This Privacy Policy (“Policy”) describes the privacy practices of Speratum Biopharma, Inc. and its subsidiaries (“Speratum,” “we,” “us,” or “our”) with respect to personal information that we collect in connection with the website maintained by Speratum at www.speratum.com, including investors. speratum.com (“Website”), and any other websites, platforms, or apps maintained by Speratum (collectively, the “Services”).

This Policy does not apply to Speratum’s clinical trials, including our research registries and information collected in connection with Informed Consent forms. The term “Services” should not be interpreted to refer to any such clinical trial(s). If you are interested in one of our clinical trials, you will be asked to sign an Informed Consent form and provide certain additional information. We do not use your personal information to assess your eligibility for, or other purposes related to, a clinical trial unless and until we first obtain approval through an Informed Consent form. Additionally, this Policy does not apply to personal information collected from Speratum employees, contractors, or job candidates, which may be
subject to separate privacy policies.

Protecting the privacy and security of your personal information is important to Speratum. This Policy is designed to help you understand what personal information Speratum may collect when you use the Services and how we use and disclose that information. We may change this Policy at any time by updating it on our Website. The revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Website, by email, or other communication.

1. Personal Information We Collect
When you use the Services, you may provide certain personal information to us. For example, you may provide us with certain personal information via the Website, such as your name and email address, to receive updates from us.

In addition to the above, as you use the Services, we may collect certain passive information, including internet protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use, your operating system, the date and time you access the Services, and the Internet address of the website from which you linked directly to the Services.

We may also collect personal information if we conduct or sponsor surveys, business or marketing events, and when you contact us via email for information or assistance. In these instances, we may ask for your name, email address, phone number, st ate of residence, and/or mailing address.

We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. 

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

2. Use of Personal Information
We may use the personal information we collect in the following ways:
– To communicate with you, provide you with updates and other information relating to our Services, respond to comments and questions, and otherwise provide support.
– To provide, maintain, improve, and enhance our Services.
– To personalize your experience on our Services, such as by providing tailored content and recommendations.
– To find and prevent fraud and abuse and respond to trust and safety issues that may arise.
– To measure interest in our Services and business, perform internal quality control, and send communications regarding the Services and our business.
– To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for public health, research, and analytics.
– For compliance purposes, including enforcing our terms of service and legal rights or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
– For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you.
– For other purposes disclosed to you at the time you provide personal information or with your consent.

3. Disclosure of Personal Information
We disclose the personal information we collect in the following ways:
– Vendors and Service Providers: We may disclose personal information to our vendors and service providers retained in connection with the provision of our Services.
– Marketing: We do not rent, sell, or share personal information with non-affiliated companies for their own direct marketing purposes unless we have your permission.
– Analytics Partners: Speratum may use Google Analytics or other analytics services to collect and process information regarding visitor behavior and demographics on our Services. You can learn more about Google’s practices [here]. You can also opt out of Google Analytics [here].
– Advertising Partners: We work with third-party advertising partners to show you ads that we think may interest you. If you do not wish to receive personalized ads, you may opt out through the Network Advertising Initiative or the Digital Advertising Alliance. You can also adjust ad settings on your mobile device.
– As Required By Law and Similar Disclosures: We may access, preserve, and disclose your personal information if we believe it is required or appropriate to comply with legal obligations, respond to requests, or protect rights, property, or safety.
-Merger, Sale, or Other Asset Transfers: We may transfer your personal information in connection with a corporate transaction such as a merger, acquisition, or sale of assets. The use of your information following any of these events will be governed by this Policy.
– Consent: We may disclose your personal information with your permission.

4. Users Outside of the United States
Speratum is based in Costa Rica and the United States. If you are outside of these regions, by submitting personal information to us, you consent to the collection, storage, and processing of that information in accordance with this Policy.

5. Security
Speratum is committed to protecting the security of your personal information. While we have implemented security measures, please keep in mind that no storage or transmission of information is guaranteed to be completely secure.

6. User Choices and Changing Your Information
You may contact us (see the Contact Us section below) to request the removal, correction, or update of your personal information. You may also “opt-out” of receiving emails and other communications from us by using the unsubscribe feature or by contacting us directly.

7. Minors
Speratum does not intend, and the Services are not designed, to attract or collect any personal information from or about children under the age of 18. If you are a parent or guardian of a child who may have provided personal information to us, please contact us.

8. Third-Party Websites
The Services may include hyperlinks to websites or other content maintained by others. Speratum is not responsible for such websites or their content, and this Policy does not apply to them.

9. Contact Us
Speratum Biopharma, Inc.
[email protected]