Privacy

Introduction

GRI Bio, Inc and its subsidiaries (collectively, “GRI Bio”) may operate a variety of websites (individually a “Site” and collectively the “Sites”) designed to provide you with information and services, including but not limited to health resources, clinical information, and corporate news. Whether you are a patient, healthcare provider, investor, or job applicant, respect for the privacy of your personal information is very important to us. This policy describes how we handle information we learn about you when you visit any of our Sites. GRI Bio Sites that display this policy (“Policy”) are committed to collecting, maintaining and securing your personal information in accordance with the terms of this policy.

By using this Site or sending GRI Bio your information, you accept the provisions of this Policy.

What information do we gather?

GRI Bio will not collect personally identifiable information about you unless you provide it voluntarily. You can use many of our Sites without telling us who you are or revealing any personal information. Depending on which Site you visit, you may not be able to receive certain information unless you agree to provide us with personally identifiable information. The type of information collected from you will be based on the specific program that you register for, as indicated at the time of your registration. The information that we may ask you to provide may include your first and last name, your mailing address, your age, birth date, email address, and information about your medical conditions. GRI Bio limits the collection and processing of personal information to what is necessary to fulfill the purposes for which it is to be used. GRI Bio will request your consent to collect your personally identifiable information when you register for a program or service. We will also offer you the option of discontinuing your consent (“opting out” or “unsubscribing”) if you later decide that you no longer want to participate in that program or receive additional information from us. In these circumstances, we may need to continue for a limited period of time to process personally identifiable information that we collected from you prior to your revocation of consent in order to protect our legal rights and interests.

Where permitted by law, non-personally identifiable information and data may be automatically collected through the standard operation of GRI Bio’s Internet service or through the use of “cookies” or “internet tags” and other similar techniques. Cookies are small text files that are sent to your computer when you visit a Site. Cookies on GRI Bio Sites do a lot of different jobs, such as letting you navigate between pages efficiently, storing your preferences, and generally improving your experience with a Site.  There are two types of cookies, Session Cookies and Persistent Cookies.  Session cookies are temporary cookie files, which are erased when you close your browser. When you restart your browser and go back to the site that created the cookie, the Site will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the site uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser.  Persistent cookies remain on your hard drive until you erase them or they expire. How long a cookie remains on your browser depends on how long the visited Site has programmed the cookie to last. This type of anonymous information allows GRI Bio to evaluate customer interest in its Sites and perform other market research activities. Cookies are small text files that a Site can use to recognize repeated usage, facilitate the user’s access to and use of the site and allow a site to track usage behavior and compile aggregate data that will allow content improvement. Generally, cookies work by assigning a unique number to the user that has no meaning outside of the assigning site. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. GRI Bio also may collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our Site; or the Internet address of the Site from which you linked directly to our Site. We may provide opportunities to contact us to ask questions or provide comments, ideas, and/or suggestions. When you communicate with us and request a response, we may ask you for additional information such as your name, email address, and contact information. If we collect this type of information, we will notify you as to why we are asking for it and how this information will be used. Your provision of such information to us is entirely voluntary.

Data Integrity and Security

GRI Bio takes reasonable steps to ensure that personal data collected are reliable for its intended use, accurate, complete, and current. We use appropriate technical, administrative, and physical safeguards to protect data that pertains to you from loss, misuse or alteration. In addition, we take steps to ensure that our safeguards take into account new known threats. Of course, no organization can guarantee the absolute security of personal information. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100% secure or error-free. Accordingly, we also caution you to guard your own computer and password against unauthorized access by others.

Sharing Your Information with Third Parties

GRI Bio will not share your personal information with third-parties for their own independent use unless we have obtained your opt-in consent to do so unless GRI Bio is be required to share your information with third-parties who have not been retained by GRI Bio such as with health authorities to report possible adverse drug experiences, during inspections or audits, as a result of a due diligence conducted as part of a possible merger or acquisition or as ordered or directed by courts or other governmental agencies. Many entities receiving personally identifiable information under these conditions have privacy requirements that apply to their handling of your information.

When you provide personally identifiable information to GRI Bio, it will be accessible to some of GRI Bio’s third-party vendors or contractors, service providers, such as companies we retain to fulfill requests for information, answer telephone calls or provide assistance to us on specific programs or projects. In those cases, the other companies may also have access to your personally identifiable information. GRI Bio requires third-parties to whom it discloses personal data to protect personal information using substantially similar standards to those required by GRI Bio. We also require that they do not use your personal information for any independent use that is not specifically authorized by GRI Bio.

Sharing Your Information within the GRI Bio Group of Companies

In addition to the above circumstances, the information that you provide to GRI Bio may sometimes be shared with other departments within GRI Bio, as well as GRI Bio subsidiaries and affiliates, and this may mean that your personally identifiable information may be transferred outside of the U.S. to GRI Bio affiliates or companies in other countries. Other departments within the GRI Bio group, and other GRI Bio companies that may receive your information, will abide by substantially similar privacy requirements relating to your personally identifiable information.

Updating and Accessing Your Information

If you have provided information to us, we encourage you to update the information periodically. This will help us continue to provide information to you that best meets your needs.

In addition, GRI Bio complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. In addition, in order to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of your identity.

If you wish to access or correct your information, where it is incorrect, you can contact the GRI Bio Legal Department and we will respond to your request.

Children’s Online Privacy

GRI Bio’s Sites are not directed at children. Our Sites are designed for individuals who are 18 years of age or older. For more information about protecting the privacy of children online in the United States under the Children’s Online Privacy Protection Act, please see http://www.ftc.gov/ogc/coppa1.htm (last accessed May 2018).

Links and Third-Party Sites

GRI Bio’s Sites may contain links or references to third-party websites. This policy does not cover the practices of those websites. Accessing these sources requires that you leave GRI Bio’s Sites. GRI Bio does not control the content of these third-party websites, and GRI Bio is not responsible for the privacy practices of those websites. Please review the privacy policies on each website that you visit.

European Union (EU) Data Protection (EU General Data Protection Regulation – GDPR)

To the extent GRI Bio receives or processes personal data directly from an individual located in the EU or European Economic Area (EEA) via this Site, or via electronic or regular mail from such individual, the following additional principles and disclosures pursuant to Article 13 GDPR shall apply:

(a) Identity and the contact details of the controller: GRI Bio Pharmaceuticals Inc. Two Logan Square, Suite 300, Philadelphia, PA 19103, USA;

(b) Contact details for privacy matters: see below under “Contacts”;

(c) Purposes of the processing for which the personal data are intended: for marketing purposes, for information about GRI Bio’s clinical trials, or to respond to inquiries by individuals pursuant to Art. 6 (1) (a) and (b) GDPR;

(d) The recipients or categories of recipients of the personal data: employees and consultants of GRI Bio who respond to the inquires;

(e) The personal data will be stored by GRI Bio for a period necessary to respond to the inquiry of the individual and to fully resolve the query;

(f) The individual has the right at any time to request from GRI Bio access to and rectification or erasure of personal data or restriction of processing concerning the individual or to object to processing as well as the right to data portability (In these cases, please send your email request to GRI Bio’ s contact listed under “Contacts”);

(g) The individual has right to withdraw his/her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal, by sending an email to the privacy contact listed under “Contacts”;

(h) The individual has the right to lodge a complaint with his/her data protection authority against the data processing;

(i) The individual is obliged to provide his/her personal data to GRI Bio (such as name and contact) so that GRI Bio can respond to the inquiry;

(j) GRI Bio will not use the personal data of the individual for automated decision-making, including profiling; and

(k) Where GRI Bio intends to further process the personal data for a purpose other than that for which the personal data were collected, GRI Bio will provide the individual prior to that further processing with information on that other purpose and with any relevant further information, insofar as the individual does not already have the information.

If you are visiting this site from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries; however, we will take the security measures described in this Policy in an effort to keep your personal data secure.

This Policy is effective as of August 2018. GRI Bio may update this Policy from time to time based on, among other things, changes in applicable laws, development of new Sites and advances in technology. GRI Bio reserves the right to modify, add or remove portions of this Policy at any time at our discretion. If we decide to change this Policy, we will post those changes at this site.

This Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

How to Contact Us

GRI Bio, Inc.
2223 Avenida de la Playa,
Suite 208
La Jolla, CA  92037