INTRODUCTION

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We recognize that you value, and Expansion Rx strives to respect, your privacy. It is our intention to balance our legitimate business interests in collecting and using information received from and about you with your reasonable expectations of privacy. This Privacy Policy describes the information we may collect about you (including via cookies) and how we use it, how long we store it, your rights over it and when we disclose it.

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This Privacy Policy governs the use of information collected at and submitted to Expansion Rx’s web site available at www.expansionrx.com. This Privacy Policy applies only to information collected by this site. Other activities or interactions with Expansion Rx may be governed by different privacy terms.

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If you are in the European Union, United Kingdom, or Switzerland, your personal information may be protected by the European Union General Data Protection Regulation, United Kingdom Data Protection Act, or the Swiss Federal Act on Data Protection (collectively, “European Privacy Laws”). For persons whose personal information is protected by the European Privacy Laws, please know that Expansion Rx is the data controller of any personal information that it may receive from your activities on this site. Additional information is provided later in this Privacy Policy that is specific to rights that you may have under the European Privacy Laws.
 

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TYPES OF INFORMATION COLLECTED

AND HOW WE USE IT

 

Involuntarily Collected, Non-Personally Identifiable Information

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We automatically collect information about you provided to us by your browser, including the web site you came from, the type of browser you use, your computer or device operating system type, IP address, the time and date of access, and other similar information. We may automatically collect information using “cookies”. Cookies are small data files stored on your hard drive by a site. To enable Expansion Rx to provide customized and personalized services, Expansion Rx may use cookies to store and sometimes track certain information about you as you use our site. You can control whether to allow your browser to accept cookies and configure your browser accordingly. If you choose not to allow cookies this may affect your ability to navigate from this site. We use analytics services to help analyze how users use the site. These analytics services uses cookies, web beacons, and other technological methods to collect and store information such as how often users visit the site, what features they use, what pages they visit, and what other sites they used prior to coming to the site. We use the information we get from analytics services to improve our site and product offerings. For further information about the cookies we use, please see the Cookies section below.

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Voluntarily Collected, Personally Identifiable Information

 

If you submit personal information (such as name, address, email address, and/or phone number) to us via an email or by other means from this site, we will use your personal information solely for the intended purpose for which it was submitted, such as in responding to a question that you have submitted, except as otherwise set forth below. In general, we do not share your personal information with third parties for their direct marketing purposes. We may, however, share your personal information with our contractors, agents, or business partners so that they may perform services for us, such as for our own marketing purposes. We may also provide your personal information to third parties with your consent, where such consent is required. In certain limited circumstances, we may be called upon to release your personal information in response to a court order, subpoena, search warrant, or to comply with state or federal law or regulations. We also reserve the right to disclose your information in response to suspected behavior that is illegal or harmful to other site users or any other person or entity. In addition, we may conduct research on users’ demographics, interests, and behavior based upon information you provide during use of our site. We may combine your information with information collected from other individuals to produce anonymous, aggregated statistical information that will not include your personally identifiable information. We may use and disclose this aggregated information for any purpose.

 

We do not collect any information about you that may be considered part of a “special category” of personal information, such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.
 

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HOW WE USE YOUR INFORMATION GENERALLY

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We may use your information to:

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• understand you and your preferences to enhance your experience and enjoyment using our site;

• operate, maintain, and improve our site;

• respond to comments and questions and provide customer service;

• send you information about our offerings and company developments; and

• protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and provide and deliver products and services that you request.

• If your personal information is protected by the European Privacy Laws, we must have a “legal basis”, as that term is defined in such laws, for processing your personal information. Most commonly, we will rely on one of the following legal bases:

• where we need to perform a contract or we are about to enter into or have entered into with you, we will rely on contractual necessity;

• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, we will relay on legitimate interests;

• where we need to comply with a legal or regulatory obligation we will rely on compliance with law; and

• where we have your specific consent to carry out the processing for the purpose in question, we will rely on your consent.
   

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COOKIES

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We use the following types of cookies for the purposes set out below:

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Essential Cookies

   
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for may not be able to be provided, and we only use these cookies to provide you with those services.

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Functionality Cookies

        
These cookies allow us to remember choices you make when you use the site, such as remembering your language preferences and remembering the changes you make to other parts of our site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our site.

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 Analytics and Performance Cookies

 

These cookies are used to collect information about traffic to our site and how users use our site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our site. The information collected is aggregated and anonymous. It includes the number of visitors to our site, the sites that referred them to our site, the pages they visited on our site, what time of day they visited our site, whether they have visited our site before, and other similar information. We use this information to help operate our site more efficiently, to gather broad demographic information and to monitor the level of activity on our site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

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You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

 

Targeted and advertising cookies

These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which will be relevant to your interests while you are on third party sites.

 

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our site.

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Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk. In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed. You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB. 
 

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SECURITY OF PERSONALLY INFORMATION

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No data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the absolute security of any information you transmit to us and you do so at your own risk. Once you have sent an email or other communication that includes personal information to Expansion Rx , we will store the personal information you have volunteered in accordance with our internal policies. Visitors should be aware that it is not technologically possible to remove from servers each and every record of the information you have provided to Expansion Rx . The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form or in form that will be difficult to completely erase. 

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STORAGE OF PERSONALLY INFORMATION

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We will only retain your personal information for so long as we reasonably need to use it for the purposes we collected it, unless a longer retention period is required by law.

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YOUR INFORMATION CHOICES AND RIGHTS

 

In certain circumstances, such as if your personal information is protected by the European Privacy Laws, you may have the right to:

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• request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it

• request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• object to processing of your personal information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• request the transfer of your personal information. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• withdraw consent. This right only exists where we are relying on consent to process your personal information (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our site. We will advise you if this is the case at the time you withdraw your consent.

 

If you believe these rights apply to you and you want to exercise any of the rights described above, please contact us at privacy@expansionrx.com.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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We try to respond to all legitimate requests within one month or quicker if legally required to do so. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Typically, you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances. We may not charge such a fee in the event our legal basis for using your personal information is based on your consent and you have withdrawn your consent.

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If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal information, please see below on how to contact us. We will reply to your complaint as soon as we can. If your personal information is protected by the European Privacy Laws and you feel that your complaint has not been adequately resolved, please note that you may also have the right to contact your local data protection supervisory authority. Contact details of the EU’s supervisory authorities, for example, can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

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You may “opt-out” of receiving our marketing emails by following the instructions in those emails.
 

 

INTERNATIONAL TRANSFERS

 

Information that we collect may be stored and processed in the United States or in another country in which we, our agents, or our affiliated businesses maintain operations. By using this site, you consent to any such transfer of information outside of your country. The laws relating to personal information in the United States may not be as protective of your personal information as the laws of the country you reside in.

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MERGER, SALE OR BANKRUPTCY

 

In the event that Expansion Rx is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to sell or otherwise transfer the information we have collected as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. Therefore, you should know that in such event, your personal information may be treated like any other Expansion Rx asset, and sold, transferred or shared with third parties, or used in ways not contemplated or permitted hereunder, without notice to you or your consent. 

 

VOID WHERE PROHIBITED PRIVACY POLICY

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Although the information on this site is accessible to users outside of the U.S., the information on this site pertaining to Expansion Rx products is intended for use only by residents of the U.S. Any offer made on this site for any product or service is void where prohibited.

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NO ERROR-FREE PERFORMANCE

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We do not guarantee error-free performance under this Privacy Policy. We may not always catch an unintended privacy issue, despite our efforts to do so. Accordingly, we welcome your feedback regarding any privacy concerns that you may have, including how we can improve this Privacy Policy. We will use reasonable efforts to comply with this Privacy Policy and will take prompt corrective action when we learn of any failure to comply with it.

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YOUR CONSENT

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By using our site, you consent to the collection and use of information as set forth in this Privacy Policy. You also acknowledge our right to change this policy, without prior notification, and our commitment to post any such changes on this page so that you are fully informed of the types of information we collect, how we use it, and under what circumstances, if any, it is disclosed. 

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CHANGES TO OUR PRIVACY POLICY

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This Privacy Policy may be revised periodically. We recommend that you read our Privacy Policy whenever you visit this site so that you are aware of any changes. Privacy Policy changes will be indicated by a change to the effective date at the end of the policy.

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QUESTIONS

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If you have any questions or complaints about this Privacy Policy or our privacy-related practices, please contact us at privacy@Expansionrx.com. You may also contact us by sending a letter to: Expansion Therapeutics, Inc., (Enter Address) Attention: Legal Department/Privacy.