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Op-T LLC - Privacy Policy

Last Updated: November 5, 2024

Op-T LLC (“Op-T,” “we” “us,” or “our”) is a clinical-stage biotechnology company that is researching autoimmune conditions to develop therapies for these diseases. This website provides information about our business and these development activities (this “site” and our “development activities” respectively.) This Privacy Policy is designed to help you understand how we collect, use, process and share your personal information, and to help you understand and exercise your privacy rights.

As used in this Privacy Policy, “personal information” has the meaning given to it under the law where you live, but typically refers to information that can be used to identify you as an individua; meanwhile our activities taken with respect to your personal information are referred to as “processing.” For residents of California and other U.S. states with special privacy rights, additional disclosures are available (below).

1. Scope and updates to this Privacy Policy

This Privacy Policy applies to all personal information processed by Op-T. By visiting or accessing this Site, you acknowledge and agree that you have read and understood this Privacy Policy.

Op-T may provide additional privacy notices to individuals at the time we collect their personal information. For example, we may provide a specific privacy notice to participants that describes our privacy practices in connection with conducting clinical trials or when you submit your information for recruitment to one of our clinical trials. These additional privacy notices may supplement this Privacy Policy or may apply in lieu of this Privacy Policy.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. If you continue to access the Site after the new Privacy Policy takes effect, we will assume you have read and acknowledged the new policy.

2. Personal Information that we collect

The types of personal information we collect vary depending on how you interact with us, our Site, and the requirements of applicable laws. We gather information you provide directly, information collected automatically when you use our Site, and data from third-party sources as outlined below.

A. Personal Information You Provide to Us
We may collect personal information through various interactions, including:

  • Account Creation: Details like your name, email address, and username when you create an account. You may also provide health, insurance, or financial information when participating in a promotion or support program.
  • Healthcare Professionals: If you’re a healthcare professional, we may collect your contact details, professional credentials, institutional affiliations, participation in our programs, publication history, photographs, prescribing practices, and details from agreements with us.
  • Clinical Trial Participants: If you join clinical trials we sponsor, personal information related to your participation may be collected by the clinical trial site, which could act as a separate “controller” or “business” of your data. We only access your information with your consent or as legally required.
  • Reporting Adverse Experiences: If you report an issue related to a clinical trial, we are required to collect specific details, potentially including sensitive health information, to address and report the incident appropriately.
  • Communications: We may gather your contact information, such as your email, phone number, or mailing address, if you request details about our company, product development, or to communicate with us.
  • Events: Personal information may be collected if you attend or register for conferences, trade shows, or other events we host or participate in.
  • Business and Partnerships: We may obtain data from individuals and third parties to explore and develop potential business opportunities.
  • Job Applications: When you apply for a job through our Site, we may collect your resume, cover letter, and any other application materials. If hired, your personal information will be governed by our employee privacy policy.

B. Information Collected Automatically
We may also collect certain data automatically when you use our Site:

  • Automatic Data Collection: This includes your IP address, user settings, cookie identifiers, mobile carrier, browser or device information, and location details (e.g., derived from your IP address). We also track how you use our Site, including pages viewed, links clicked, and engagement with content.
  • Cookie Policy and Technologies: We use cookies, pixel tags, and other technologies (“Technologies”) to enhance your experience and collect data automatically.
    • Cookies: Small text files stored on your device that help us remember your preferences and improve your experience.
    • Pixel Tags/Web Beacons: Code snippets on our Site or in emails that collect data about interactions, such as when a web page is visited or an email is opened.

Our use of these Technologies generally falls into these categories:

  • Operationally Necessary: To ensure access to our Site and its core functions, prevent fraud, enhance security, and detect irregular activity.
  • Performance-Related: To analyze and improve Site performance, helping us understand how visitors use our services.
  • Functionality-Related: To offer a better user experience by remembering your preferences, settings, and interactions.
  • Analytics: To process data about usage patterns, helping us optimize and personalize our digital services.

C. Personal Information Collected from Other Sources
We may obtain personal information about you from other sources, including through third-party services and organizations or individuals.

  • For example, if you access our Site through a third-party platform, such as an app store, a social networking site, or a third-party login service, we may collect personal information made available by that platform based on your privacy settings.
  • Additionally, if you are a healthcare professional or researcher, we may gather personal information from various sources. This may include your hospital affiliation, license details, areas of professional interest, and contact information, such as your address, email, and phone number, as well as any due diligence information relevant to our interactions.
  • Finally, we may also obtain personal information about you from other individuals. For instance, a spouse or family member might contact us to report a potential Adverse Experience you experienced in connection with a clinical trial we sponsor.

3. How we use your personal information

We collect and use your personal information for various business purposes, including to operate and enhance our Site, manage administrative functions, communicate about our Product Development Activities, and for other legitimate business purposes as permitted by law.

A. Supporting Our Product Development Activities and Site
We may use your personal information to support the operation and development of our Site, including:

  • Managing your account and personal information;
  • Granting access to specific areas, features, or functionalities of our Site;
  • Responding to your requests for support or assistance;
  • Communicating with you regarding our Site and Product Development Activities;
  • Undertaking activities to ensure the quality, safety, and integrity of our Site;
  • Processing your application if you apply for a job posted on our Site;
  • Allowing you to register for specific features or services.

B. Administrative Purposes
We may also use your personal information for administrative functions, such as:

  • Pursuing legitimate business interests, including research and development (e.g., pharmaceutical clinical trials and studies), network and information security, and fraud prevention;
  • Detecting and preventing security incidents, malicious activity, and illegal behavior, and taking legal action when necessary;
  • Measuring user engagement and interest in our Site;
  • Enhancing, upgrading, or improving the features of our Site;
  • Verifying your identity in connection with requests related to your rights under this Privacy Policy;
  • Meeting compliance obligations, such as gathering information from individuals who may have experienced Adverse Experiences during clinical trials we sponsor or are associated with;
  • Identifying and correcting technical issues with our Site through debugging;
  • Auditing our interactions, transactions, and other compliance activities;
  • Sharing personal information with third parties as necessary to provide our Site;
  • Enforcing our agreements and policies.

C. With Your Consent
We may also use your personal information for purposes disclosed to you at the time of collection or as authorized by you.

D. Other Purposes
In addition to the uses listed above, we may use your personal information for other purposes as permitted by applicable law or as requested by you. This includes creating de-identified or aggregated data. Please note that if we create or receive de-identified information, we will not attempt to re-identify it, except when required to comply with applicable laws.

4. How we disclose your personal information

We may disclose your personal information to third parties for various business purposes, such as providing our services, protecting ourselves or others, or in the event of a major business transaction, such as a merger, sale, or asset transfer, as detailed below.

A. To Support Our Site and Product Development Activities
We may share your personal information with the following categories of third parties:

  • Clinical Research Organizations (CROs): If you participate in clinical trials or research, the clinical trial sites may disclose personal information related to your participation to the CROs we have engaged to manage the research or conduct the trial. We do not typically collect clinical trial participant personal information directly, and any personal data we receive from CROs is de-identified or pseudonymized, unless an exception applies.
  • Service Providers: We may share your personal information with third-party vendors who assist us in providing our Site and Product Development Activities. For example, these service providers may offer IT support, hosting, research and development services, payment processing, customer support, and other related functions.
  • Business Partners: We may share your personal information with our business partners to fulfill your product or service requests. Additionally, we may share your information with partners with whom we jointly offer products or services.
  • Other Users or Third Parties You Interact With: As described in the “Personal Information We Collect” section, our Site may allow you to share personal information or interact with other users and third parties, including those who do not use our Site or the general public.

B. To Protect Ourselves or Others
We may access, preserve, and disclose personal information associated with you to third parties when we believe, in good faith, that it is necessary to:

  • Comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas;
  • Protect your, our, or others’ rights, property, or safety;
  • Enforce our policies or contracts;
  • Collect amounts owed to us;
  • Assist in the investigation or prosecution of suspected or actual illegal activities.
Additionally, we will disclose personal information when required for reporting Adverse Experiences to the relevant regulatory authorities.

C. Disclosure in the Event of Merger, Sale, or Asset Transfer
In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, asset sale, or transition of services to another provider, your personal information may be disclosed, sold, or transferred as part of such a transaction, as permitted by law or contractual obligations.

5. Your privacy choices and rights

Your Privacy Choices
The privacy choices available to you regarding your personal information are determined by applicable law and are outlined below.

Email Communications
If you receive unwanted emails from us, you can opt out by using the “unsubscribe” link at the bottom of the email. Please note that you may not be able to opt out of non-promotional communications, such as those regarding our Site or updates to our legal terms or Privacy Policy.

“Do Not Track” / Global Privacy Control
“Do Not Track” (DNT) is a privacy setting that users can enable in some web browsers to signal their preference not to be tracked online. Additionally, some browsers or plugins use the “Global Privacy Control” (GPC). For more information, visit https://globalprivacycontrol.org/. Please note, we do not currently respond to DNT signals or similar mechanisms transmitted by web browsers. To fully exercise your rights, you must separately opt out in each browser and on each device.

Your Privacy Rights
Depending on applicable law and our processing activities, you may have the following rights:

  • Access and Portability: You have the right to confirm whether we are processing your personal information, obtain access to or a copy of your personal information, and request an electronic copy of the data you have provided to us. You may also request that we send this information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”).
  • Correction: You can request the correction of any inaccurate or incomplete personal information. We may also provide tools that allow you to update your information directly.
  • Deletion: You may request the deletion of your personal information, subject to certain exceptions.
  • Withdrawal of Consent: You have the right to withdraw your consent for processing your personal information. Please note that this will only apply to future processing and will not affect the lawfulness of processing conducted before the withdrawal.
  • Non-Discriminatory Treatment: You are entitled to be free from discriminatory treatment for exercising any rights that are conferred upon you by applicable law.

Exercising Your Rights

  • Authorized Agent: Only you, or someone legally authorized to act on your behalf, can submit a verifiable request related to your personal information. You may also submit a request on behalf of your minor child. To authorize an agent, you must provide written authorization signed by both you and the agent. For further instructions, please refer to the “Contact Us” section.
  • Verification: To protect your privacy, we will take reasonable steps to verify your identity before processing your request. This may involve asking you to provide information to confirm your identity or to answer questions related to your account or use of our Site.
If you wish to exercise any of the above rights, please contact us using the details provided in the “Contact Us” section or as specified in any additional privacy notices provided at the time we collect your personal information. We will handle such requests in accordance with applicable laws.

6. Security of your information

We take measures to protect your information and ensure it is handled in accordance with this Privacy Policy. However, please note that no system is completely secure, and we cannot guarantee the absolute security of any information you provide to us. To the fullest extent allowed by applicable law, we are not responsible for any unauthorized access, use, disclosure, or loss of personal information.
By using our Site or providing personal information to us, you consent to receiving electronic communications regarding security, privacy, and administrative matters related to your use of our Site. In the event of a security breach, we will make reasonable efforts to notify you electronically, either by posting a notice on our Site, sending an email, or through postal mail.

7. International data transfers

Any information processed by us may be transferred, processed, and stored in locations around the world, including but not limited to the United States or other countries that may have data protection laws differing from those in your home country. We strive to protect your information in accordance with applicable legal requirements.
If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not have an adequate level of data protection as defined by relevant laws, we may use safeguards such as the EU Standard Contractual Clauses to support these transfers.

8. Retention of personal information

We retain the personal information we collect as outlined in this Privacy Policy for as long as you continue to use our Site or as necessary to fulfill the purposes for which it was collected. This includes providing our Site, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business interests, enforcing our agreements, and complying with applicable laws. Retention periods may also be based on other factors, such as the sensitivity and volume of the data. Additionally, we strive to retain all personal information in compliance with relevant legal requirements.

9. Information of minors

Our Site is not designed for individuals under the age of 18 (or the minimum age required by local law), and we do not intentionally collect personal information from children. If you are a parent or guardian and believe that your child has submitted personal information to our Site without your consent, please reach out to us as described in the “Contact Us” section below. If we discover that we have inadvertently collected personal information from a child in violation of applicable laws, we will take steps to delete that information unless we are legally obligated to retain it for purposes such as safeguarding our rights.

10. Third-party websites/applications

The Site may contain links to other websites or applications, and other websites or applications may reference or link to our Site. These third-party services operate independently and are not controlled by us. We encourage you to review the privacy policies of any website or application you interact with. We do not endorse, monitor, or approve the privacy practices or content of these external sites or applications and are not responsible for them. Sharing personal information with third-party websites or applications is done at your own risk.

11. Contact Us

Op-T is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy:

Please contact us at: privacy@op-t.com

12. Notice of collection & supplemental notice for residents of certain U.S. States

This Notice applies to residents of states that have enacted comprehensive privacy laws, as applicable to our Site and Product Development Activities (collectively referred to as “Applicable State Laws”).
In the past 12 months, we may have collected the following categories of personal information from you:

Personal Identifiers: Such as name, postal address, unique personal identifiers, or similar identifiers, protected classification characteristics, as defined under California or federal law, financial Information, employment Information, Internet or Other Electronic Network Activity Information.

Sensitive Personal Information: We may have also collected sensitive personal information, including health and disability details, medical information, health insurance information, and mental health data in connection with your employment or if you reported an Adverse Event. Any processing of sensitive personal information is performed solely for the purposes stated above, as permitted by law.

Collection: As outlined in the section “Personal Information We Collect,” we gather personal information through various sources, including directly from you (e.g., when you interact with us), automatically through your use of our Site (e.g., through cookies and other technologies), and from third parties (e.g., referrals).

Use: We use the personal information we collect as described in the “How We Use Your Personal Information” section.

Disclosure: Your personal information may be disclosed to the parties listed in the “How We Disclose Your Personal Information” section.

Sale and Sharing: We do not “sell” or “share” your personal information (for targeted advertising purposes), nor do we have actual knowledge of any such activity involving the personal information of minors under 16 years of age.

Data Retention: The criteria for determining how long we retain your personal information are outlined in the “Retention of Personal Information” section.

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