Privacy Policy

Effective date: [Effective Date]

Thank you for visiting brixtonbio.com (the “Site”), owned and operated by Brixton Biosciences, Inc. (“Brixton Biosciences,” “we,” “us,” or “our”). Brixton Biosciences Brixton Biosciences is a life sciences company developing a novel, first-in-class nerve-selective biomaterial designed to provide targeted and durable relief from pain..

This Privacy Policy describes how we collect, use, and disclose Personal Data through the Site and through communications related to the Site, such as when you contact us with an inquiry (collectively, the “Services”). By using or accessing our Site, you acknowledge the practices and policies described in this Privacy Policy. Your use of the Site is also subject to our Terms of Use [LINK]. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Site, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

• Privacy Policy Table of Contents
• What this Privacy Policy Covers
• Personal Data
  • Categories of Personal Data We Collect
  • Our Commercial or Business Purposes for Collecting Personal Data
  • Other Permitted Purposes for Processing Personal Data
  • Categories of Sources of Personal Data
• How We Disclose Your Personal Data
• Cookies and Similar Technologies
• Data Security
• Data Retention
• Personal Data of Children
• Third-Party Links
• Your Choices and Privacy Rights
• Contact Information
• What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy applies only to the Services. It does not apply to information processed in connection with the use of our therapies, patient care, clinical activities or research, employment, or other activities outside the Services. This Privacy Policy also does not cover the practices of companies we don’t own or control or people we don’t manage. Please do not submit health information, patient information, medical images, or other sensitive information through the Site or in your communications with us through the Site.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect through the Services:

Category of Personal Data (and Examples)	Business or Commercial Purpose(s) for Collection	Categories of Third Parties With Whom We Disclose this Personal Data
Device/IP Data such as IP address, general location derived from IP address, device ID, and type of device, operating system, or browser used to access the Services.	·  Monitoring, testing, and improving the security, integrity, and availability of our Services. ·  Analyzing how you interact and engage with the Services	·  Service Providers
Web Analytics such as web page interactions, referring webpage or source through which you accessed the Services, and statistics associated with the interaction between device or browser and the Services.	·  Monitoring, testing, and improving the security, integrity, and availability of our Services. ·  Analyzing how you interact and engage with the Services.	·  Service Providers
Contact and Inquiry Information such as your name, email address, phone number, company or organization, job title, and the content of emails or other communications you send us, including through our contact form.	·  Providing, Customizing and Improving the Services ·  Marketing the Services ·  Corresponding with You	·  Service Providers

 

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Providing you with the information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Improving the Services, including through internal analytics.
  • Doing fraud protection, security and debugging.
• Marketing the Services
  • Sending you information about Brixton Biosciences and our technology, where permitted by applicable law.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Company or the Services.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Brixton Biosciences or another party; enforcing any agreements with you; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you submit an inquiry or other information through the Site, such as through our contact form.
    • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
    • Through Cookies (defined in the “Cookies and Similar Technologies” section below).
  • Third Parties
    • Vendors
      • We may use service providers, such as analytics providers and website hosting providers, that collect information on our behalf in connection with the Services.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Analytics providers regarding web traffic or usage of the Services.
  • Marketing providers, such as email communication providers.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Cookies and Similar Technologies

The Site may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services.

The Services do not currently respond to “Do Not Track” signals sent from a browser.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for the Site to function or to provide features you request. Disabling these Cookies may make certain features unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services and maintain your preferences over time (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You can opt out of Google Analytics by using the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking [To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. However, no method of transmitting data over the internet or storing data is completely secure, and we cannot guarantee the security of your Personal Data.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations or resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

We do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as required by applicable law. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at info@brixtonbio.com.

Third-Party Links

The Services may contain links to third-party websites or services, such as social media pages, that we do not own or control. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

Your Choices and Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@brixtonbio.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of website and web applications and services that you do not wish such operators to track certain of your online activities over time and across different website. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Brixton Biosciences, Inc.

info@brixtonbio.com