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WinSanTor Inc. (“WinSanTor,” “we,” “our,” and/or “us”) is a clinical-stage biotechnology company focused on the discovery and development of treatments for peripheral neuropathies, including diabetic peripheral neuropathy, chemo- and HIV-induced peripheral neuropathy, and others.

This Online Privacy Notice (“Privacy Notice”) explains how WinSanTor handles Personal Data (as defined below) that it collects and receives through this website (“WinSanTor Website”) from WinSanTor Website visitors (“Users”).

This Privacy Notice does not address:

Data Collected During Clinical Trials. If you enroll in a WinSanTor clinical trial, you will receive detailed information about data collection during the clinical trial process and you will be asked for your consent for such data collection as part of the enrollment process. If you have questions regarding data collected during a clinical trial in which you are enrolled, please contact your clinical trial research coordinator.

● Investigators and Staff

For purposes of this Privacy Notice, “Personal Data” means any data related to you as an identified or identifiable natural person. Examples of Personal Data include name, address, telephone number, and email address. This Privacy Notices is effective as of July 1, 2019.

Information We Collect
How We Use the Information We Collect
How We Share the Information We Collect
Your Choices
Third Parties
Security
Children’s Privacy
Your California Privacy Rights
International Visitors
Changes to this Privacy Notice
Contact Information

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below. If you do not provide your information when requested, you may not be able to use the WinSanTor Website if that information is necessary to provide you with the information or services requested or if we are legally required to collect it.

A. Information You Provide to Us

Registration and Profile Information. If you request information about enrolling in a specific clinical trial, sign up for notifications or updates, or participate in our surveys, we may ask you for your name, email address, phone number, zipcode, gender, birthdate, and medical information. If you sign up using a Facebook, Twitter, LinkedIn, or Instagram account, we will also receive information from those social media services such as your name, email address, gender, date of birth, profile photo, and list of friends.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact info@winsantor.com, we will receive your name, email address, phone number, and other information you choose to provide. If you subscribe to our newsletter or alerts, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

B. Information We Collect When You Use the WinSantor Website

Location Information. When you use the WinSanTor Website, we may infer your general location information, for example by using your internet protocol (IP) address.

Device Information. We receive information about the device and software you use to access the WinSanTor Website, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. To help us understand how you use the WinSanTor Website and to help us improve it, we automatically receive information about your interactions with the WinSanTor Website, like the pages or other content you view, the searches you conduct, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We and 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 the WinSanTor Website. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

C. Information We Receive from Third Parties

● Information from Third Party Services. If you choose to link the WinSanTor Website to a third party account, we may receive information about you, including your profile information and your photo, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.

● Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

How We Use the Information We Collect

We use the information we collect:

● To communicate with you, provide you with updates and other information relating to the WinSanTor Website and/or clinical trials, provide information that you request, respond to comments and questions, and otherwise provide customer support;

● 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;

● To provide, maintain, improve, and enhance the WinSanTor Website;

● To personalize your experience on the WinSanTor Website such as by providing tailored content and recommendations;

● To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;

● For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

● For other purposes for which we provide specific notice at the time the information is collected.

How We Share the Information We Collect

We do not share or otherwise disclose the information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Clinical Trial Investigators. If you submitted information regarding eligibility and enrollment in a specific clinical trial, we may share that information with the clinical trial investigator and staff for the locations relevant to you.

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Notice.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the WinSanTor Website.

Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. To help us understand how you use the WinSanTor Website and to help us improve it, we automatically receive information about your interactions with the WinSanTor Website, like the pages or other content you view, the searches you conduct, any comments or content you submit, and the dates and times of your visits.

Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post or submit any objectionable content on or through the WinSanTor Website.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Notice in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

● If you choose not to provide us with information we collect, some features of the WinSanTor Website may not work as intended.

Other Choices. Under applicable data protection law, you may be entitled to request access to and/or rectify, block, or delete your information, transmission to third parties, withdraw your consent at any time for future activities related to your information, or object to any use of your information. If WinSanTor will not be able to provide the requested information or does not make the changes you request, you will be provided with reasons for such decision. Under local law you may also be entitled to lodge a complaint with your local data protection authority. Please submit your privacy inquiries here: info@winsantor.com. Alternatively, you may send a letter to WinSanTor, 7220 Trade St., Ste. 370, San Diego, CA 92121.

Third Parties

The WinSanTor Website may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the WinSanTor Website is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Notice, then you may alert us at info@winsantor.com.

Your California Privacy Rights

If you reside in California and have provided your personal information to us, you may request information once per calendar year about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing at the following email address: info@winsantor.com.

International Visitors

This site is owned and operated by WinSanTor, and if you are visiting this site from a country outside the US, your communication with us will necessarily result in the transfer of information across international borders. Personal Data may be transferred, consistent with applicable law, to other WinSanTor affiliates suppliers, and vendors in territories that may not provide a level of protection to Personal Data equivalent to that provided by your home country. By providing your Personal Data through the WinSanTor Website, you consent to the processing of your information by WinSanTor and its affiliates, suppliers, and vendors in other territories. Any onward transfers of Personal Data to vendors and suppliers outside the European Economic Area will be done in compliance with the international data transfer restrictions that apply under EU and Swiss data protection laws, including, where appropriate, through the use of EU model contracts for data transfers to processors or any other lawful basis for such transfers.

Changes to this Privacy Notice

We will post any adjustments to the Privacy Notice on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the WinSanTor Website, we will notify you through the WinSanTor Website, by email, or other communication.

Contact Information

WinSanTor is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at info@winsantor.com or write to us at 7220 Trade St., Ste. 370, San Diego, CA 92121.

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