Privacy Policy
Effective Date: October 1, 2021
INTRODUCTION
Tryptamine Therapeutics Ltd. (“Tryp,” “us,” “our,” or “we”) recognizes that your personal privacy is important to you. This Privacy Policy (“Privacy Policy”) describes how we collect, process, and share your Personal Data (defined below) through our website at www.tryptherapeutics.com (the “Site”) and when you otherwise interact with us (collectively, our “Services”). We also describe your rights and choices with respect to your Personal Data and other important information. Please read this Privacy Policy carefully.
This Privacy Policy does not apply to any data collected by third parties you may encounter through our Services, which have their own privacy policies. Please review the separate privacy policies of any third parties before you provide information to them. This Privacy Policy also does not include any information collected if you participate in a clinical trial, which will be subject to a separate privacy notice and consent process. However, if you create an account with us to express your interest in a clinical trial, the account creation is subject to this Privacy Policy.
CATEGORIES AND SOURCES OF PERSONAL DATA
The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”):
The categories of Personal Data we may collect and use include (these are examples may be subject to change):
| Identity Data | Information such as your name; account details; user name and password; and your identity. |
| Contact Data | Identity Data that relates to information about how we can communicate with you, such as email, phone numbers, and mailing addresses. |
| Location Data | Information about your location, including data you provide to us, or location data we may infer from your IP address. |
| Device/Network Data | Browsing history, search history, and information regarding your interaction with our website or an advertisement (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs, embedded pixels, and pixel tags. |
| Commercial Data | Information about services we provide to you and about transactions you make with us, and similar information. |
| Inference Data | Personal Data we may infer based on your interactions with us or any data we may receive about you from third parties, such as our inferences regarding your interests based on your interactions with our website any User Content you provide to us, or otherwise. |
| Financial Data | Information such as bank account details or payment card information. |
| Health Data | Information relating to your health, such as if you indicate that you have a particular medical condition. We may infer Health Data based on your interest in a particular clinical trial. |
| User Content | Unstructured/free-form data that may include any category of Personal Data, e.g. data that you give us in free text fields such as comment boxes. Depending on the information you provide to us, this may include information relating to your health, which may be considered Special Category Data pursuant to various laws. |
Sources of Personal Data
We collect Personal Data from various sources, including:
| Data you provide us | We receive Personal Data you provide to us, such as when you create a customer account, complete a form on our Site, or when you join our email list. |
| Data we collect automatically | We collect Personal Data about or generated by any device you have used to access our Site. |
| Data we receive from service providers & Agents | We may receive Personal Data from service providers or agents performing services on our behalf, such as service providers who provide corporate communications services to Tryp. |
| Data we receive from aggregators and advertisers | We receive Personal Data from ad networks, behavioral advertising vendors, market research, and social media companies or similar companies that provide us with additional Personal Data such as Inference Data. |
| Data we receive from social media companies | We receive Personal Data from Facebook and other social media companies who may transfer Personal Data to us when you interact with that social media company in connection with our Services. |
| Data we create and infer | We, certain partners, social media companies, and third parties operating on our behalf create and infer Personal Data such as Inference Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. In some cases, we may make inferences regarding your health if you express interest in a particular clinical trial, or based on other User Content you provide to us. We may combine any Personal Data about you that we receive from you and from third parties. |
HOW WE PROCESS PERSONAL DATA
When you access or use our Site
When you use our Site, we automatically collect and process Device/Network Data. We use this data as necessary to initiate or provide certain features or functions through our Site. In addition to Device/Network Data, we may also collect and process Contact Data, Identity Data and Inference Data that we collect, create, and/or receive (including through the use of cookies and similar technologies). We typically use this data as necessary in connection with certain legitimate business interests, such as ensuring the security of our Site and other technology systems, and analyzing the use of our Site, to help us make improvements.
When you register for an account with us
When you register for an account with us, we generally process Identity Data and Contact Data. We may process this Personal Data to provide you with information about upcoming clinical trials or other information about our Services.
Cookies and other tracking technologies
We use cookies, web pixels, and similar technologies on our Site. These technologies can be used to collect or create Identity Data, Device/Network Data, Contact Data, or Inference Data. Third parties may be allowed to view, edit, or set their own cookies, web pixels or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of our websites, and some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in targeted advertising using this data. We and authorized third parties may use cookies and similar technologies for the following purposes:
- for “essential” or “functional” purposes, such as to enable certain features of our Site;
- for “analytics” purposes, such as to analyze the traffic to and usage of our Site;
- for “retargeting” or similar advertising or commercial purposes:
- for social media integration e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Site;
- to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising;
- to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website);
- identifying unique visitors to the Site; and
- to allow us to know when you visit our Site after clicking on one of our ads on social media or another website.
The use of these technologies by third parties may be subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.
When you contact us or submit information to us
We collect and process Identity Data, Contact Data, and any User Content you provide as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes.
How we Process Personal Data for Business Purposes
Service Provision and Contractual Obligations
We process any Personal Data as is necessary to provide our Services, to authenticate users who have accounts with us, and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request.
Internal Processing and Service Improvement
We may use any Personal Data in connection with improving our Site and email communications, for customer service purposes, to understand what parts of our Service are most relevant, how you interact with our Site, and how our Site performs.
Security and Incident Detection
We may process any Personal Data we collect in connection with detecting security incidents, or to protect against, and respond to malicious, deceptive, fraudulent, or illegal activity.
Legal Compliance
We also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials.
Aggregated data
We process Personal Data in order to identify trends (to create aggregated and anonymized data about our customers/users interests, use of our Services, and other similar information (“Aggregated Data”). We may pass Aggregated Data to certain third parties to give them a better understanding of our business and to improve our Site. Aggregated Data will not contain information from which you may be personally identified.
Other Business Purposes
If we process Personal Data in connection with our Service in a way not described in this Privacy Policy, we will process such information in accordance with the notice provided at the time of collection or in a manner that is necessary and proportionate to achieve the purpose for which the Personal Data was collected, or for another purpose that is compatible with the context in which the Personal Data was collected.
How we Process Personal Data for Commercial Purposes
Personalization & Consumer Profiles
In order to understand our customers’ preferences, and better recommend products and services to our prior customers, we may create a “Consumer Profile” by linking together and analyzing Personal Data collected in the following contexts:
- When you contact us or submit information to us
- When you register for a customer account
- When you access our Site
- When you subscribe to receive communications from us
- Cookies and other tracking technologies
We may also augment Consumer Profiles with Personal Data that we create (such as Inference Data) or that we receive from third parties. We use Consumer Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services. We may also use this information for other Commercial Purposes.
Marketing Communications
Consistent with our legitimate business interests, we or our third-party partners may send you marketing and promotional communications if you sign up for such communications. We may also collect Device/Network Data and Contact Data so that we can determine whether you have opened an email or interacted with our communications, and we may generate Inference Data based on these interactions. We may also process this Personal Data for targeted advertising. However, where consent to processing is required by law, we will link and process this information only with appropriate consent.
Targeted Advertising
We may engage in targeted advertising. This form of advertising includes various parties and services providers, including third parties, engaged in the processing of Personal Data in connection with advertising. These parties may be able to identify you across sites, devices, and over time. The parties that control the processing of Personal Data for behavioral advertising may create or leverage information derived from personalization and profiling. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether to advertise to you, and if ads you see are effective.
HOW WE SHARE PERSONAL DATA
| Affiliates | We may share Personal Data internally with our current and future affiliated entities. |
| Service Providers & Agents | In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests and business purposes, we may share your Personal Data with service providers who provide certain services or process data on our behalf. For example, we use third parties to host our Site and email server, provide cloud storage, send certain emails, process credit card payments, deliver packages. These companies only have access to personal information needed to perform their functions, but may not use it for other purposes. |
| Social Media Platforms | We may share certain Personal Data with current or future affiliated entities and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow third parties (such as social media advertisers, ad exchanges, data management platforms, or ad servers) to operate on our Services and process data for targeted advertising. |
| Corporate Events | Your Personal Data may be shared in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets |
| Legal Disclosures | In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use or an agreement we have with you, or in the vital interests of us or any person. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties. |
If we otherwise intend to disclose your Personal Data to a third party, if required by applicable law, we will identify that third party and the purpose for the disclosure, and obtain your consent.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
If you are located outside the US, your Personal Data may be transferred to and/or processed by Tryp or third parties in the US or another location, which may include locations outside of the European Economic Area (EEA) in connection with our Services. Some countries outside the EEA do not have laws that protect your privacy rights as extensively as those in the EEA. However, if we do transfer your Personal Data to other territories, we will put in place appropriate safeguards to ensure that your Personal Data are properly protected and processed only in accordance with this Privacy Policy. We may transfer Personal Data from the EEA to the US using the EU standard contractual clauses or other lawful mechanisms.
YOUR Rights and CHOICES
Marketing Communications
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails. Note that some non-marketing communications are not subject to general opt-out, such as communications related to your user account for this Site, transactions with Tryp and product and service updates.
Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you.
Tracking
Certain third parties may track your Internet usage over time and across third party sites. Our Services do not respond to your browser’s do-not-track request. If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.
Advertising
You may opt out or withdraw your consent to behavioral advertising. In some cases, we may be able to process third party opt-out requests directly, however in some cases, you must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choic…;or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp. You can limit or opt out of our processing for behavioral advertising by contacting us.
Other Data Rights
Depending on the location of your residence, you may have certain rights regarding your Personal Data. These may potentially include the right to make a written request to review any Personal Data we have about you that we have collected, used or disclosed, and the right to receive a copy of such Personal Data, or to have it deleted, and we will provide you with applicable data rights to the extent required by law. You may also have the right challenge the accuracy or completeness of your Personal Data in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.
ADDITIONAL RIGHTS AND DISCLOSURES: EU/EEA
Under the GDPR and analogous legislation, you may have the following rights, subject to your submission of an appropriately verified request:
| Access: | You may have a right to know what Personal Data we collect, use, disclose, or sell, and you may have the right to receive a list of that Personal Data and a list of the third parties (or categories of third parties) with whom we have received or shared Personal Data, to the extent required and permitted by law. You may be able to access some of the Personal Data we hold about you directly through the account settings menu. |
| Rectification: | You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided to us using the account settings menu. |
| Delete: | To the extent required by applicable law, you may request that we delete your Personal Data from our systems. We may delete your Personal Data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you. Contact us as part of your request to determine how your Personal Data will be erased in connection with your request. |
| Data Export: | To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice. |
| Objection: | You may have the right under applicable law to object to our processing of your Personal Data that we undertake without your consent in connection with our legitimate business interests (including any processing specified as such, or processed under this Privacy Policy for a Business Purpose). You may do so by contacting us. Note that we may not be required to cease, or limit processing based solely on that objection, and we may continue processing cases where our interests in processing are balanced against individuals’ privacy interests.You may also object to processing for direct marketing purposes. We will cease this processing upon your objection. |
| Regulator Contact: | You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority. |
Submission and Verification of Requests
You may submit any of the above requests by emailing privacy@tryptherapeutics.com. We verify requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your Personal Data. We recommend that you consult this page frequently so that you are aware of our latest Privacy Policy and can update your preferences if necessary. Your continued use of our Services shall constitute your acceptance of any revised Privacy Policy.
HOW TO CONTACT US
If you have any comments or questions about this Privacy Policy or privacy practices, please contact our team at privacy@tryptherapeutics.com.