CLICK THERAPEUTICS, INC. PRIVACY POLICY

Effective Date: July 16, 2018

This Privacy Policy explains how information is collected, used and disclosed by Click Therapeutics, Inc. (“we”, “us”, “the Company”, “Click”) with respect to your access and use of Click Therapeutics' services, whether through our user websites or our mobile applications (the “Services”). When we use the term “Personal Information” in this document, we mean any information relating to an identified or identifiable person). This Privacy Policy applies to the Services accessed by authorized users but does not apply to other general Click Therapeutics websites that have links to separate privacy policies.

By accepting this Privacy Policy during registration, or by visiting and/or using any of our Services, you expressly consent to our collection, use, and disclosure of your Personal Information (as described further below) in accordance with this Privacy Policy.

1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to how we use and disclose Personal Information we collect when you use our Services and explains your rights and choices related to our use and disclosure of your information.

The Services may contain links to other websites or apps. Such websites or apps are not governed by this Privacy Policy. We do not have any control over those websites or apps and are not responsible for their security, privacy policies and/or practices. When linking to another website or app, you should exercise caution and read the privacy policy published on those websites or apps.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect the following types of information from our users:

Information You Provide to Us. We collect and store information you enter on or through our Services or otherwise provide to us. The Personal Information we collect from you will vary depending on the Services you are using or the features you have enable and how you access the Services. Personal Information you provide to us may include:

  • Demographic information such as your name, mobile phone number, email address, and home or business postal addresses used to create your account profile and to provide you with the Services.
  • General health information related to your condition or use of non-prescription aides in order for you to take advantage of certain features of the Services.
  • Contact information for people you want on your support team. You may choose to provide us with the names, email addresses, or mobile phone number of your friends or family members whom you want to invite to be your “supporters” as part of the Services. We will use this information to send an invitation to your selected supporters and they can decide whether to join your support team.
  • Other information you might provide when you contact us for technical support or customer service.

You can choose not to provide us with certain information, but that may result in our inability to provide you access to select features.

Information Collected Automatically. We collect certain information automatically when you use the Services (such as through cookies, Java scripts, or log files) that relates to your access and use of the Services (“Usage Data”). Usage Data can include information such as your IP address, indication of browser or device type, numbers and frequency of users, and diagnostic data. We automatically collect the following information:

  • We automatically receive and record certain Usage Data on our server logs from your browser, including your IP address, and the page you requested.
  • We may collect cookies or other identifiers to recognize you when you arrive at our Services via an external link, such as a link appearing on a third-party site or in an email we sent to you.
  • We may also receive an auto-generated confirmation when you open an email from us, if your computer supports this type of program.
  • We collect the general location of your device in cases where you use a mobile device to access our Services. Your general location also may be discernible from your device’s IP address or the URLs we receive while you use the Services.

We typically aggregate the data that we collect automatically and use it for analytics purposes, in a way that does not identify individuals and treat that information as (“Non-Personal Information”). We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Services so that we can improve our Services. We may provide this Non-Personal Information to our business partners to identify how our customers, collectively, use our Services.

We do not permit third parties to collect Personal Information or Usage Data through our Services concerning your activities over time across different websites or applications.

Google Analytics Data. Our Websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” to help us analyze how users use our Websites. The information generated by the cookie about your use of the Websites (including your IP address) will be transmitted to and stored by Google. To learn more about Google Analytics and how you can opt out, visit https://tools.google.com/dlpage/gaoptout. By using our Websites, you consent to the processing of data about you by Google.

3. HOW DO WE USE THE INFORMATION WE COLLECT?

We use the information collected through the Services (including Personal Information) for the following purposes:

-to provide communications about our Services, including updates and new features or personalized messaging or reminders related to your goals;
-to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
-to monitor and analyze usage and trends, and to increase the functionality and user friendliness of our Services;
-to provide content or features that match your profile or interests;
-to detect, prevent investigate and address technical issues with our Services;
-to send you confirmations, updates, alerts, administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services;
-for security purposes and for internal auditing and data analysis;
-to comply with legal obligations or regulatory requests or to enforce our rights arising from any agreements we have entered with you, such as the Terms of Use; and
-to protect the rights, property, or safety of our company, our affiliates, our users, our customers, or others

4. WHEN DO WE SHARE INFORMATION?

Personal Information about our users is an integral part of our business. We do not rent or sell your Personal Information with other people or non-affiliated companies. We may share or disclosure your Personal Information for the following purposes:

  • Business Partners. With our business partners as needed to provide the Services to you or to facilitate our business operations or to perform functions on our behalf.
  • Messaging Services. We may provide functionality to permit your supporters to send messages using the Services, including text messages. Please note, if a message your supporter sent using such functionality contains Personal Information, we cannot control how the Personal Information will be used or disclosed. We urge you and your supporters to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any message. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT IS DISCLOSED BY YOU OR ON YOUR BEHALF IN SUCH MESSAGES.
  • Business Transfers. We may share your Personal Information with third parties in the event of a potential or actual merger or sale involving our business, including any transfer made as part of insolvency or bankruptcy proceedings. By continuing to use our Services, you acknowledge that if we sell or transfer our business (e.g., through an acquisition) or an asset (e.g., our mobile application) to another company, we will share your Personal Information with such company and will require such company to use and protect your Personal Information consistent with this Privacy Policy.
  • Protection of the Company and Others. We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the company, our employees, our users, or others.
  • Wellness Program. If you are using the Services in connection with an employer wellness program or similar sponsored program, we may be required to share certain information with the employer or sponsor of the program, as needed for the employer or sponsor to provide the intended benefit offerings to you.
  • Required by Law. We may also disclose your Personal Information if we are required to do so by applicable law, legal process, or a reasonable request from law enforcement authorities or government officials.

5. HOW DO WE RESPOND TO DO NOT TRACK SIGNALS?

Our Services do not currently respond to browser-based do-not-track signals. Most web browsers automatically accept cookies, but you can modify your browser settings to decline or block cookies if you prefer. In some cases, block or disabling cookies may prevent you from being able to use certain features of our Services.

6. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We employ administrative, physical, and technical measures designed to safeguard and secure Personal Information we collect through the Services. Your Personal Information may be accessible when you log-in to certain features of the Services. In those instances, you are responsible for keeping your user credentials and password confidential and secure so that your information is protected.

7. WHAT CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?

As stated previously, you can always opt not to disclose your Personal Information to us, even though it may be needed to take advantage of certain features of the Services. You also have the following rights or choices related to Personal Information we maintain about you:

  • You may contact us to correct or amend your Personal Information using the contact information below.
  • You may ask us to remove your records from our system. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain.
  • You may choose not to receive communications from us by indicating your preferences to us or using the opt-out or unsubscribe features included in our communications.

For questions or to exercise any of these rights, please contact us using the contact information at the bottom of this Privacy Policy.

8. HOW DO WE PROTECT CHILDREN’S PRIVACY?

The Services are not directed to children (or anyone under age 18). We do not knowingly or intentionally collect Personal Information from children. If you are a parent or guardian and you believe your child has provided us with Personal Information, please contact us using the contact information provided below and we will delete such Personal Information from our files.

9. CHANGES TO THIS PRIVACY POLICY

By using the Services, you agree to the current Privacy Policy and our Terms of Use, into which this Privacy Policy is incorporated. Please review this Privacy Policy periodically as we may change it at any time without prior notice to you. Any changes will be effective immediately upon posting unless otherwise indicated. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. The date at the top of this page indicates when this Privacy Policy was last updated.

10. QUESTIONS?

Please contact us at 101 Avenue of the Americas, 8th Floor New York, NY 10013 or support@clicktherapeutics.com if you have any questions about this Privacy Policy.