Privacy Policy - Alcyone Tx

Alcyone Therapeutics, Inc. Privacy Policy

Introduction

This Privacy Policy (the “Policy”) describes the type of information that Alcyone Therapeutics, Inc. (the “Company,” “we” or “us”) gathers from visitors to the Alcyone Therapeutics Website (the “Site”). The Site provides information about the Company’s business activities, and means through which interested users may learn more about Company.

Collection, Use, and Sharing of Personal Information

“Personal Information” means information that can be associated with a particular user. The chart below details what Personal Information we collect.

What Personal Information We Collect	How We Collect the Personal Information	Why We Collect the Personal Information
Information you provide directly.	You may include information that you select in using the “Contact Us” or similar features of the Site. We ask that users not include personal health information or similarly sensitive information in such communications.	We collect information to allow us to respond to inquiries and questions from users.
Collection of information regarding the use of the Site.	We may use cookies and similar tools (with the agreement of the user) in order to record how users interact with the Site.	We collect this information to improve the functionality of the Site.
Contact information for newsletters, updates, and similar.	We collect contact information (typically an email address) in order to provide the requested information.	We utilize contact information to deliver newsletters, updates, and other information requested by users.

We do not share this information, except as explained below under “Research Partners,” “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”

Third-Party Contractors – We may use contractors (“Service Providers”) to perform limited services on our behalf, such as hosting websites and providing email services. Service Providers are required to obtain only the Personal Information they need to deliver the service they were hired to perform, to maintain the confidentiality of Personal Information, and not to use Personal Information for any purpose other than the service they were hired to perform.

Business Transitions – We may share information with businesses that are legally part of the same group as the Company, or that become part of that group. We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Policy.

Compliance with Law and Prevention of Harm – We may disclose your Personal Information or any information submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, yourself or the public. We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Aggregated and De-identified Data – As noted above, this Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user. We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user. When that occurs, such information is no longer Personal Information.

No Sale of Personal Information – We do not sell Personal Information.

Use, Sharing, and/or Sale of Non-personal Information – We may aggregate data on user behavior with respect to the Site. This data does not enable identification of individual users and is not Personal Information as defined by this Policy. As such, our use, sharing, and/or sale of non-personal Information is not restricted by this Policy.

Additional Rights and Information for Users Residing in California

Users of the Site who reside in California have the right to request information about our collection, use, and disclosure of their information (a “Request to Know”), including:

the categories and specific pieces of Personal Information we have collected about the user;
the categories of sources from which we have collected the user’s Personal Information;
the business or commercial purpose for collecting or selling the user’s Personal Information;
the categories of Personal Information we have sold about the user; and
the categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.

Users of both the Site also have the right to request that we delete their Personal Information (a “Request to Delete”).

Requests to Know

Users may submit a Request to Know by emailing us at general@alcyonetx.com.

Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected about you in the past twelve months, and we have used and disclosed that Personal Information.

When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If you submit a Request to Know for the specific pieces of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.

If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information. If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity. We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.

If we provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.

Requests to Delete

Users may submit a Request to Delete by emailing us at general@alcyonetx.com. When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information. We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information. We will specify the manner in which we delete your Personal Information.

If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete.

Additional Rights and Information for Users Residing in the European Union and Switzerland

For users outside of the United States, we transfer data from outside countries – including the European Union and Switzerland – to data centers located in the United States for processing. Our processing of personal information is intended to be performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25, 2018 onward, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal information and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”). With respect to direct communications with EU residents, we provide the rights required by the GDPR and rely upon such residents’ consent and our legitimate interests in doing business with such residents. With respect to information we may receive from third-parties regarding an EU resident, we rely upon contractual provisions that are in accordance with the GDPR.

Please note that the European Commission has the power, pursuant to Article 45 of the GDPR, to determine whether the laws of a country outside the European Union provide an adequate level of data protection. To date, the European Commission has not determined that the state and federal laws of the United States provide European residents an adequate level of data protection.

If you are a resident of the European Union, you have several additional rights under the GDPR regarding personal information:

You have the right to request an accounting of all personal information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
You have the right to request that we change any personal information that pertains to you.
You have the right to request that we delete any personal information that pertains to you.

To request an accounting of your personal information, a change to your personal information, or deletion of your personal information, contact general@alcyonetx.com.

If you have a complaint about our use or processing of your personal information, you have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Protection and Retention of Personal Information

We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. The appropriate administrative, physical, and technical safeguards employed by us may vary depending on the nature of Personal Information collected, with more stringent measures applied to information of a sensitive nature.

However, no method of transmission over the Internet, or method of electronic storage, is entirely secure. Therefore, while we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. Please be aware that certain Personal Information and other information provided by you in connection with your use of the Site may be stored on your device (even if that information is not collected by us). You are solely responsible for maintaining the security of your device from unauthorized access.

Personal Information will be retained for as long as is reasonably necessary to achieve the purposes set forth in this Policy, and to comply with all applicable laws.

Other Provisions

Accessibility and Language – Any person that is unable to access this Policy through the Site may request this Policy in an alternative format or language by contacting us at general@alcyonetx.com.

International Users – The Company and its servers are located in the United States and are subject to applicable local, state, and federal laws. Users who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules and regulations. Users who choose to access the Site consent to the use and disclosure of information in accordance with this Policy and subject to such laws. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any other jurisdiction.

Children’s Privacy – The Site is neither directed to nor structured to attract Users under the age of 16. If you are under the age of 16, you are not permitted to use the Site. The Company does not knowingly collect Personal Information from users under the age of 16. If you are a parent with concerns about children’s privacy issues in conjunction with the use of the Site, please contact the Company at general@alcyonetx.com.

Do Not Track Signals and Collection of Information for Third-Party Advertising – The Company is required to disclose how it responds to “Do Not Track Signals” and whether third parties collect personally identifiable information about users when they use online services. The Company honors “do not track” signals and does not track, use cookies, or use advertising when a “do not track” mechanism is in place. The Company does not authorize the collection of personally identifiable information from our users for third-party use through advertising technologies.

Amendments – We may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by us, to this Privacy Policy, including in the way in which Personal Information is collected, used or transferred, we will notify you by e-mail to the address specified in your profile or by means of a notice on the Site prior to the change becoming effective.

Contact Information

If you have questions about this Policy, please contact us at general@alcyonetx.com.

Effective Date

The effective date of this Policy is July 1, 2022.