Privacy notice

Last updated: May 21, 2025

Overview

Your privacy is very important to Alterome Therapeutics, Inc. (“we”, “us”, “our”). This Privacy Notice explains our practices with respect to personal data we collect, use, store and disclose (together “process”) and explains the rights and choices available to individuals.

This Privacy Notice applies to all personal data submitted to us for use with or in connection with this site and other websites or digital portals we own or operate (the “Website”) as well as personal data collected via email, all personal data collected in connection with applications for employment, personal data we collect as necessary to deliver our products or collaborate with our research partners, and all personal data we may collect when you enter our premises. Please note this Privacy Notice does not apply to Alterome’s processing of employee or contractor data.

Alterome may provide additional privacy notices to individuals at the time we collect their data (e.g., informed consent forms for clinical trial participants or recruitment disclosures for employment candidates) that describe our privacy practices in connection with specific activities and will apply to the information you provide at that time, in addition to this notice.

Please review the following to understand how we process personal data about you. By using the Website, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

Whose Personal Data We Collect?

We collect personal data about the following types of individuals: clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, contractors, consultants, job applicants, volunteers, visitors to our offices, and other individuals who interact directly with Alterome or its service providers or business partners, including users of websites and mobile applications.

What Information Do We Collect?

The types of personal data we collect and share depends on the nature of the relationship you have with Alterome and the requirements of applicable laws. The types of personal data we collect include:

  • Health and medical information we collect in connection with managing clinical trials, conducting research, providing patient support programs, and tracking adverse event reports;
  • Personal and business contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information);
  • Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians);
  • Professional credentials, educational and professional history, institutional and government affiliations, background checks, performance reviews, and information of the type included on a resume or curriculum vitae education and work history;
  • If you are a third party with whom we have or are contemplating a contractual relationship, such as a health care professional, we collect publicly available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information; 
  • Payment-related information we need to pay for services and products that individuals may provide to us (such as tax identification number and financial account information);
  • From health care professionals, we may collect information about the programs and activities in which you have participated, our interactions with you, and the agreements you have executed with us;
  • Security and access credentials such as username and password that may be created in connection with establishing an account on our website or mobile application;
  • Your photograph, social media handle or digital or electronic signature;
  • If you are a visitor to an Alterome office location, we may collect information through closed circuit television (CCTV); and
  • Other information you provide to us (such as in emails, on phone calls, through our websites or mobile applications, or in other correspondence).

How Do We Collect Information?

We collect personal data:

  • When you provide it to us directly;
  • Automatically through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Website or mobile apps;
  • From healthcare professionals;
  • From contract research organizations and clinical trial investigators;
  • From government agencies or public records;
  • From third-party sources, including service providers data brokers or business partners;
  • From industry and patient groups and associations;
  • From social media or other public forums (including adverse event information or product quality complaints); and
  • From recruiters.

Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

How We Use Your Personal Data

 To the extent permitted by applicable local law, we may use personal data for the following purposes:

  • Communicating with you about the products and services we offer, and responding to requests, inquiries, comments, and suggestions;
  • Analyzing and enhancing our communications and strategies (e.g. effectiveness of emails or our websites and mobile applications);
  • Operating, securing, and improving our business (including both physical premises digital environments);
  • Developing, personalizing customer relationship management activities, including the delivery of programs and materials, as well as surveys and market research;
  • Staffing, facilitating, conducting and managing clinical trials;
  • Tracking and responding to safety and product quality concerns (including product recalls);
  • Complying with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, spend transparency, and patient safety);
  • Defining and managing appropriate patient engagement and enrollment activities;
  • Identifying, interacting, and engaging with health care professionals, including thought leaders and external experts; and
  • Facilitating and improving our recruitment activities (such as processing employment applications, evaluating a job candidate for an employment activity, analyzing trends, and monitoring recruitment statistics).

We will specify the purpose and basis on which we intend to use personal data when we collect or begin using the personal information. In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a special program, activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information.

Sensitive Personal Data

We do not use or disclose your sensitive personal data for purposes that are not necessary to provide our products or conduct health research as are reasonably expected by an average person engaging in these activities with us.

Legal Basis for Processing Data

In some cases, Alterome has a legitimate interest to process the personal data that we collect, such as to operate, evaluate and improve our business; to facilitate and manage clinical trials or other patient advocacy and engagement programs; to promote scholarly research; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition. We may also process your personal data as necessary for the protection against criminal offenses, safeguarding of domestic law, and the maintenance of a safe workplace for staff.

In other cases, Alterome processes personal data to fulfill our contracts with our business partners, such as healthcare professionals or our research partners.

It may be also necessary for Alterome to process personal data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.

Alterome’s processing of certain health and other associated information may be necessary to comply with our legal obligations, and for reasons of public interest in the area of health or for scientific or historical research purposes, such as with respect to adverse event and product safety reporting.

Alterome may also process personal data as specifically permitted by applicable legal requirements, such as laws and regulations that authorize Alterome to process personal data for purposes of clinical trials.

If Alterome relies on consent for the processing of your personal data, we will seek such consent at the time we collect your personal data. For information on how to withdraw consent, please see the “Personal Data Access Rights” section of this Privacy Notice.

Information Collected Automatically

When you browse or use the Website, we utilize commonly used logging and analytics tools, including Google Analytics, to collect information about your device, the network used to access the Website, and information about your use of the Website (such as how you navigate and move around the Website).

We also use certain technologies on the Website, including cookies and web beacons, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your interactions with messages we send, and track activity over time and across websites.

Information collected automatically includes the software and hardware attributes of the device you use to access the Website, unique device ID information, regional and language settings, performance data about the Website, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics (including Google Analytics) that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website and track the dates and times that you use the Website, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).

Cookies and Web Beacons. We use cookies and web beacons to personalize and enhance your experience in regard to our Website, to collect data about your visit to our Website, to help diagnose problems with our servers, to administer and market the Website, to permit analytics providers to gather information about your visit to the Website, and to gather broad demographic information about our users. You can find more information about the cookies we use on our sites as well as manage your cookie preferences by accessing our Cookie Policy.

Information Obtained from Third Parties

We receive personal data from third parties that we have engaged to provide services to us, as well as from third parties that provide web analytics and usage information to us such as Google Analytics.

Sharing of Personal Data

Some of the above processing involves sharing collected personal data with third parties, including service providers and other third parties.

Alterome shares personal data for the purposes described in either this Privacy Notice or through a specific “in-time” privacy notice provided at the time we collect the information.

The types of individuals or entities we share personal data with include:

  • Alterome affiliates and research partners;
  • Service providers that perform services on our behalf, including:
    • Contract research organizations that conduct clinical trials on our behalf
    • Customer service and patient support providers (including for product quality and adverse event reporting etc.)
    • Data storage and analytics and technology providers (including technology support, marketing and advertising technology providers, software and Web developers, commercial email providers, security consultants)
    • Event planning and travel organizations that help facilitate Alterome programs;
  • Regulators worldwide, as required by law, including in connection with monitoring, review and approval of our studies, products and services, and adverse event reporting; and
  • Health care professionals, researchers, academics, and public health organizations.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.

Unless prohibited by applicable law, we may disclose personal data as part of a corporate business transaction, such as a merger, acquisition, reorganization, joint venture or the sale of our assets. We may also disclose personal data to a successor entity in the event of insolvency, bankruptcy or receivership.

Except in the event that our company undergoes a merger, corporate restructuring, or the sale of all or substantially all of our assets, we do not disclose personal data to third parties for their own direct marketing purposes or sell your Personal Data in exchange for money.

Security

We employ reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Website is or will be secure.

International Data Transfers

We may transfer your personal data to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. The countries to which we transfer personal data may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal data across borders (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we consider a variety of requirements that may apply to such transfers, but in any event we will only transfer your data to a destination and in a manner that ensures your personal data will remain protected to the same or equivalent level as in the country of origin. This may include standard contracts that have been provided by the relevant regulatory authorities, and which commit the recipient to process personal data in accordance with applicable law in the country of origin.

Your Rights and Choices

You have the ability to make certain choices exercise certain rights about how we communicate with you, and how we process your personal data. We will not discriminate against you for exercising any of your rights over your personal data. However, if you exercise these rights, it may limit our ability to process your personal data, and we may not be able to provide the products or services you requested.

We reserve the right to verify the identity of an individual in connection with any requests regarding personal data, to help ensure that we provide the information to individuals to whom the information pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

If we receive personal data about you from a third party, we will protect it as set out in this privacy notice.

Withdrawal of Consent

Where you have provided consent to us to process your personal data, you may withdraw such consent by following the instructions provided at the time of collection or by contacting us using details in the Contact Us section below. In some instances, withdrawing your consent may mean we can no longer provide products or services to you or otherwise engage with you.

Access to Personal Data

You may request access to the personal data that we maintain about you. You may request to correct any errors in your personal data. In the event we cannot comply fully with your request, we will notify you of the reasons for this.

Objection to, and Deletion of, Personal Data

To the extent provided by applicable law, you may object (opt-out) at any time on legitimate grounds to the processing of your personal data or request that we delete your personal data from our records. In some cases, we may not be able to comply with your request or comply fully. In the event we cannot comply, we will notify you of the reasons for this.

In any event, you have the right to file a complaint with a regulator or data protection supervisory authority in your jurisdiction.

You also have the right to object if we use your Personal Data for direct marketing purposes. This includes your right to request that your Personal Data not be Sold to or Shared with third parties for their own proprietary purposes including for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on that consumer’s Personal Data from a number of sources. If you wish to modify your preferences in respect to updates or notifications, you can contact us using the details provided in the Contact Us section below. All commercial and marketing communications (e.g. notification emails and newsletters) include instructions on how to opt out of those communications in the future.

When submitting a request related to any of these rights, please describe your relationship with us and your request, with sufficient detail to allow us to properly understand, evaluate, and respond to it. We will need to verify your identity before processing your request, which may require us to request additional personal data from you.

If you would like an authorized agent to exercise these rights on your behalf, you (or the authorized agent) must provide a written request including your full name and all contact details (e.g. email address, mailing address) that we have in our records and with which we can authenticate you, as well as (if applicable) the relationship with Alterome. The written request must include the full name and preferred contact details of the authorized agent. We may deny a request from an agent who cannot meet these requirements.

If you believe that we have breached relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

For Trial Participants: Please note that due to the confidentiality restrictions in place to protect participants in our trials, Alterome cannot identify an individual trial participant and therefore, we cannot respond to any request from a trial participant to withdraw from any Alterome sponsored trial or to exercise the personal data access rights outlined above. Such requests must be directed to the respective study doctor or study team who will advise you further on the necessary procedures.

Cookies and Web Tracking

It is possible to change your browser settings to block the automatic collection of certain information. Please note that disabling or removing cookies may prevent certain functionality on the Website from working correctly or at all.

Other Important Information About Personal Data and this Website

Collection of Personal Data from Children

Children under 18 years of age are not permitted to use the Website, and we do not knowingly collect information from children under the age of 18. By using the Website, you represent that you are 18 years of age. If you are under 18, do not use or provide any information to us through the Website.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from, or about, a child under 18, please contact us at privacy@alterome.com.

Third-Party Websites and Services

As a convenience, we may reference or provide links to third-party websites and services. When you access these third-party websites or services, you leave our Website, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party websites and services at your own risk. This Privacy Notice does not apply to any third-party websites or services; please refer to the privacy notice or policies for such third-party websites or services for information about how they collect, use, and process personal data.

Business Transfer

We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Website may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

Do Not Track

We use analytics systems and providers that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

Modifications and Updates to this Privacy Notice

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Website. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. Your continued use of the Website following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

Applicability of this Privacy Notice

This Privacy Notice is subject to any agreements, including the Terms of Use that govern your use of the Website. This Privacy Notice applies regardless of the means used to access or provide information through the Website.

This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

Additional Information and Assistance

Contact Us

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at:

Alterome Therapeutics, Inc.
13480 Evening Creek Drive North, Suite 450
San Diego, CA  92128
privacy@alterome.com

In order to make this Privacy Notice reasonably accessible to users with disabilities, we follow the Web Content Accessibility Guidelines (WCAG 2.1). Users with disabilities may access the Website, and this Privacy Notice, using standing navigation on the website through the aid of additional software, such as screen readers.