Privacy Policy

This Privacy Policy (“Privacy Policy”) explains Cognition Therapeutics’ (“CogRx,” “we,” “us,” “our”) privacy practices. This Privacy Policy applies when you visit our website at https://cogrx.com/ or any associated pages and services (collectively referred to as our “Website”).

Please read this Privacy Policy carefully to learn how we collect, use, and share information relating to individuals, and to learn about your rights and choices regarding your Personal Information. By using any Website or providing your information to us, you understand and acknowledge that we will collect and use personal information as described in this Privacy Policy.

PERSONAL INFORMATION WE COLLECT

In conducting every aspect of our business, we may collect personal information. Such information may include, without limitation: your name, home and mailing addresses, email addresses, telephone numbers, protected health information and other types of personal information that you choose to provide to us or that we may obtain about you. We collect personal information, as well as non-personally-identifiable information, in multiple ways:

Directly from You. We collect information you provide to us. This may include, for example, when you request information or materials from us, visit our Website, use our App, fill out a contact form, apply for a job, or communicate with us in any way.

Automatically Through Cookies and Other Collection Technology. When you use our Website, we collect some information automatically. For example, when you visit our website, we may collect device, usage and log information such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, the search engine you used to locate the website, and the website you visited before or after our site. In addition, we gather certain navigational information about where you go on our website to help us determine which areas of the website are most frequently visited and helps us to tailor the sites to the needs and interests of our online visitors.

Like most companies, we use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather this information. When you visit our website, we, or an authorized third party, place or recognize a unique cookie on your browser (including through use of pixel tags) that collects information, including personal information, about your online activities over time and across different sites. We also use web beacons and pixels in our emails to collect information about how you interact with our emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies and the information they collect: (a) for security purposes; (b) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (c) to provide custom, personalized content and information; (c) to gather aggregate statistical data and metrics such as total number of visitors, traffic, and demographic patterns to continually improve design and functionality, as well as understand how the websites are used and assist us with resolving questions; (d) to diagnose or fix technology problems; and (e) to deliver, evaluate the effectiveness of, and improve our marketing and advertising.

If you want to remove or block collection technology, you may be able to update your browser settings (consult your browser’s “help” menu to learn how to remove or block cookies and similar technology). You can also find instructions on how to manage collection technology on different types of web browsers at www.allaboutcookies.org.

HOW WE USE PERSONAL INFORMATION

We may use your personal information to:

  • Complete contracts as well as any disclosures or other documents required by law;
  • Determine your eligibility for, and solicit your participation in, research studies or clinical trials;
  • Process any applications, forms, requests, orders, purchases, inquiries, or other information submitted to us;
  • Send marketing communications, market research or quality assurance surveys;
  • Communicate with you;
  • Perform research and analytical activities (e.g. identifying trends and the effectiveness of marketing campaigns);
  • Conduct audits, security and fraud monitoring and prevention;
  • Protect our legitimate business interests and legal rights;
  • Manage all aspects of an applicant or employee’s employment relationship, including, but not limited to the establishment, maintenance, and termination of employment relationships; and
  • Assist us with legal claims, compliance, regulatory and investigative purposes as necessary (including in connection with law enforcement investigations, legal process, or litigation).

We may also use personal information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, inferred commercial interests, and other information we may collect from you or from third parties.

HOW WE SHARE PERSONAL INFORMATION

We may share your personal information as described below.

Service Providers. We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, suppliers, agents, attorneys, and representatives (collectively, “Service Providers”). Service Providers assist us with a variety of functions including, but not limited to, sending marketing communications, processing payment of gift cards, assisting with advertising and related analytics, delivering orders, providing management services, conducting research or surveys, sending regular mail and e-mail, maintaining databases, or processing credit card payments.

Government Agencies. We may share your personal information with government agencies such as the National Institute on Aging, the National Institute of Health or the Internal Revenue Services.

Disclosures Under Special Circumstances. We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm, illegal activity, or financial loss; (iii) to detect, investigate and help prevent security, fraud or technical issues; (iv) to cooperate with law enforcement, government, quasi-governmental and public agency requests, legal processes, or reporting requirements; and (v) to enforce or protect our contracts, legal rights or the rights of others.

Corporate Transactions. We may transfer your personal information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.

With Your Consent or At Your Direction. We may share your personal information with third parties whenever you consent to or direct such sharing.

Aggregated or Anonymized Data. We may also share personal information we have collected and aggregated or anonymized (such as demographic data) with investors, partners, clinical trial sites, patient advocacy groups, and in press releases.

PERSONAL INFORMATION OF CHILDREN

We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to compliance@cogrx.com.

“DO NOT TRACK” DISCLOSURE

We do not collect or respond to Do Not Track signals and our websites do not function differently based on any Do Not Track preferences that may be received. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

ANALYTICS SERVICES

We also use analytics services provided by Google Analytics. Google Analytics uses cookies and other collection technology to collect and store information about the use of the websites and the use of other websites, apps and online resources. You can read Google’s privacy policy, which applies to Google Analytics, at http://www.google.com/intl/en/policies/privacy/. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current browser, at https://tools.google.com/dlpage/gaoptout.

LINKING TO OTHER SITES AND ADS

Our website may contain links to third-party websites and services, and/or display advertisements for third-parties(collectively, “Third-Party Links & Ads”). Where the Website contain links to Third-Party Links & Ads, these links are provided for your information and convenience only. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. Third-Party Links & Ads may send their own cookies to your device, they may independently collect information about you or from you, and they may or may not have their own published privacy policies. We do not review, approve, endorse or make any promises with respect to Third-Party Links & Ads. You use all Third-Party Links & Ads at your own risk, and should apply a suitable level of caution and discretion in doing so. When you click on any of the Third-Party Links & Ads, the applicable third party’s terms and policies apply, not this Privacy Policy.

PROTECTION OF PERSONAL INFORMATION

We store your information using reasonable physical, technical and administrative safeguards. Please be aware that the Website and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. In addition, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. We cannot ensure or warrant the security of any information you transmit to us over the internet.

YOUR CHOICES

Marketing. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by contacting us by email at compliance@cogrx.com or by following the instructions in any such email you receive from us. We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.

PRIVACY RIGHTS OF CALIFORNIA RESIDENTS

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes without either obtaining your consent or giving you the ability to opt-out. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at compliance@cogrx.com. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, ZIP code, email address and telephone number. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address. Please also note that “Shine the Light” rights and CCPA rights are established under different legal regimes and must be exercised separately.

USERS OUTSIDE THE UNITED STATES

If you are using the Website from outside the United States, please be aware that information we obtain about you will be processed in the United States or in other jurisdictions. By using the Website, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence.

CHANGES TO THIS PRIVACY POLICY

The Privacy Policy may be revised from time to time. The “Last Updated” legend at the bottom of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our websites or notify you of any revisions.

CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at compliance@cogrx.com.

Last Updated: May 2, 2021

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