Privacy Policy

Last Updated: September 18, 2024

Who We Are

Ataraxis AI, Inc. (“Ataraxis,” “Company,” “we,” “our,” or “us”) value your privacy and the protection of your Personal Data. This Privacy Notice (“Notice”) explains how we collect, store, use, share, transfer, delete, and process information collected from or about you, known as Personal Data (defined further below in this Notice).

Purpose and Reach of this Privacy Notice

This Notice describes the types of Personal Data that we may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data.

This Notice applies to Personal Data collected or processed by us:

• Through online activities and services, we offer (through websites, web surveys, newsletters, applications, email, online messaging services/channels, and otherwise) (“Online Services”);
• Related to activities we undertake in recruiting participants for clinical trials or identifying and contracting with study investigators and their staff;
• In connection with adverse events, complaints, and reports;
• When we provide products or services to you or your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, “Healthcare Provider”) or, if you are a Healthcare Provider, your patients;
• When you are applying to and/or enrolled in patient support programs, such as Access Solutions, patient foundations, or co-pay assistance programs;
• When we provide products and services directly to you and in other situations where you interact with us, including interactions through customer service centers, email, SMS/text, or visits to our sites and offices or events (e.g., tradeshows, conferences) (collectively, the “Products and Services”);
• When you interact with us in a professional capacity, for example, if you are a Healthcare Provider or an employee of a company with which we do business or provide Products and Services;
• When we undertake employment recruiting activities; or
• Anywhere this Notice is posted or referenced.

We may provide a different privacy notice in specific situations, which will govern the Personal Data collected or processed in that specific context, rather than this one.

If you provide us with Personal Data of anyone other than yourself (such as a patient or family member), you are responsible for complying with all applicable privacy and data protection laws before sharing that information (including obtaining consent, if required).

Please review this Notice carefully. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.

Information Collected

What is Personal Data?

“Personal Data” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information. Data that could be considered Sensitive Personal Data is highlighted with an asterisk (*) in the chart below.

We will process any Personal Data we collect in accordance with applicable law and as described in this Notice (unless a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Data, certain Products and Services may be unavailable to you.

The below table is a high-level summary of the types of Personal Data we may collect from you. Following that summary is additional detail on how we collect, process, and use Personal Data and the potential recipients of your Personal Data. The types of Personal Data we collect and disclose depend on your relationship with us. Not all of the categories listed below may apply to you.

Note regarding De-identified Data - We will not attempt to re-identify you or anyone else from this De-identified Data, and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the De-identified Data. De-identified Data includes health information resulting from the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act ("HIPAA"), 45 CFR § 164.514(b)(2). Please note that in the course of research, study doctors and authorized personnel may still have access to named subject records collected for such research.

Sensitive Personal Data is noted with an asterisk (*). De-identified Data is not considered Personal Data under data protection laws, and there is a commitment not to attempt re-identification.

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries

We may process your Personal Data when you: (1) visit our websites and physical locations; (2) submit inquiries to us both online or offline; (3) sign up for newsletters or other informational or marketing materials; and/or (4) register for, visit, or use our online Products and Services.

Patients Applying to or Enrolled In Patient Support Programs

We may process your Personal Data when you are applying to or enrolled in patient support programs.

Healthcare Providers

We may process your Personal Data when you are a Healthcare Provider who is a current or prospective customer, use Products and Services, or treat patients using our Products and Services, including our online portals.

Patients and Users of Medical Products

We may process your Personal Data when you are an existing or prospective patient of a Healthcare Provider who uses our products and/or services.

Business Partners and Their Employees, Agents, and Contractors

We may process your Personal Data if you are a current business partner, employee of a business partner, agent, or contractor.

Attendees and Participants at Events

We may process your Personal Data when you attend or participate in professional and educational events we sponsor or hold.

Clinical Investigators and Members of Investigator Teams

We may process your Personal Data if you are an existing or prospective clinical investigator or a member of an investigation team for a clinical study we manage on behalf of a customer.

Clinical Study Candidates

We may process your Personal Data when you have been identified as a potential candidate for clinical studies sponsored by us or conducted on behalf of a third party.

Employment and Apprenticeship Candidates

We may process your Personal Data when you apply or are a candidate for employment or apprenticeship.

Children

We do not knowingly collect, maintain, disclose, or process Personal Data from minors under the age of 18 without the permission of their parents or legal guardians.

Consumer Health Data

In some jurisdictions, specific requirements apply to the processing of Consumer Health Data. Please review the “Information Collected” section of this Notice for more information on the collection, use, and sharing of Consumer Health Data.

Marketing, Cookies, and Tracking

We may use your contact details for marketing purposes and display advertisements to you that we believe are relevant. You can opt out of such communications or tracking through various methods detailed in this Notice.

We use cookies and similar tracking technologies to track the activity on our Online Services and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. They are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Online Services.

Types of Cookies Used:

• Essential Cookies: Necessary for the website to function and cannot be switched off in our systems.
• Performance Cookies: Allow us to count visits and traffic sources so we can measure and improve the performance of our site.
• Functionality Cookies: Enable the website to provide enhanced functionality and personalization.
• Targeting Cookies: May be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Online Services.

Third Parties

We may share your Personal Data with third parties, such as service providers acting on our behalf. These service providers must maintain confidentiality and process Personal Data as necessary to perform their functions.

Your Rights Regarding Your Personal Data

Depending on the state in which you reside, you may have rights regarding your Personal Data, or opting out of certain processing activities, including:

• Right to Access: You can request a copy of your Personal Data.
• Right to Rectification: You can request that we correct any inaccurate or incomplete data.
• Right to Erasure: You can ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
• Right to Restrict Processing: You can ask us to suspend the processing of your Personal Data.
• Right to Data Portability: You can request the transfer of your Personal Data to another party.
• Right to Object: You can object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party).

To exercise any of these rights, please contact us using the contact details provided in this Notice. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

Safeguarding Information

We take reasonable steps to protect Personal Data from loss, misuse, alteration, unauthorized access, and unauthorized disclosure.

How Long Your Personal Data Will Be Retained

We generally retain Personal Data for as long as needed for the specific business purposes for which it was collected or obtained, and per legal obligations.

Changes to This Privacy Notice

We reserve the right to change this Notice from time to time. It is recommended that you periodically revisit this Notice to learn of any changes.

Contact Us

If you have questions or comments about this Notice or how your Personal Data is processed, please contact us by email or mail at the details provided on our website.