NTDataPrivacyOfficer@neurotechusa.com or the study site at which you are participating in the Clinical Research.
Neurotech regularly reviews this Privacy Policy and ensures that we process your information in a manner compliant with applicable laws. We reserve the right to change this Privacy Policy from time to time to reflect changes in our business practices, technological advancements and legal/regulatory environment. Any changes to this Privacy Policy, including information collected and the use and disclosure of that information will be posted here. Following any modification, we will revise the “last updated” date at the top of this Privacy Policy. If you are concerned about how your information is used, you should check our websites periodically. By continuing to use our Websites following the “last updated” date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.
You may contact us with any questions, concerns, or inquiries about this Privacy Policy or our privacy practices. If you would like to make a formal complaint, please contact NTDataPrivacyOfficer@neurotechusa.com. All complaints will be evaluated and a reply will be sent as
soon as appropriate. In some instances, Neurotech may cease services to you if necessary to satisfy your reques.
Neurotech Pharmaceuticals, Inc.
900 Highland Corporation Drive
Building 1
Cumberland, RI 02864
Telephone: 401.333.3880
Email: NTDataPrivacyOfficer@neurotechusa.com
