Last Updated on October 14, 2021
Privacy is important to Neurogastrx, Inc. and its affiliates (“Neurogastrx”, “we”, “us” or “our Company”), and we are committed to maintaining privacy protections for our users. This Website Privacy Policy (“Website Privacy Policy”) explains how we collect, use and store the information we obtain from or about you when you visit or use our website at neurogastrx.com (our “Site”) and also explains the security approaches we use to protect your information, and how you may access and request deletion of certain information that we may store about you. Our Site provides information about our Company, including information about our business, product candidates, therapy areas, investors, and publications.
Please note that this Website Privacy Policy applies only to information collected via the Site – it does not apply to information you disclose to Neurogastrx and its affiliates through other means. For information about our privacy practices with respect to our Dragon Study mobile application, and related Dragon Study secure web portal, please review our Mobile Application Privacy Policy located at neurogastrx.com/mobile-app-privacy-policy, and for information about any of our specific studies in which you participate, please refer to the respective study specific informed consent form. This Website Privacy Policy is not a contract and does not create any legal rights or obligations. By using the Site, you accept the Website Privacy Policy and you expressly consent to our collection, storage, use and disclosure of your information as described in this Website Privacy Policy.
The information provide on our Site, including descriptions of our therapy areas is not intended or implied to be a substitute for professional medical advice, diagnosis or treatment. Neurogastrx is not a health care provider (e.g. physician, hospital, pharmacist, etc.), and you are encouraged to confirm any information obtained from or through our Site and review all information regarding any medical condition or treatment with your physician. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY SEEKING MEDICAL TREATMENT BECAUSE OF SOMETHING YOU HAVE READ ON OR ACCESSED THROUGH THE SITE.
Neurogastrx does not recommend, endorse or make any representation about the efficacy, appropriateness or suitability of any specific tests, types of tests, products, procedures, genetic testing companies, treatments, services, opinions, health care providers, research institutions or other information that may be contained on or available through the Site.
By accessing, viewing or otherwise using our Site, you consent to the collection and use of your information by Neurogastrx in accordance with this Website Privacy Policy. If you do not agree to this Website Privacy Policy you may not use our Site. Neurogastrx reserves the right to change, modify, add or remove portions of this Website Privacy Policy at any time, without prior notice. Changes take effect on the date that appears on the revised Website Privacy Policy. If you use our Site following a change in this Website Privacy Policy, your use will be understood to signal that you accept and agree to the changes. Accordingly, we urge you to review this Website Privacy Policy frequently for changes.
We collect limited personally identifiable information (“Personal Information”) in connection with providing our Site. We may collect Personal Information that you provide to us, for example such as your name and email, when you contact us through our Site. We may automatically collect and use other information such as device identifiers, IP addresses and session identifiers to analyze trends, to track user activities and to improve our Site.
Please refer to the “Cookies and Other Data Collection Technologies” section below for more information about cookies and other information collection technologies.
As described, our information collection includes the following categories of Personal Information described in the California Consumer Privacy Act (“CCPA”):
We may use the Personal Information and other data we collect from you when you visit or use our Site in the following ways:
We may also de-identify and aggregate your Personal Information for our use. Aggregated Data is information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified. “De-identified Information” is information that has been stripped of your identifiers, such as your name, contact information, and other identifying data, such that you cannot reasonably be identified as an individual.
Our Site is intended for use by United States residents only. You understand and agree that if you are visiting or using our Site from a country outside the United States and provide Personal Information to Neurogastrx, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the Site may be stored and processed in the United States or abroad.
When you send email or other communications to Neurogastrx through our Site, we may retain those communications in order to process your inquiries, respond to your inquiries or requests, and improve our Site, our studies, and related products and services. When you send and receive messages, we may collect and maintain information associated with those messages.
Neurogastrx may share your information as follows:
We do not sell your Personal Information and have not done so in the 12-months preceding the effective date of this Website Privacy Policy.
9.1 Cookies
“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. Some cookies last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to our Site. Cookies are designed to make your online experience easier and more personalized.
Web server logs are files that store the activity on a certain website.
Information gathered through cookies and web server logs may include information such as the date and time of visits to our Site, the pages viewed, time spent at our Site, and the websites visited just before and just after our Site. We may use cookies and web server logs to help you move between websites in a smooth and secure manner, and to gather information about the browsing activities of users of our Site in order to continually improve it and better serve the needs of its users.
Most web browsers automatically accept cookies. You can change your browser settings to notify you of the cookies being set or updated, and to block cookies. Please note that if you have turned off all cookies, some features of our Site may not be available to you or otherwise function as intended. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
Our Site may use the following types of cookies:
9.1.1 Essential/Strictly Necessary Cookies:
These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.
9.1.2 Analytics/Performance Cookies:
These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Site. They help us know which pages are the most and least popular and see how visitors move around the Site. Information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Site through the use of cookies.
9.2 Other Data Collection Technologies
A web beacon is a web page element (such as a clear gif, pixel tag or single-pixel gif) that may be embedded into our Site or email messages, newsletters, and other electronic communication. They help us to determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.
We may use third-party web analytics services (such as those of Google Analytics) and other technologies on our Site to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by visiting https://tools.google.com/dlpage/gaoptout.
Our Site currently does not respond to “Do Not Track” (“DNT”) signals.
Neurogastrx has in place measures to safeguard and help prevent unauthorized access and maintain data security of Personal Information and other information you provide to us. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of our Site. Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.
This Website Privacy Policy applies solely to information collected through our Site. We may provide links to websites and other third-party content that we do not own or operate. Our Website Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you on our Site. We also do not control the privacy policies and your privacy settings on third-party sites, including social networks.
Our Site is intended only for use by adults. We do not knowingly collect information directly from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Site, please notify us and we will endeavor to delete that information from our databases.
Under the California Consumer Privacy Act (“CCPA”), California residents may have certain privacy rights, including the rights to: (i) request additional disclosures about the Personal Information and obtain a copy of that information, i.e., a “Request to Know,” sometimes called the Right to Access; (ii) request deletion of Personal Information, i.e., a “Request to Delete Information,” sometimes called the Right to Be Forgotten or the Right to Erasure; and (iii) opt out of the sale of Personal Information if we were to sell Personal Information, i.e., a “Request to Opt Out.” Since we do not sell your Personal Information, you are already opted-out of any sales.
14.1 How to Exercise Privacy Rights
If you wish to exercise any of these rights please email info@neurogastrx.com with “Request for California Privacy Information” on the subject line and in the body of your message. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. If we retain Personal Information you have provided to us only in de-identified form, we will not attempt to re-identify your data in response to a rights request.
We do not discriminate against you, for example, by offering a different level of service, for exercising any of these rights.
If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we may request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.
14.2 California Shine the Light
Additionally, under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2021 will receive information regarding 2020 sharing activities).
To obtain this information from Neurogastrx please send an email message to info@Neurogastrx.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
If you have any questions, comments, and concerns about our Site, please contact us at:
Neurogastrx, Inc.
600 Unicorn Park Drive
Woburn, MA 01801
info@neurogastrx.com
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