Privacy Policy

Volastra Therapeutics, Inc. (“Volastra”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This notice describes our privacy policy (“Policy”) for the “www.volastratx.com” website (the “Site”), as well as information that we collect offline in the ordinary course of business (collectively, the “Services”).

Please note that any information we collect from or about clinical trial participants is not governed by this Policy. It is governed by the documents related to the specific clinical study itself, including any relevant informed consent forms.

Information We Collect And How We Use It

We collect both “Personal Information” and “Other Information”. For purposes of this Policy, “Other Information” is information that we cannot directly associate with a specific person without the aid of additional information. In contrast, “Personal Information,” is information such as a name or email address that we can directly associate with a specific person or entity without additional information. When we combine Other Information with Personal Information, we treat all of the combined information as Personal Information.

We collect some of this information by requesting it directly from you, and we collect additional information automatically when you access our Site.

Personal Information through our offline Services. In the ordinary course of business, we may collect personal information about our business contacts, including the clinical investigators that we work with. This information may include your name, contact information, and information about your company.

Personal Information from Site visitors. You can visit the Site without submitting any Personal Information. However, if you use certain features on the Site, you may be asked to register as a user. The Personal Information you may need to provide to register includes, for example, your name and email address. Our primary purpose in collecting Personal Information is to provide you with an efficient and secure way to obtain information about Volastra, such as to respond to your inquiry, send you news alerts or to consider your qualifications for a position at Volastra. We collect personal information about you that we consider necessary for achieving these purposes. We may combine Personal Information collected through the Site with additional information that we or third parties collect about you in other contexts—such as our communications with you via email. We will treat such combined information as Personal Information and protect it in accordance with this Policy.

We may track certain information based upon your behavior on the Site. We use this information to analyze how our Site is used.

Web log data. When you use the Site, we may automatically receive and record certain information from your computer (or other device) and your browser. This information may include your IP address and domain name, the pages you visit and content that your select to view on the Site, the dates and times of your visits, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including browser type, operating system, and device type), your approximate geographic location (e.g., your city, state, or metropolitan region), GPS coordinates (subject to your opting in) and certain cookie information (see “Cookies” below). To obtain this information, we use web logs or similar applications that recognize your computer and gather information about its online activity.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

SDKs and mobile advertising IDs. Our Site may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about Site visitor activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify visitors over time for advertising purposes.

Cookies. We also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and additional information. Cookies cannot read your data off of your hard drive. For example, cookies can be used to collect information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

Flash cookies. Where we use Macromedia Flash to display video content on our Site, a special type of cookie (or “local shared object”) called a Flash Cookie may be used. These cookies are used to store your flash player preferences and enhance your browsing experience. Flash Cookies are stored on your computer in a similar way to standard cookies, except they are stored in a different location. Due to this, it is not always possible to block or manage Flash Cookies directly from your browser. In order to manage or delete Flash Cookies, you may visit Adobe’s Flash privacy page for more information. However, some of the interactive tools will not work properly if Flash cookies are disabled.

Where We Store Your Information

The Personal and Other Information that we collect about you is controlled by Volastra Therapeutics, Inc., which is headquartered in the United States at [1361 Amsterdam Ave Suite 520, New York, NY 10027]. As a result, such information may be transferred to and processed in the United States, as described in the section below titled “Information for Site users from outside the United States.”

How We Use Personal and Other Information

We use the information that we collect for a variety of purposes. If we have Personal Information about you, we may use it, for example: to respond to your questions or to fulfill your requests; to fulfill the terms of any agreement you have with us; to improve your user experience on our Site; to comply with legal and/or regulatory requirements; and to manage our business.

We use the Other Information that we collect for such purposes as: counting and recognizing returning visitors to the Site; analyzing how visitors use and interact the Site and various Site features; improving the Site and enhancing users’ experiences; customizing and evaluating content, features, and multimedia on our Site; creating or improving our products, services and information available through the Site; enabling additional website analytics and research concerning the Site; engaging in online behavioral advertising; and managing our business.

Corporate communications. We may use the Personal and Other Information that we collect to send you promotional communications, including emails or postal mail about the products and services offered by us or our affiliates or partners. Promotional emails will also contain instructions for opting out of future issues of that type of communication. If you no longer wish to receive our news alerts and informational materials, you may opt-out of receiving them by following the instructions included in each email notifying you of an alert.

How We Share Personal and Other Information

We share your Personal Information and Other Information with other parties for the purposes described below.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

Interest-Based Advertising.  The Site also enables third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising.  For example, third parties may use the fact that you visited our Site to target online ads to you.  In addition, our third-party advertising networks might use information about your use of our Site to help target advertisements based on your online activity in general.  For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy.  If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies.  Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here.  Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

Third-party service providers and business partners. We use other third-party service providers to help us manage and improve the Site. These service providers may collect and/or use your Personal or Other Information to assist us in achieving the purposes discussed above in the section entitled “How We Use Personal and Other Information.” We use third-party platforms to help us manage our relationships with our customers and to provide features, functionality, or other offers.

We may share your Personal or Other Information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our affiliates or partners; or to manage our business.

Legal purposes. We also may use or share your Personal or Other Information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate a merger, acquisition, financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information. We may share aggregated demographic information about our user base with third parties that may or may not be affiliated with us, but this information does not identify individual users. We do not link aggregate user data with personally identifiable information.

When we share personally identifiable information with Third Parties, we disclose information as needed for these services providers to perform their functions, but do not authorize the service providers to use the information for other purposes.

We may also disclose personal information in accordance with any notice provided to you at the time such information is collected, or as you otherwise authorize.

Links To Other Sites

This privacy policy applies only to information collected by the Site. The Site contains links to other sites that are not owned or controlled by Volastra. Please be aware that we are not responsible for the privacy policies of such other sites. We encourage you to be aware when you leave the Site and to read the privacy policies of each and every web site that collects personally identifiable information.

Your Rights and Choices

We provide you with choices to review, access, update, and delete your information. You may also have additional rights available to you depending on your jurisdiction. To make a privacy request or exercise your rights, please send us an email at info@volastratx.com with “Attn: Privacy” in the subject line. For your protection, we may only implement requests related to information that we have associated with the email address you use to send us your request, and we may need to verify your identity before implementing your request.

Additionally, if you no longer want to receive communications from us, each of our email communications will contain instructions for opting out of future issues of that type of communication. You may also send an opt-out request to us at the address provided above.

Data Security and Retention

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, and we cannot guarantee its absolute security.

We retain your information for as long as reasonably necessary for our legitimate business purposes, to provide the Site to you, to fulfill the purposes described in this Policy, or as required by law.

Information collected from outside the United States

The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above.  We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.

Children’s Privacy

The Services are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws. We request that such individuals do not provide information to us through the Services.

Changes In This Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make changes that materially affect our uses or disclosures of personally identifiable information that we have previously collected, we will announce the changes on our Site or, if appropriate, by email.

Questions or Comments

If you have any questions or comments regarding this Policy, please mail or email us at:

1361 Amsterdam Ave Suite 520, New York, NY 10027

Or info@volastratx.com (please include “Attn: Privacy” in the subject line)

 

Effective Date: 2022-07-28