Privacy - Sling Therapeutics

Sling Therapeutics, Inc. (the “Company,” “we,” “us,” or “our“) takes the privacy and security of personal information, including information related to our patients, their caregivers, healthcare professionals, our employees, Site users, investors, and other third parties seriously. This privacy notice describes how and why we, as a controller, might collect, store, use, and/or share (“process“) your information when you use our Site (“Site“).

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Site. Personal Information does not include, and this Privacy Notice does not apply to, aggregate information or information that has been de-identified or anonymized in accordance with applicable law. Any specific privacy notice will be delivered to the data subjects for that specific purpose(s). This is a notice of our privacy practices; it does not create any agreement between the parties.

To review our Supplemental Privacy Notice for California, Virginia, and other U.S. State Residents, please see below.

1. HOW DO WE COLLECT OR OBTAIN PERSONAL INFORMATION ABOUT YOU? We may collect or obtain personal information directly from you or someone acting on your behalf; from your healthcare provider, including hospitals, doctors, and other healthcare professionals; from contract research organizations and clinical investigators; from third-party service providers and business partners; from public databases, marketing partners, social media platforms, and other outside sources; through our Site or social media; and automatically through cookies or other technologies.

2. WHY WE PROCESS AND WHAT PERSONAL INFORMATION DO WE COLLECT AND USE? (If applicable laws require a “legal basis” to process personal information, we indicate our legal bases applicable for only for those jurisdictions. The legal bases provided herein do not apply in any jurisdictions not requiring such.)

With your consent or the consent of your parent or legal guardian:

Collect information from and about you (where consent is required under applicable law) for internal and external use. We may use your contact information, photographs, audio, video, and sensitive information, such as health information and physical characteristics.
Evaluate job candidates, including receiving and reviewing any job applications, obtaining information from you, external recruiters, or websites, talking to references, and performing legally permissible background checks. We use your contact information, employment-related information, education, and any other information you share.

In accordance with our Legitimate Interests:

Personal information you disclose to us. We collect your contact information and other personal information that you or someone acting on your behalf provide to us from your inquiries or our interaction with you. We request that you do not share any sensitive or health information with us unless we request it under obligations under law.
Operating and administering our business, including but not limited to supporting safe, responsible, compliant, and ethical business and commercial operations; facilitating quality and safety of our products and research; conducting audits and investigations; managing our financial and other accounts; developing and improving our products; etc. We may use any contact information, background information, education history, and photographs, video, audio information, and any other applicable personal information.
Identifying potential candidates for recruitment via online or public sources. We may use your contact information, professional or employment-related information, education history, and demographic information.
Operating the Site, including automatically collecting information when you visit, use, or navigate the Site in order to maintain and enhance the Site and the user experience, to maintain the security and operation of the Site, and for our internal analytics and reporting purposes. We may use device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, other technical information, dates/times you access the Site, and other information about your interactions with the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. We can collect such information through cookies and other tracking technologies, for more information please see our “Cookies and Other Tracking Technologies” section below.

Related to a contract (including pre-entering of a contract) between us:

Hiring you to provide services or partner with you. We may use your contact information and financial information.
Other contractual interactions.

When required by law:

Monitoring and reporting pharmacovigilance and product safety, quality, and complaints as part of our clinical research. We may use your contact information, health information, and physical characteristics.
Ensuring compliance with applicable laws and regulations. We may use your contact information and financial information.
Responding to legal inquiries, requests, and summons. We may use your contact information, employment-related information, financial information, contractual information, and other information.

Due to the nature of our business, we may be subject to a number of legal requirements, thus requiring us to process personal information and sensitive information (including health information) to meet these requirements. When permissible under law, we will attempt to limit and protect the confidentiality of your personal information to the extent possible, for example de-identifying or anonymizing information, while still complying with our legal obligations.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations described in this section and/or with the following third parties:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners, including but not limited to research collaborators, co-developers, and license partners.
Vendors and service providers working on our behalf to provide us with services, data storage, Information Technology and data security, legal services, etc.
Government or law enforcement agencies (where required or permitted by applicable laws, court orders, or government regulations).
Third parties to protect rights and interests, including when needed for audits, investigations, or to respond to inquiries/complaints, etc.
With your consent or as directed by you.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may process your personal information automatically through the use cookies and other tracking technologies to collect and store your information through the following:

Cookies: A cookie is a small block of data placed, and sometimes stored, on your computer when you access certain websites. Your browsers may be set-up to automatically accept cookies, however, you can change your browser settings at any time to deny all cookies or specific types of cookies. Please note that if you deny certain cookies on the Site, we cannot guarantee that the Site will be fully functional.
Web Beacons: A web beacon allows us to see what you have accessed on the Site. We may use web beacons or pixels to help assess the response of our communications or user interactions with our Site.
Analytics: Website Analytics help measure, collect, analyze, and report on the Site usage to better optimize and enhance the Site and to understand user preferences. We use Google Analytics on the Site. To learn more about Google’s privacy practices, please review the Google Privacy Policy. To prevent Google Analytics from using your information for analytics, you can install the Google Analytics Opt-Out Browser Add-on here.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

We may transfer, store, and process your information in countries other than your own. We are located in the United States, which may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. If you are accessing our Site from outside of the United States, please be aware that your information will be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), Switzerland or other countries, we will take the necessary measures to protect your personal information in accordance with this privacy notice and applicable law. To comply with legal requirements for data transfers to the United States, we use data transfer mechanisms permitted under applicable laws, including but not limited to standard contractual clauses.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 18, please contact us at contact@slingtx.com.

8. HOW DO WE SECURE YOUR PERSONAL INFORMATION?

Securing your Personal Information is important to us, which is why we maintain privacy and security measures and controls designed to help protect your personal information. No security measure, however, is 100% effective and we cannot guarantee total security of your personal information. Please take steps to protect yourself, including using and protecting your unique login credentials and passwords, utilizing encryption, personal firewalls, and anti-virus solutions.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Many jurisdictions, including certain U.S. States, afford data subject rights. We comply with any applicable laws permitting data subject rights and will honor requests according to applicable laws. Depending on your jurisdiction, your rights may include the following:

You may opt-out of communications from us at any time by following our opt-out instructions in the communication. We may still need to send you important administrative messages even if you opt out of receiving communications.
To the extent provided under applicable law, you may request access to, correction of, opt-out of, deletion of, restriction of, or object to the processing of your personal information. In addition, you may request that you obtain a portable copy of your personal information.
Withdrawing your consent, if we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Automated decision making. We do not engage in any automated decision making.

If you would at any time like to invoke your data subject rights, you can contact us at contact@slingtx.com. You may also have the right to lodge a complaint with your Supervisory Authority, if applicable, available here.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. To learn more about how to exercise your choice regarding the collection of information about your online activities over time and across third-party websites or online services by visiting http://www.aboutads.info/ and http://www.networkadvertising.org/.

11. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by post at:

Sling Therapeutics

455 E. Eisenhower Pkwy
Suite 300 PMB1048
Ann Arbor, MI 48108

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA AND CERTAIN OTHER U.S. STATE RESIDENTS

This Supplemental Notice of Privacy Practices (“Supplemental Notice”) describes how we process personal information of consumers residing in California and certain other U.S. States. This notice only applies to the extent you are a resident of a U.S. State with applicable laws in effect.

We do not sell Personal Information as the term “sell” is traditionally understood or defined as a “sale” or “sharing” under applicable California privacy laws or regulations. We do not knowingly sell the Personal Information of consumers under 16 years of age.

HOW DO WE COLLECT OR OBTAIN PERSONAL INFORMATION ABOUT YOU? We may collect or obtain personal information directly from you or someone acting on your behalf; from your healthcare provider, including hospitals, doctors, and other healthcare professionals; from contract research organizations and clinical investigators; from third-party service providers and business partners; from public databases, marketing partners, social media platforms, and other outside sources; through our Site or social media; and automatically through cookies or other technologies.

WHAT TYPES OF PERSONAL INFORMATION DO WE PROCESS

During the last 12-months, we may use the following personal information about you (below is not a full accounting of the data related to any category):

Contact information: name, address, email address, phone number, date of birth, and other similar contact information.
Health information: health statistics, tests, results, diseases, symptoms, therapies, medications, patient or research study id, outcomes, barriers to access, insurance information, and dates of service.
Mental and physical characteristics: eye color, height, weight, attitude, and emotions.
Employment information: employer, job title, specialty, employment history, awards and honors, membership in professional organizations, speaking engagements, and affiliations with patient advocacy organizations.
Education history: degrees, level of education attained, institutions attended, majors and areas of study, and grades.
Job candidates and recruitment related information: social security number; government issued identification number; interview information and notes; employment information; employee termination information; race or ethnic origin; credit history; criminal history; immigration status, work permit status; and other appropriate information.
Photograph, audio, or video information.
System Account information: username and password.
Financial information: bank account information, credit card number, and bank accounts.
Inferences: notes about preferences and aptitudes.
Opinions or statements: publicly available social media posts and opinions.
Internet or other electronic network activity information: IP address, country or geographic region location, browser type, device type, operating system, dates, and times you access our services, browsing history, and other information about your interactions with our online services. We collect such information through cookies and other tracking technologies.

WHY WE PROCESS AND WHAT PERSONAL INFORMATION DO WE COLLECT AND USE?

Collect information from and about you for internal and external use. We may use your contact information, photographs, audio, video, and sensitive information, such as health information and physical characteristics.
Evaluate job candidates, including receiving and reviewing any job applications, obtaining information from you, external recruiters, or websites, talking to references, and performing legally permissible background checks. We use your contact information, employment-related information, education, and any other information you share.
Personal information you disclose to us. We collect your contact information and other personal information that you or someone acting on your behalf provide to us from your inquiries or our interaction with you. We request that you do not share any sensitive or health information with us unless we request it under obligations under law.
Operating and administering our business, including but not limited to supporting safe, responsible, compliant, and ethical business and commercial operations; facilitating quality and safety of our products and research; conducting audits and investigations; managing our financial and other accounts; developing and improving our products; etc. We may use any of the categories of Personal Information, including but not limited to contact information, background information, education history, and photographs, video, and audio information.
Identifying potential candidates for recruitment via online or public sources. We may use your contact information, professional or employment-related information, education history, and demographic information.
Operating the Site, including automatically collecting information when you visit, use, or navigate the Site in order to maintain and enhance the Site and the user experience, to maintain the security and operation of the Site, and for our internal analytics and reporting purposes. We may use device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, other technical information, dates/times you access our services, and other information about your interactions with the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. We can collect such information through cookies and other tracking technologies.
Hiring you to provide services or partner with you. We may use your contact information and financial information.
Other contractual interactions.
Monitoring and reporting pharmacovigilance and product safety, quality, and complaints as part of our clinical research. We may use your contact information, health information, and physical characteristics.
Ensuring compliance with applicable laws and regulations. We may use your contact information and financial information.
Responding to legal inquiries, requests, and summons. We may use your contact information, employment-related information, financial information, contractual information, and other information.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may process your personal information automatically through the use cookies and other tracking technologies to collect and store your information through the following:

Cookies: A cookie is a small block of data placed, and sometimes stored, on your computer when you access certain websites. Your browsers may be set-up to automatically accept cookies, however, you can change your browser settings at any time to deny all cookies or specific types of cookies. Please note that if you deny certain cookies on the Site, we cannot guarantee that the Site will be fully functional.
Web Beacons: A web beacon allows us to see what you have accessed on the Site. We may use web beacons or pixels to help assess the response of our communications or user interactions with our Site.
Analytics: Website Analytics help measure, collect, analyze, and report on the Site usage to better optimize and enhance the Site and to understand user preferences. We use Google Analytics on the Site. To learn more about Google’s privacy practices, please review the Google Privacy Policy. To prevent Google Analytics from using your information for analytics, you can install the Google Analytics Opt-Out Browser Add-on here.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share informationin specific situations described in this section and/or with the following third parties:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners, including but not limited to research collaborators, co-developers, and license partners, to offer you certain products, services, or promotions.
Vendors and service providers working on our behalf to provide us with services, data storage, Information Technology and data security, legal services, etc.
Government or law enforcement agencies (where required or permitted by applicable laws, court orders, or government regulations).
Third parties to protect rights and interests, including when needed for audits, investigations, or to respond to inquiries/complaints, etc.
With your consent or as directed by you.

DATA SUBJECT RIGHTS

Certain U.S. States afford data subject rights, including but not limited to California, which grants consumers have certain rights with respect to their personal information. You may exercise the rights applicable to you by emailing us at contact@slingtx.com. We comply with any applicable laws permitting data subject rights and will honor requests according to applicable laws. Depending on your jurisdictions, your rights may include the following:

You may opt out of communications from us at any time by following any opt-out instructions in the communication. We may still need to send you important administrative messages even if you opt out of receiving communications.
To the extent provided under applicable law, you may request access to, correction of, opt-out of the sale of or deletion of the personal information we process about you.

Verification: When you make a request, please provide your full name (first and last name), email address, city, and state of residence, and which of the right(s) described above that you are requesting. We will verify your request against our records. We cannot fulfill any unverified or incomplete requests.

We do not and will not discriminate against you for exercising your data subject rights, however, we cannot guarantee that all services and features will be available and will not be impacted because of your request.

You may designate an authorized agent to request data subject rights on your behalf by providing a signed and authenticated letter that identifies (i) your agent and (ii) the purposes for and nature of your appointment of an agent. If you are an authorized agent, you must provide the information described in “Verification” hereinabove about the consumer for which you are acting as an agent, as well as your own full name (first and last name), email address, and a letter, signed by the consumer, that appoints you as their agent. In some instances, we may decline to honor your request if an exception applies under applicable law, however we will respond to your request in compliance with applicable law.

UPDATES

We may change this Privacy Notice sometimes without notice. Please check back regularly to stay up to date with the most recent version.

If you have questions or comments about this notice, you may contact us by post at:

Sling Therapeutics
455 E. Eisenhower Pkwy
Suite 300 PMB1048
Ann Arbor, MI 48108
info@slingtx.com