Tract Bio Privacy Policy

Introduction 

We at Tract Pharmaceuticals, Inc. as well as our affiliates (collectively, “we”, “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this Tract Bio Privacy Policy (this “Policy”).  This Policy describes the types of information we may collect from you or that you may provide to us when you visit our website at https://tractbio.com, as well as any successor or subdomains thereof and any other websites where we post this Policy (collectively, our “Website”), and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to (i) any information that we collect on the Website or otherwise in connection with your use of the Website, including any information in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website; and (ii) any information collected when you interact with us by phone, e-mail or other electronic messaging service.  This Policy does not apply to any other information we may collect by any other means, including (i) any information we may collect from you or your organization pursuant to any written contract between us containing privacy or data protection covenants that are distinct from the terms of this Policy; and (ii) any information we may collect from participants in our clinical trials or otherwise in connection with conducting our clinical research, testing and development activities.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, you can choose not to use our Website or provide us with your information.  By accessing or using our Website, you agree to this Policy.  This Policy may change from time to time.  When we make changes to this Policy, we will post the updated Policy on our Website and update the Policy’s “Last Modified” date.  We will also provide notice of any material changes as explained in the section below titled “Changes to Our Privacy Policy.”  Your continued use of the Website after we make changes is deemed to be acceptance of those changes. 

Information We Collect About You and How It Is Collected 

Personal Information We Collect – Generally 

We may collect several types of information from and about users of our Website.  This may include information by which users may be personally identified or other information about a user to the extent maintained in personally-identifiable form (collectively, “Personal Information”).  Specifically, we (or our third-party service providers acting on our behalf) may collect the following from you:

• Personal identifiers and contact information, such as your full name, e-mail address, telephone number (including mobile phone telephone number) and the IP address or mobile device ID of the computer or device used to access and use our website (“Identifiers”). 

• The name and contact information of your organization or institution, and your position or role within your organization or institution. 

• The Technical Information described in the section below titled “Traffic, Usage and Computer/Device Information.” 

• Any other information (including Personal Information) you choose to provide to us, such as any information in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website.  

How We Collect Information 

With the exception of your Technical Information (which we or our third-party service providers collect automatically as you navigate through or interact with our Website, as described below in the section titled “Traffic, Usage and Computer/Device Information”), generally we collect Personal Information directly from you when you provide it or submit it to us directly, such as in connection with registering to obtain additional information from us (including by downloading one of our FAQs, executive summaries or other informational materials made available through the Website, or by signing up to receive our e-newsletter or other informational and promotional content about us or our business); reporting a problem you have experienced with our Website; or otherwise submitting an inquiry to us using the contact methods provided on the Website. 

Traffic, Usage and Computer/Device Information 

Additionally, as you navigate through and interact with our Website or the e-mails or other electronic messages we send to you, we or our third-party service providers may automatically collect certain traffic data, usage information and information about your computer equipment or mobile device, such as your browser and operating system, your wireless carrier, the geographic region from which you are accessing the Website, time stamped logs regarding access times and duration of visits, the pages of our Website that you visit, whether you opened the e-mail message we sent to you and whether you clicked on any links in the message, configuration data, clickstream analytics and your actions and patterns when you use our Website or interact with our e-mail messages (collectively, “Technical Information”).  The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code.  We collect this information to manage our content and improve users’ use of our Website; to count and review the number of users of our Website and their usage patterns; to track key performance indicators such as pages accessed, frequency of access, bounce rates and other statistical information related to our Website and the performance of our e-mail messages (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who access our Website via different web browsers or mobile operating systems; to recognize if a user is a return user of our Website; to store information about a user’s visits; to remember a user’s preferences; and for similar purposes in connection with monitoring, maintaining and improving our Website and our e-mail messaging.  Third parties may also collect Technical Information and other information on our behalf as further described in the sections below titled “Use of Google Analytics” “Tracking and ‘DO NOT TRACK’.”  

How We Use Your Information 

Generally 

We may use the information we collect about you or that you provide to us, including Personal Information, to:

• Provide our Website and its contents to you. 

• Provide you with information you request from us. 

• Authenticate or otherwise verify your identity in connection with your access to the Website, requests via the Website or otherwise. 

• Provide you with support and respond to your inquiries and customer service and support requests, including to investigate and address your concerns and to monitor and improve our responses. 

• Update and maintain subscription, e-mail or mailing lists. 

• Provide you with informational and promotional content and materials regarding the Website and our business, including through our e-newsletter or other e-mail alerts. 

• Help maintain the safety, security and integrity of our Website, databases and other technology assets and our business. 

• Fulfill, with respect to Technical Information, the purposes described in the section above titled “Traffic, Usage and Computer/Device Information.”  

• Fulfill, with respect to aggregated and de-identified information, the purposes described in the section below titled “Use and Disclosure of Aggregated or De-Identified Data.” 

• Notify you about changes to our Website, our business or this Policy. 

• Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations. 

• Enforce any contracts between you and us, including for billing and collection, or for the establishment, exercise or defense of legal claims. 

• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information (including Personal Information) held by us is among the assets transferred. 

• Fulfill any other purpose for which you provide the information. 

• Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.  

Use and Disclosure of Aggregated or De-Identified Data 

We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user.  As an example, we may de-identify or aggregate information provided by or collected about you and other visitors to our Website to generate aggregate trends or insights about the behavior of visitors to our Website.  You understand and agree that we may use and disclose to third parties any such de-identified or aggregated data for any lawful purpose. 

Tracking and “DO NOT TRACK” 

Tracking involves the use of cookies, web beacons or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions.  Tracking information can be used to enable companies to make interest-based (“behavioral” or “targeted”) advertising available to users on multiple sites that they visit. 

Currently we do not (and we do not allow third parties to) collect Personal Information about your online activities over time and across third-party sites for tracking purposes when you use our Website.  Because of this, our Website does not respond to any “do not track” signals sent by your computer, browser or mobile device, and if your computer, browser or mobile device sends a “do not track” signal to our Website, our Website will not treat you differently from users who do not send such signals.

For more information on how to disable certain tracking technologies, please visit the Network Advertising Initiative’s Consumer Opt-Out page at https://thenai.org/opt-out/ and the Digital Advertising Alliance’s Consumer Assistance page at https://youradchoices.com/. 

Use of Google Analytics 

We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Website, such as the number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long individuals are visiting our Website, and information about the equipment individuals are using to access our Website (e.g., browser version and operating system).  Google Analytics may use a Google Analytics cookie as part of this service, and we may share certain Personal Information with Google Analytics (such as an IP address) as part of this service.  We use this traffic and usage information to make improvements to our Website and our own commercial and promotional efforts. 

For more information, please review the following: 

• Information about Google’s use of cookies: https://policies.google.com/technologies/cookies?hl=en-US 

• You can opt out of our use of certain Google Analytics features by updating the “Ads Settings” in your browser (www.adssettings.google.com/authenticated) or mobile device (www.support.google.com/ads/answer/1660762#mob), by enabling the Google Analytics Opt-out Browser Add-on in your browser (https://tools.google.com/dlpage/gaoptout) or by visiting the Network Advertising Initiative’s Consumer Opt-Out page (www.optout.networkadvertising.org/).  Because those opt-out and preference control pages are specific to the individual browser used to visit them, and because those pages are not operated by us, we are unable to perform the opt-outs on your behalf. 

Disclosure of Your Information 

We may share your Personal Information with third parties in the following circumstances:  

• We may disclose Personal Information to our affiliates or to any contractors and other service providers who need to know such information (or such contractors or service providers may collect Personal Information directly from you on our behalf while you use our Website) to provide services to us that support our hosting, maintenance, operation and promotion of our Website and our permitted uses of Personal Information under this Policy.  For example, we may use one or more cloud-hosting providers (e.g., Amazon Web Services, Google Cloud or Microsoft Azure) to securely store your Personal Information collected through our Website or e-mail platform; we may use a website design and user experience / user interface (UX/UI) provider to present our Website and its contents to you; we may use a third-party customer relationship management and/or e-mail marketing software solution to organize and track our communications with you; and we may use certain third-party web analytics providers to collect and analyze information related to your use of our Website (such as Google Analytics, as described above in the section titled “Use of Google Analytics”). 

• We may disclose Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, and in connection with any due diligence review with respect to any such proposed transaction. 

• We may disclose Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements or to respond to any government or regulatory request or audit.

• We may disclose Personal Information to enforce or apply any legal agreements between us and you, or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our users or others.

• We may also disclose your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent. 

We may disclose all forms of Personal Information for each of the purposes described above, including but not limited to your Identifiers and Technical Information.  

Third-Party Sites and Services 

Our Website and e-mail messages to you may include links to blogs, social media and third-party websites.  These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy.  You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any Personal Information.  If you follow a link from our Website or e-mail messages to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy.

We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including links to any third-party site from our Website or e-mail messages.  We make no representations, express or implied, concerning the accuracy, privacy, safety, security or the information practices of any third-party site.  The inclusion of a link to a third-party site on our Website or in our e-mail messages does not constitute any type of endorsement of the linked site by us.  We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.

Your Rights and Choices

You have certain choices regarding the Personal Information you provide to us.  You can set your browser to refuse all or some browser cookies.  If you choose not to accept cookies, you may be unable to access certain parts or pages of our Website, or certain parts or features of our Website may not function properly.

If you do not wish to have your Personal Information used by us to contact you with promotional content, you can opt out by (1) sending us an e-mail with your request to info@tractbio.com or (2) with respect to promotional communications by e-mail, by clicking on the “Unsubscribe” or similar link in the most recent e-mail you received from us and by following the prompts that appear.  This opt-out does not apply to information provided as a result of a business inquiry you submit or other informational or transactional communications, nor does it apply to our disclosure to a third party that is acting on our behalf and under our instruction in support of our permitted uses of your Personal Information.

Please also refer to the section above titled “Use of Google Analytics” for more information regarding opting out of certain Google Analytics features used on and in connection with our Website. 

Accessing, Correcting and Deleting Your Information 

You may send us an e-mail at info@tractbio.com to request access to any Personal Information that you have provided to us, or to request to correct or delete that Personal Information. The following will apply with respect to each such request: 

• We will evaluate such requests on a case-by-case basis.

• In certain cases, we cannot delete your Personal Information, so a request to delete certain forms of Personal Information may require the deletion of any account you maintain with us and the cessation of our partnership with you.

• We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California “Shine The Light” Disclosure 

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year.  To make such a request, please send an e-mail to info@tractbio.com.  Please mention that you are making a “California Shine the Light” inquiry.  Please note, however, that we do not currently disclose Personal Information to third parties for their direct marketing purposes.  

Nevada Residents: Sale Opt-Out Rights 

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@tractbio.com.  Please mention that you are making a “Nevada Sale Opt-Out Right” request.  However, please know we do not currently sell data triggering that statute's opt-out requirements.  

Users Outside of the United States

Our Website is hosted in the United States and is provided from the United States.  It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms.  If you are accessing our Website from Canada, the United Kingdom, a country in the European Economic Area, Asia or any other jurisdiction with laws governing personal data collection, use and disclosure that differ from United States laws, please note that by using the Website and providing your Personal Information to us through the Website you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above (where laws may differ from the laws of your jurisdiction) and you are expressly and knowingly consenting to our use and disclosure of such Personal Information in accordance with this Policy.  

Children Under the Age of 18 

Our Website is not intended for children under 18 years of age, and no one under the age of 18 may provide any information to us on or using the Website.  We do not knowingly collect Personal Information from children under the age of 18.  If you are under 18 years of age, do not use our Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address, IP address or mobile device ID or any screen name or username you may use.  If we learn we have collected or received Personal Information from a child under 18 years of age without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under the age of 18, please contact us at info@tractbio.com.

Data Security 

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.  The safety and security of your information also depends on you.  If we have given you (or if you have chosen) a password for access to certain parts of our Website, you are responsible for keeping that password confidential.  We ask you not to share your password with anyone.  Unfortunately, the transmission of information over the Internet is not completely secure.  Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to or using our Website.  Any transmission of Personal Information is at your own risk.  We are not responsible for the circumvention of any privacy settings or security measures contained on our Website. 

Changes to Our Privacy Policy 

We post any changes we make to our Policy on this page.  If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on our Website home page.  The date this Policy was last revised is identified at the top of the page.  You are responsible for periodically visiting our Website and this Policy to check for any changes. 

Contact Information 

To ask questions or to submit comments about this Policy and our privacy practices, you may contact us: 

• Via E-mail: info@tractbio.com  

• Via Telephone: (617) 360-1185 

• Via Postal Mail: 99 Derby St, Hingham, MA 02043