Privacy Policy

The privacy of your personal information is important to Benuvia Therapeutics Inc. To better protect your privacy, we provide you with our privacy policy so that you will understand our commitment to you and to your privacy. This privacy policy describes what information we may collect about you; how we use your information; how we protect it; and what choices you have on how that information is used. At Benuvia Therapeutics Inc., we understand that health is a very personal, private subject, and we want you to feel as comfortable as possible visiting our various websites and using their respective services.

As our privacy policy changes in significant ways, we will post changes on our website in a timely manner. Minor changes to the policy may occur that will not affect our use of individually identifiable or personal health information (“PHI”). When the privacy policy changes in a way that significantly affects the way we handle personal information, we will not use the information we have previously gathered without providing notice or obtaining your consent when appropriate.

The following articles make up our privacy policy. We hope that reading them gives you a clear idea of how we manage information regarding you. For immediate access to a particular topic, click on the title of that topic.

Personal Information We Collect

Information we collect from visitors

Visitors to each of our websites can access the website’s home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the website you came from (known as the referring URL), the type of browser you use, the time and date of access, and other information that does not personally identify you. On some of our sites, you must register to access portions of the site.

In addition, we gather information about you that is automatically collected by our web server, such as your IP address and domain name. Benuvia Therapeutics Inc. may use web server and browser information to individually customize its offerings and presentations if you submit your personal information.

Children’s privacy

We are committed to protecting the privacy of children. We do not knowingly collect personal information from anyone under the age of 18.

Information we collect when you register

Visitors registering for services on our websites are asked to provide identifying information, such as name, gender, and contact information. On the registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretion. Benuvia Therapeutics Inc. websites obtain visitors’ consent before collecting personally identifiable information.

Information from outside sources

We may also collect information about physicians or other healthcare professionals who register on our websites from other sources in order to verify their licensure status and identity. In some cases, we may ask customers for information after they register, such as credit card information. Where necessary (for example, to process an order for a purchase), our websites may contact financial or credit organizations to confirm customer credit card information.

From time to time, we may augment our existing user databases with legally obtained information from third parties. Some of this information may be personally identifiable, such as national change of address information. We do this to better target our information offerings and promotional campaigns and to provide pertinent offers in which we think you would be interested.

Other information

We also collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, and the like.

On some of our websites, we offer health assessment tools that ask you to provide self-assessment information.

We may also ask you to provide additional information such as your email address if you want to obtain additional services or information or to resolve complaints or concerns.

Use of cookies and other tracking systems

Cookies, log files, and pixel tags (web beacons) are technologies used by the Benuvia Therapeutics Inc. websites to identify a user as the user moves through our websites. Your browser allows us to place some information (session-based IDs and/or persistent cookies) on your computer’s hard drive that identifies the computer you are using. We may use cookies to personalize our websites and to track your usage across other Benuvia Therapeutics Inc. websites.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The help section of your browser will tell you how to prevent your browser from accepting cookies.

On occasion, we may contract with third parties that have agreed to observe our privacy policy to place cookies on your computer’s hard drive.

Although cookies do not normally contain personally identifiable information, if you have provided us information about you, we may associate your registration information with cookies or other tracking utilities our website places on your computer’s hard drive. Associating a cookie with your registration data allows us to offer increased personalization and functionality. Without cookies, this functionality would not be possible.

Some of our business partners may use cookies on our sites (for example, links to business partners). We do not want our business partners to use cookies to track our customers’ activities once they leave our sites. However, we may not have control over how our business partners use cookies on our websites. If you become aware that a Benuvia Therapeutics Inc. business partner is placing an unwanted cookie on your hard drive, please contact our Privacy Officer to assist us in resolving the problem.

In addition, we may use other tracking systems like pixel tags. Pixel tags, sometimes called web beacons, are similar in function to a cookie. But because of their insignificant size, they are not visible; though they are used to pass certain information to our servers to personalize our websites and to track your usage across other Benuvia Therapeutics Inc. websites. In addition, we may also use pixel tags in our HTML-based emails.

Use of Your Information

Aggregate data

We gather aggregate data about visitors to our websites for product and service development and improvement activities. We also use it for market analysis. We may provide information from our websites in aggregate form, with identifying information removed, to third parties. When aggregate health information is provided, we pool it from many individual records. Before it is used, we strip it of any data that could be used to identify an individual. Any third party that receives aggregated health-care data must agree not to attempt to re-identify the people the data belongs to.

Marketing and healthcare messages

We may target our marketing and healthcare messaging depending on information we have about you. For example, a user whom we know is a woman may receive information on products targeted to women. A male user would not see this information. Or, a user whom we know is a healthcare professional who treats Chemotherapy Induced Nausea and Vomiting (CINV), may receive information for new CINV therapies. We may send information to you that we may believe will benefit you, including information about any Benuvia Therapeutics Inc. product (see your Privacy Choices section).

We may also personalize our website based on your interests. For example, you may see different articles in different places on our website based on information you have shared with us, or information we have gained by reviewing your previous visits, or information we may have gained from your interactions with a third party that shares information with us.

When we share information with third parties working on behalf of Benuvia Therapeutics Inc. we use reasonable efforts to assure that they agree in writing to abide by Benuvia Therapeutics Inc. privacy policies.

If we discover that a third party working on behalf of Benuvia Therapeutics Inc. inappropriately disclosed personal information about any of our visitors, we will take immediate action to prevent further occurrences.

Other than as described above, Benuvia Therapeutics Inc. will not release personally identifiable information to a third party without your consent.

Tell a friend

If you choose to use a referral function on a Benuvia Therapeutics Inc. website to tell a friend about our site, our site may ask you for your friend’s name and email address as well as your information. The form automatically sends your friend a one-time email inviting him or her to visit the site. We do not access or store this information, except to send this invitation.

How Benuvia Therapeutics Inc. Handles Privacy Internally

Our commitment to security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

General policies

We have implemented technology and security policies, rules, and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access to, or are associated with, the processing of your data, respect your confidentiality.

Benuvia Therapeutics Inc. uses security methods to determine the identity of each registered user, so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. Benuvia Therapeutics Inc. uses both passwords and usernames to authenticate users. Users are responsible for maintaining their own passwords.

Storage of health information

Personally identifiable health information you share with us is stored on our database servers. We have a firewall and other technology to prevent individuals from accessing information without authorization. Facilities where our servers are located are designed to be physically secure and protected from unauthorized access by unauthorized persons.

Information in our servers is backed up routinely in order to aid in the recovery of information in the event of accidental damage of information or due to a natural disaster. The backup media are stored in a physically secure storage facility.

Third parties

In addition to aggregate information (discussed previously), we may share some kinds of information with third parties as described below.

Companies and people who work for us:

We contract with other companies and individuals to help us provide services. For example, we may host some of our websites on another company’s computers, hire technical consultants to maintain our web-based health sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed healthcare professionals. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. Other companies may collect information on our behalf through their sites. This occasionally incorporates the use of frames on the site that will not show the URL you are visiting in the browser address window. We require such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us. We use our best efforts to limit other companies’ use of personally identifiable or healthcare information.

Promotional and informational offers:

Sometimes we may send offers to selected groups of customers. To accomplish this, we may use third parties working on behalf of Benuvia Therapeutics Inc. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional or informational offers. For example, we may provide an opt-in box for customers to receive information that is sent by a third-party fulfillment house, and we make clear that, by opting in, you are submitting your data to a third party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out as mentioned or included in each of our programs we send to you.

Legal requirements:

We may release account and other personal information when we believe release is required to comply with applicable law. We may release personal health information if, after review and consultation with an attorney, the release is compelled by law or regulation, or if the release may be necessary to prevent the death or serious injury of an individual.

Your Privacy Choices

If you register to receive recurring informational/promotional email from Benuvia Therapeutics Inc. or third parties working with Benuvia Therapeutics Inc. you may subsequently opt-out from receiving this email when you provide the information or follow the instructions as mentioned in the email or included in each program we send to you.

We will unsubscribe you from that newsletter or other programs within ten (10) business days.

Choice

You will be given the opportunity to choose whether your personal information is (a) to be disclosed to a third party working with Benuvia Therapeutics Inc. or (b) to be used for a purpose that is different from the purpose originally intended or authorized. In addition, we will not request sensitive information that includes personal information specifying medical or health conditions without providing you with an affirmative or explicit opt-in choice.

Onward transfer (transfers to third parties)

We will provide you with notice and choice before either personal information or sensitive information is transferred by us to a third party.


Updating Your Personal Information and Contacting Benuvia Therapeutics Inc.

You can always contact us in order to (i) remove from our systems the personal information that you have provided to us, (ii) update the personal information that you have provided to us, and (iii) change your preferences with respect to marketing contacts by emailing us at info@benuvia.com or if available also logging into your account to update your information.

Benuvia Therapeutics Inc. Privacy Policy March 2020.