Last Updated: 08/19/2024

Spinogenix, Inc. (“Spinogenix”, “we”, “us”, and/or “our”) is developing proprietary ocular tracers that enable identification of molecular biomarkers for diseases of the eye, heart and brain.

This Privacy Notice describes how Spinogenix handles personal information that we collect from and about you when do any of the following:

• visit our main public website, https://www.spinogenix.com/
• engage with us through our newsletters, emails, and branded social media accounts;
• or otherwise interact with us.

Collectively, we describe our products and services – including our Main Site, and online publications and communications – as our “Services.” This Privacy Notice also describes certain rights you may have, subject to applicable law, and how you can exercise them.
For the purposes of this Privacy Notice, “Personal Information” means information about an identifiable person, as defined by applicable law. This includes information that alone or in combination with other information may be used to identify, contact, or locate you, such as your name, address, email address, or phone number.

Please read this notice carefully.

Information We Collect

Information you give us directly

Some information we collect directly from you. For instance, we collect information that you voluntarily provide in the following ways:

• When you fill in forms on our Site. When you fill in forms on our Main Site, such as our “Contact Us” form, we require that you provide us with certain information including your first and last name, email address, phone number, and your current company/organization. We also collect any information you choose to provide to us as part of your request (such as the reason you are contacting us or what types of updates you’d like to receive).
• When you help conduct a clinical trial. If you are Site Staff, Spinogenix collects certain information about you in relation to the studies which are being carried out at your clinical trial site. This may include your first and last name, professional contact information, role/job duties, and qualifications.
• When you attend a conference, trade show, or other in-person event. We may collect Personal Information individuals who swipe their badge or provide information to us at conferences, trade shows, or other events we may host or sponsor. This information may include your first and last name, job title, company/organization name, and business contact information. Occasionally, we may record events and make those records accessible to the general public. If we do so, we will indicate that the event will be recorded.
• When you email us to ask a question or when you communicate with us via a third-party social media platform. When you contact us by email; through our branded social media accounts; through any integrated chat providers we may provide; or by telephone, SMS, or physical mail, we may collect your name, username, email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide.

Information we collect automatically when you use our Services

We also collect certain information automatically as you navigate our Services or interact with our communications. To collect this information, we, or our third-party service providers may use cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We, and our third-party service providers use cookies in order to do things such as recognize you when you return to our Site, save your preferences (including your preferences regarding cookie handling), understand which sections of the Site you find most interesting, ensure our Services are working properly, and prevent fraud. We use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or until they expire).

The information we collect automatically can include the following:

• Information about the devices you use to access our Services (including your internet protocol (IP) address, browser type, and operating system);
• The address of the web page visited before and after using our Services;
• Details about your interactions with our Services (such as the date, time, length of stay, and specific pages accessed during your visits);
• Search terms used to reach our Services;
• Usage information (such as the number and frequency of visitors to our Services); and
• Location information (such as general location information inferred from your IP address).

If you do not want us to collect information through the use of cookies, you can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to the guidance offered by your chosen web browser if you would like help managing your cookie preferences. Please note that if you reject or block cookies, the Services may not work as intended.

Information we collect from other sources

We may also collect information about you from other sources including the following:

• A family member or other trusted individual. We may collect your Personal Information from a family member or other trusted individual who completes the interest form on our clinical trial patient portal on your behalf.
• Another individual at your organization: We may collect your Personal Information from another individual at your organization who may provide us with your business contact information in the course of using our Services or in connection with a current or prospective clinical trial.
• Other sources: We may also obtain Personal Information about Site Staff and business partners from other sources, including publicly available information on internet sites, and third parties that help us update, expand, and analyze our records and inform our networking and marketing efforts. For instance, we may use information from LinkedIn or from a third-party data provider to update information about you in our contact database.

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

Pseudonymous Information

If you choose to enroll in a clinical trial sponsored or organized by Spinogenix, you will be asked to sign a separate informed consent form that describes the trial and confirms that you wish to participate. Your participation is voluntary, and you can withdraw at any time.

By consenting to the trial, you confirm that you understand and agree that we will receive certain pseudonymous information about you from Site Staff in connection with that trial. This can include general demographic information, medical history and diagnostic details related to the trial, and information about the particular clinical trial site you visited.

YOU WILL NOT BE IDENTIFIED ON ANY TRIAL-RELATED MATERIAL BY YOUR NAME, ADDRESS, TELEPHONE NUMBER, OR ANY OTHER DIRECT IDENTIFIER. INSTEAD, A UNIQUE PARTICIPANT IDENTIFICATION NUMBER WILL BE ASSIGNED TO YOU AND USED FOR ALL TRIAL-RELATED MATERIALS AND DATA. SITE STAFF WILL KEEP A LIST THAT MATCHES PARTICIPANT IDENTIFICATION NUMBERS TO PARTICIPANT NAMES, BUT SITE STAFF WILL NOT SHARE THAT LIST WITH SPINOGENIX.

How We Use Your Information

We use the information described above to:

• Provide our Services (including managing your access to and use of our Services and sending you technical notices, updates, security alerts, and support and administrative messages);
• To carry out research (including supporting recruitment of study subjects, managing and facilitating trials, answering the research questions for the trial, and publishing the results);
• To plan, and/or conduct other clinical trials (including identifying suitable investigators for our studies, assessing the effectiveness of the sites participating in our clinical trials, and sharing information with potential partners in the pharmaceutical, medical device, or biotechnology industries);
• Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);
• Communicate with you (including responding to your requests, inquiries, comments, and suggestions);
• Personalize content (including tailoring content we send or display to you, offering location customization, and personalizing your experiences while using our Services);
• Further our networking, marketing, and social strategies (including notifying you about news, services, and events we think might be of interest to you and using information that we learn about you to assist us in promoting our Services);
• Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);
• Support our general business operations (including maintaining our business and legal record-keeping); and
• Carry out any other purpose described to you at the time the information was collected.

How We Share Your Information

We may share information about you with certain third parties in the following circumstances:

• Companies under common control. We may share data between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with Spinogenix.
• Vendors and service providers. We may share Personal Information with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf. This includes analytics, cloud-hosting, and email marketing services which help us operate the Main Site and Clinical Trials Site. This can also include contract research organizations; patient recruitment services; and quality assurance and safety services which we may engage to help us run our clinical trials. We contractually require vendors, consultants, and service providers to safeguard your
  Personal Information and only use it for the purposes of providing services on our behalf.
• Business transfers. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, reorganization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
• Regulatory requirements. We may disclose your Personal Information to governmental authorities for regulatory and supervision purposes, where necessary.
• Legal requirements. We may share Personal Information when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Personal Information when we believe it is necessary to protect Spinogenix’s rights and property, to protect the safety of our users, and to defend against legal liability.
• Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information.

We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to public or private researchers.

Your Rights and Choices

You have a variety of rights and choices related to our use of your Personal Information.

• Restricting cookies/Do Not Track. Spinogenix does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” signals, we will assess and provide an appropriate response to those signals.
• Accessing, updating, or deleting your Personal information. If are participating in a clinical trial and would like to access, update, or delete Personal Information you have provided, please contact Site Staff at your chosen facility directly. As described above, we only possess pseudonymized data about you and cannot identify which records relate to you. For all other requests to access, update, or delete Personal Information, please contact us at info@spinogenix.com. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business
  purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.
• Withdrawing from a clinical trial. If you wish to withdraw from participating in a clinical study, please contact Site Staff at your chosen facility directly. Please note that Personal Information collected in connection with the clinical trial prior to your
  withdrawal may still be processed after you withdraw.

Children’s Privacy
Our Services are intended for adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 18 has given us Personal Information without your consent, please contact us at info@spinogenix.com.

Links to Other Websites and Third-Party Content
We may provide links to third-party websites, services, and applications that are not operated or controlled by Spinogenix. This Privacy Notice does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.

Data Transfer
Personal Information we collect may be stored and processed for the purposes set out in this Privacy Notice in the United States where we are based or in any country where we have operations or where we engage vendors or service providers. These countries may not have the same data protection laws as the country in which you originally provided the data. By using our Services or submitting your Personal Information to us, you agree to such transfers

Data Retention
We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Notice, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Security
Spinogenix uses generally accepted administrative, physical, and technical safeguards we believe are appropriate to protect the confidentiality, integrity, and availability of your Personal Information. Although we make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet and storing information electronically. Spinogenix cannot and does not guarantee absolute security.

Changes to Our Privacy Notice
We may change this Privacy Notice from time to time to reflect changes in our practices or in the law. If we make changes to this notice, we will post the updated Privacy Notice on our website and indicate when it was last revised. You are advised to review this notice periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Notice has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Notice, to the extent permitted by law.

Contacting Us
If you have any questions about our Privacy Notice or how we protect your Personal Information please contact us at info@spinogenix.com or you may write us at 1901 Avenue of the Stars, Suite 200, Los Angeles, CA 90067.