Privacy Policy

Privacy Policy

Effective Date: May 2021

The following Privacy Policy governs the online information collection practices of Oligonucleotide Therapeutics Society (“COMPANY,” “we” or “us”). Specifically, it outlines the types of information that we gather about you while you are using the www.oligotherapeutics.org website (the “Site”), and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail).

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

How We Collect and Use Information

We may collect and store personal or other information that you voluntarily supply to us online while using the Site (e.g., while on the Site or in responding via email to a feature provided on the Site). The Site only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products. The Site collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you.

We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer’s connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. We also may use a standard feature found in browser software called a “cookie” to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.

We use the information we collect from you while you are using the Site in a variety of ways, including using the information to customize features; advertising that appear on the Site; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Site in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services. If you do not wish your information to be used for these purposes, you must send a letter to the Online Privacy Coordinator whose address is listed at the end of this Privacy Policy requesting to be taken off any lists of information that may be used for these purposes or that may be given or sold to third-parties.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Some of our third-party advertisers and ad servers that place and present advertising on the Site also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure

and research the advertisements’ effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party’s privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party’s use of cookies or web beacons or use of your information, you should visit that party’s website and review its privacy policy.

The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.

We may also make some content, products and services available through our Site or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or services. We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partner may apply to the provider partner’s use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Site or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.

Google Analytics

We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third- party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook’s Data Use Restrictions.

• Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.

• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related

General Data Privacy Regulation (GDPR)

The GDPR took effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.

As a company that markets its site, content, products and/or services online we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our site, content, products and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.

If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the “right to be forgotten.”

To make any of these requests, please contact our GDPR contact at info@oligotherapeutics.org

California Consumer Privacy Act (CCPA)

The CCPA took effect on January 1, 2020, and is intended to protect the personal information of California residents.

The CCPA has certain threshold requirements which a company must meet in order to be required to comply with its provisions. Upon information and belief, our company does not meet those thresholds. In the event of a change in our status, and if the data that you provide in the course of your use of our site, content, products and/or services is governed by CCPA, we will abide by the relevant portions of the Act.

If you are a resident of the state of California, you may have the right to: request disclosure of the personal information we have collected about you and the types of third parties with whom it has been shared; request a portable copy of your information; opt out from marketing messages or the sale of your information to third parties; and request deletion of your personal information.

To make these requests, please contact our CCPA contact at info@oligotherapeutics.org.

Children’s Privacy Statement

This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.

• This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such If we become aware that we have inadvertently received

personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.

• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third
• We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable

The HIPAA Privacy Rule

The US Department of Health and Human Services provides: “The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.”

You acknowledge that our operation of the Site does not constitute the practice of medicine, and specifically does not create a doctor-patient relationship between you and Dr. Jeffrey Bland, PhD (the “Doctor”). The information provided on the Site is for educational purposes only.

Notwithstanding the fact that the Site does not create a doctor-patient relationship between you and DOCTOR, our preservation of your personal health information shall be HIPAA compliant.

For purposes of this Privacy Policy, “patients” are those individuals who have secured the in-person services DOCTOR. If you are a patient of DOCTOR, you will be provided with a copy of DOCTOR’s HIPAA Privacy Statement, which governs the information collection practices of patients’ personal information by DOCTOR.

How do we store your information?

Your information is stored at the list server that delivers the Site content and messaging. Your information can only be accessed by those who help manage those lists in order to deliver e-mail to those who would like to receive the Site material.

All of the messaging or emails that are sent to you by the Site include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you.

Changes to this Policy

This policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Website.

Questions About this Policy

If you have any questions or concerns regarding our privacy policy please direct them to: info@oligotherapeutics.org

Notice To European Union Residents

As a European Union Resident, you enjoy certain protections under the Global Data Protection Regulation or GDPR. The GDPR is a new piece of legislation applying to users residing within the European Union. In compliance with the GDPR, We want to inform you regarding the following:

1. Personal Data We Collect

In this Policy, “Personal Data” means any information relating to an identified or identifiable individual. We may collect Personal Data about you per our description above under “Information we Collect About You.”

2. How We Use Personal Data

We use the Personal Data we collect for the purposes we list under “How Your Information is Used.”

3. Legal Basis for the Processing of Personal Data

We rely on a legal basis to process your Personal Data, including:

• Consent. You have consented to the use of your Personal Data, for example to send you electronic marketing communications or for the use of certain cookies.
• Contract. We need your Personal Data to provide you with our Website and to respond to your inquiries.
• Legal Obligation. We have a legal obligation to use your Personal Data, for example to comply with tax and accounting obligations.
• Legitimate Interest. We or a third party have a legitimate interest in using your Personal Data, for example we have a legitimate interest in using your Personal Data for product development and analytics purposes. We only rely on this legal basis when our or a third party’s legitimate interests are not overridden by your rights and interests.

4. How We Disclose Personal Data

We may disclose Personal Data about you in the following circumstances:

• Group Entities. We may disclose Personal Data about you to our affiliates and subsidiaries.
• Service Providers. We work with third-party service providers to provide services such as hosting, payment processing, maintenance, and support. These third parties may have access to or process your Personal Data as part of providing those services to us.
• Legal. We may disclose your Personal Data if we believe, in good faith, that this is appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• Merger. Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• Aggregated Information. We may use and disclose aggregated or otherwise de-identified information for any purpose, unless we are prohibited from doing so under applicable law.

5. Your Rights and Choices

Unless otherwise provided under applicable law, you have the following rights:

• Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have directly provided to us, and request information about its processing.
• Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymized or deleted, as appropriate.
• Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.
• Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Note that there are exceptions and limitations to each of these rights, and that we may nevertheless retain Personal Data about you where we reasonably believe that we have a legitimate reason to do so.

6. International Data Transfers

We may transfer your Personal Data outside of Europe and, in particular, to USA and other non-European countries, where the level of protection of Personal Data may be different than in your country. If we do so, we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision, rely on contractual protections for the transfer of your Personal Data, on Binding Corporate Rules or on the EU-U.S. Privacy Shield framework. For more information about how we transfer Personal Data outside of Europe, or to obtain a copy of the contractual safeguards we use for such transfers, please contact us as specified below.

7. Data Security and Data Retention

We use physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Data that we collect, maintain and otherwise process. We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep it for a longer period. When determining the retention period, we take into account various criteria, such as the type of products or services provided to you, the nature and length of our relationship with you, mandatory retention periods and the statute of limitations.

8. Third-Party Services

Our Website may contain features or links to websites and services provided by third parties. Any information you provide via these websites or services is provided directly to these third-party operators and is subject to their privacy policies, even if accessed through our Services. We encourage you to learn about these third parties’ policies before providing them with your Personal Data.

9. Changes and Updates to this Policy

We may update this Policy from time to time to reflect changes in our privacy practices. If we modify this Policy, we will indicate the date of the latest revision above.

10. Our Contact Information

OTS is the entity responsible for the processing of your Personal Data. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us by email to info@oligotherapeutics.org and include “Privacy Notice” in the subject line. You may also contact us by mail using the details provided below:

Oligonucleotide Therapeutics Society

info@oligotherapeutics.org