OncoPep Privacy Policy
Last Updated: February 25, 2022

This Privacy Policy describes the privacy practices of OncoPep, Inc. (“we”, “us”, or “our”) and how we handle personal information that we collect through our website, platform, and mobile applications (collectively, the “Service” or “Services”).

We may provide additional or supplemental privacy notices to individuals for specific products or services that we offer at the time we collect the personal information, for example, in connection with our clinical trials. These supplemental privacy policies govern how we may process your information in those contexts.

We treat all personal information covered by this Privacy Policy, including information about any visitors to our website, as pertaining to individuals acting as business representatives, and not in their individual or household capacity.

Personal Information We Collect

Information you provide to us:

• Contact details, such as your first and last name and email address.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Health and medical information we collect in connection with managing clinical trials, conducting research, and tracking adverse event reports.
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third Party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Healthcare organizations, such as your healthcare providers, industry and patient groups / associations.
• Research organizations, such as clinical trial investigators or contract researchers.
• Data providers, such as information services and data licensors.

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with our website and the Services (in your capacity as our customer’s authorized user), our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

• Provide, operate and improve the Services and our business;
• Communicate with you about the Services, including by sending announcements, updates, and administrative messages; and
• Provide support for the Services, and respond to your requests, questions and feedback.

Research and development. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote our business.

Marketing and advertising. We may collect and use your personal information for marketing and advertising purposes, including:

• Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via postal mail, email, telephone, text message, and other means. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.
• Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our and our customers’ and partners’ Services. We and our advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across the web, our communications and other online services, and use that information to serve online ads. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt out” section below.

Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern our website and Services; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Personal Information

We may share your personal information with:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above, that may collect information on our website through cookies and other automated technologies.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, OncoPep or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Opt out of marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communications we send you.

Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
• Google: www.adsettings.google.com
• Facebook: www.facebook.com/about/ads
• Twitter: www.twitter.com/settings/personalization
• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
• Digital Advertising Alliance for Websites: outout.aboutads.info
• Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices
• Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through our Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Job Applicants

When you visit the “Careers” portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to provide improved administration of the website, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend the rights or property of us or others; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to Contact Us

You can reach us by email at info@oncopep.com or at the following mailing address:

222 3rd Street • Suite 1100 • Cambridge, MA 02142