Aspen Neuroscience, Inc. (“Aspen,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information through aspenneuroscience.com and any Aspen webpages that link to this Privacy Policy (collectively, the “Website”).

Aspen Neuroscience, Inc. is located at 10835 Road to the Cure, Suite 100, San Diego, California 92121.

This Privacy Policy applies only to the Website. It does not govern information collected in connection with clinical trials, patient screening, healthcare services, employment, or other activities governed by a separate privacy notice or consent form.

1. Personal Information We Collect

Depending on how you interact with the Website, we may collect the following categories of personal information:

Information You Provide

We may collect information you provide through the Website or when communicating with us, such as:

  • name;
  • email address, telephone number, and other contact information;
  • company, organization, professional title, or affiliation;
  • the contents of messages, inquiries, or other communications;
  • information submitted in connection with investor-relations inquiries;
  • information submitted when expressing interest in employment or other opportunities; and
  • other information you choose to provide.

Please do not submit medical records, genetic information, sensitive health information, or other sensitive personal information through a general Website contact form unless Aspen expressly requests that information through an authorized process.

Information Collected Automatically

When you use the Website, Aspen and its service providers may automatically collect:

  • Internet Protocol address;
  • browser type and version;
  • device type and operating system;
  • referring and exit pages;
  • pages viewed and links selected;
  • date and time of access;
  • approximate location derived from an Internet Protocol address;
  • cookie and similar-technology identifiers; and
  • information concerning Website performance and interactions.

Aspen will update this section if the Website collects additional categories of information.

2. How We Use Personal Information

We may use personal information to:

  • operate, maintain, secure, and improve the Website;
  • respond to questions, requests, and other communications;
  • provide information requested by Website visitors;
  • administer investor, corporate, recruiting, or business communications;
  • understand Website use and performance;
  • diagnose technical and security issues;
  • prevent fraud, misuse, and unauthorized access;
  • protect Aspen’s rights, property, personnel, and users;
  • comply with applicable law and legal process; and
  • establish, exercise, or defend legal claims.

We will not use information collected through the Website for materially different purposes without providing any notice or obtaining any consent required by applicable law.

3. Cookies and Similar Technologies

The Website may use cookies, pixels, tags, local storage, and similar technologies. A cookie is a small text file placed on a device when a person visits a website.

We may use the following categories of cookies:

Strictly Necessary Cookies

These cookies support functions necessary to operate or secure the Website or provide a service requested by the user. They may support functions such as security, network management, page navigation, load balancing, and recording privacy choices. Because these cookies are necessary to provide the relevant functionality, they generally cannot be disabled through a cookie-consent tool.

Functional Cookies

These cookies remember choices or settings and may enable enhanced Website functionality. If these cookies are disabled, some features may not operate as intended.

Analytics or Performance Cookies

Subject to applicable consent requirements, these cookies help us understand Website traffic, interactions, and performance. Aspen may use Google Analytics or another analytics provider for these purposes. Analytics cookies will be listed in the Website’s cookie-management tool or cookie table if implemented.

Advertising or Targeting Cookies

Aspen does not presently intend to use advertising or targeting cookies unless they are identified in the Website’s cookie-management tool or cookie table. If such technologies are implemented, Aspen will provide any choices required by applicable law.

Some Website features or third-party tools, including an accessibility tool, may place cookies or use similar technologies. Their classification will depend on their actual function. Aspen will classify and disclose such technologies after reviewing the applicable vendor documentation and Website scan.

Managing Cookie Choices

Where a cookie-management tool is available, visitors may use it to accept or reject non-essential cookies and revise their preferences. A cookie used to remember a visitor’s privacy preferences may remain on the device because it is necessary to honor those choices.

Visitors may also configure their browsers to delete or block cookies. Blocking certain cookies may impair Website functionality.

Aspen will maintain or link to a cookie list identifying applicable cookies, providers, purposes, categories, and durations after the Website configuration is finalized.

4. How We Disclose Personal Information

We may disclose personal information to:

  • Service providers, including providers of website hosting, content delivery, security, analytics, communications, investor-relations, recruiting, accessibility, and cookie-management services;
  • Professional advisers, including attorneys, accountants, auditors, insurers, and consultants;
  • Corporate counterparties, in connection with a merger, financing, acquisition, reorganization, sale of assets, collaboration, bankruptcy, or similar transaction;
  • Governmental and legal authorities, when disclosure is required or permitted by law or reasonably necessary to protect rights, safety, property, or security; and
  • Other parties at your direction or with your consent.

Service providers are authorized to process personal information for the services they provide to Aspen, subject to applicable contractual and legal requirements.

5. Sale, Sharing, and Targeted Advertising

Based on the Website practices currently contemplated, Aspen does not sell personal information for money.

Whether a particular analytics or advertising integration constitutes “selling,” “sharing,” or targeted advertising under an applicable state privacy law depends on the technology’s configuration and use. Aspen will assess the final Website configuration and provide any required opt-out mechanism before deploying technology used for cross-context behavioral advertising or similar purposes.

6. Data Retention

Aspen retains personal information for as long as reasonably necessary for the purpose for which it was collected, including to respond to requests, maintain business and legal records, protect the Website, comply with law, and establish or defend legal claims.

The criteria used to determine retention periods may include:

  • the nature and sensitivity of the information;
  • the duration of Aspen’s relationship or interaction with the individual;
  • operational and security requirements;
  • applicable limitation periods; and
  • legal, regulatory, contractual, and recordkeeping obligations.

7. Data Security

Aspen uses administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, however, and Aspen cannot guarantee absolute security.

8. Children’s Privacy

The Website is intended for adults and is not directed to children under 13. Aspen does not knowingly collect personal information through the Website from children under 13. If you believe a child has provided personal information through the Website, please contact us using the information below.

9. U.S. State Privacy Rights

Residents of certain U.S. states may have rights concerning their personal information, subject to applicable thresholds, definitions, exceptions, and verification requirements. Depending on applicable law, these rights may include the right to:

  • confirm whether Aspen processes personal information;
  • access or obtain a copy of personal information;
  • correct inaccurate personal information;
  • delete certain personal information;
  • obtain certain information in a portable format;
  • opt out of the sale or sharing of personal information;
  • opt out of targeted advertising or certain profiling;
  • limit certain uses or disclosures of sensitive personal information;
  • receive equal service and not be unlawfully discriminated against for exercising privacy rights; and
  • appeal a denial of a privacy request.

To submit a request, contact Aspen using the information in Section 14. Aspen may need to verify your identity and authority before completing a request. Applicable law may permit an authorized agent to submit a request on your behalf, subject to verification of the agent’s authority and your identity.

Aspen will not discriminate against you for exercising an applicable privacy right.

Aspen will supplement this section, including with any required request form, telephone number, appeals procedure, or opt-out link, after confirming which state laws apply and finalizing the Website’s data practices.

10. California Residents

Subject to the applicability of California law and relevant exceptions, California residents may have the right to request:

  • the categories and specific pieces of personal information Aspen has collected about them;
  • the categories of sources from which personal information was collected;
  • the purposes for collecting, using, selling, or sharing personal information;
  • the categories of third parties to whom personal information was disclosed;
  • correction of inaccurate personal information;
  • deletion of certain personal information; and
  • information about, or the ability to opt out of, certain sales or sharing of personal information.

Aspen does not knowingly sell or share the personal information of consumers under 16.

This Website notice does not state that Aspen collects government identification numbers, biometric identifiers, precise geolocation, genetic information, or detailed health information unless the final Website inventory confirms that Aspen collects such information through the Website.

11. Visitors in the European Economic Area and United Kingdom

If applicable data-protection law governs Aspen’s processing of your personal information, Aspen processes personal information under one or more of the following legal bases:

  • Legitimate interests, such as operating, securing, evaluating, and improving the Website; communicating with Website visitors; and protecting Aspen’s legal and business interests, where those interests are not overridden by applicable individual rights;
  • Consent, including for non-essential cookies where consent is required;
  • Legal obligations, when processing is necessary to comply with applicable law; and
  • Contractual necessity, when processing is necessary to take requested steps before entering into, or to perform, an agreement.

Depending on applicable law, you may have rights to access, correct, delete, restrict, or object to processing of your personal information; receive certain information in a portable format; withdraw consent; and lodge a complaint with a competent supervisory authority. Withdrawal of consent does not affect processing lawfully performed before withdrawal.

Personal information may be processed in the United States or another country whose laws may differ from those where you reside. Where required, Aspen will use an approved transfer mechanism or other legally recognized safeguard. The mechanism applicable to a particular transfer will depend on the service provider and transfer arrangement.

12. Third-Party Websites and Services

The Website may link to websites or services operated by third parties. Aspen does not control their privacy or security practices. You should review the privacy policies of those third parties before providing personal information.

13. Changes to This Privacy Policy

Aspen may update this Privacy Policy from time to time. Aspen will post the revised policy on the Website and revise the “Last Updated” date. Aspen will provide additional notice or obtain consent if required by applicable law.

14. Contact Us

Questions or requests concerning this Privacy Policy may be directed to:

Aspen Neuroscience, Inc.
10835 Road to the Cure, Suite 100
San Diego, CA 92121
Email: [privacy email address]
Telephone: [privacy telephone number, if applicable]