Pasithea

PRIVACY POLICY

 Last Updated September 9, 2021

Pasithea Therapeutics Corp. and its affiliates (“Pasithea”, “we” or “us”) are focused on the research and discovery of new and effective treatments for psychiatric and neurological disorders. We understand that the privacy of your personal information is important to you. We have prepared this Privacy Policy to inform you about how we use, disclose and otherwise manage the personal information we collect about you when you interact with us through our websites and related services.

 

A Note about Health Information

You may use our websites and services to connect with clinics and other healthcare providers in the United Kingdom and United States. In the process of connecting you to healthcare providers, we may be asked by these healthcare providers to collect certain information about your health on their behalf. In the US, this information may be regulated as Protected Health Information under the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act and their implementing regulations as amended from time to time. In the UK, this information is considered special category data governed by the UK General Data Protection Regulation . Where this is the case, we act as a “business associate” or “data processor” to the healthcare provider, and your healthcare provider’s privacy policies and our agreements with your healthcare provider will govern the use of your health information. If you have any questions about the use and disclosure of your health information, please contact your healthcare provider.

 

How We Collect Your Information

Depending on how you use our websites or services, we may collect information from you in the following ways:

  • Directly from you. We may collect information from you directly through your use of our websites or in other direct interactions with us, such as emails or phone calls. This information may include your name, address, age, email address, username and password, telephone and facsimile numbers, payment information (solely for payment purposes), and any other information you provide in the course of our interactions with you.
  •   Through automated data collection technologies. We may collect your information using automated data collection technologies as described in the “Cookies and Other Data Collection Technologies” section below. In general, you can visit our websites without telling us who you are or providing us with your personal or business information. However, we will collect the IP (Internet protocol) address of the device you use to access our websites and other browsing information, such as page requests, browser type, operating system, and average time spent on our websites. 
  •   From third parties. We may obtain your information through third party sources such as lead generation companies, marketing partners, and service providers. For example, if you are on a third party website and you opt in to receive information from us, that website will forward your contact information to us so we may contact you as requested. We may combine this information with the information we collect from you to help us tailor our communications and improve our Services.

 

How We Use Your Information

We use your information in ways you would expect based upon why you provided your information to us, such as signing you up for mailing lists, providing information about our services, facilitating our services, and responding to inquiries. We also use your information to:

  • Facilitate and improve the operation of our websites and business, including for internal review, analysis, and improvement, such as testing new features and technologies to better present, organize, and provide you with useful insights.
  • Maintain the safety, security, and integrity of our websites and our business and to comply with our legal obligations.
  • Better understand your preferences and interests so we can improve our products, tailor our marketing, and better serve you and our other customers.
  •  Respond to your feedback, suggestions, survey information, and comments.

We may also use your information for other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information, or with your consent. 

 

How We Share Your Information

In the course of our business we may disclose your information to third parties in the following circumstances:

  • Service Providers.
    We share your information with the clinics and other healthcare providers you connect with through our site and services. We also share your information with companies that provide services to us, such as helping us manage our operations and technology, payment, and marketing platforms. These service providers may have access to your information in order to perform their respective functions. It is our policy to limit our service providers’ use of your personal information to purposes related to the services they provide.
     
  • Sale of Business.
    Pasithea may transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets to a third party as part of a merger, acquisition, bankruptcy proceeding, or other restructuring.
  • Legal Purposes.
    We may provide your information if we have a good faith belief that the law requires it, such as in response to a search warrant, subpoena, or other legally valid inquiry, order, or process, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. We may also disclose information to assist us in collecting a debt, or as necessary to exercise our legal rights or defend claims brought against us.

 

Cookies and other Data Collection Technologies

Our websites use cookies. A “cookie” is a small text file that is placed on your computer or mobile device when you enter a website or a mobile app. It enables the website or mobile app to remember your actions and preferences over a period of time. While the cookies we use may change from time to time, they generally fall into one of the following categories:

  • Strictly necessary cookies.
    These cookies are strictly necessary in order for you to use the services, load and view content, and access your account.
  • Functionality cookies.
    These cookies help us remember you and personalize features and content for you on the services.
  • Preference cookies.
    These cookies allow us to capture and store your information privacy related preferences (e.g., your opt-in and opt-out), account settings, and certain login information.
  • Analytics cookies.
    These cookies help us and our service providers compile statistics and analytics about platform users, including traffic, usage, demographic, and trend data. For example, we use
    Google Analytics to help us understand how users engage with the platform. Google Analytics uses cookies to track your interactions with the platform, then collects that information and reports it to us. This information helps us improve the Platform so that we can better serve you. If you wish, you can opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on.
  • Advertising cookies.
    These cookies will display advertising on our website and on third party websites. Some of these advertisements may be interest-based, meaning that they are tailored to your interests or behaviors on our website or on other websites.

To learn more about cookies and similar technologies, please visit www.allaboutcookies.org. Most web and mobile device browsers automatically accept cookies. If you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You may also choose to opt out of receiving interest-based advertising by visiting the Network Advertising Initiative’s Opt-Out Tool.

Some web browsers incorporate a Do Not Track or DNT feature that signals to the websites that you visit that you do not want to have your activity tracked. Presently, many websites and mobile apps, including our website, do not respond to DNT signals because such signals are not yet uniform. As a result, we and third parties may track your online activities, including over time and across different sites and apps.

 
Your Rights and Choices

You have the following rights and choices with respect to the information we maintain about you:

  • Correct your information.
    You can request to correct certain personal information we maintain about you. To make such a request, please contact us using any of the methods described at the end of this Privacy Policy. 
  • Promotional Email Opt‑Out.
    We may send promotional email communications. If you have opted in or otherwise qualify to receive these forms of communication, and no longer wish to receive promotional communications by email, you may opt‑out or unsubscribe by following the instructions that are included on each email.
 
Retention of Your Information

As a general matter, we will keep your personal information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your personal information as necessary to protect our legal rights. In some circumstances we will anonymise or de-identify your personal data (so that data can no longer be associated with you) in accordance with applicable law, in which case we may use this information indefinitely without further notice to you.

 

Security of Your Information

We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, Pasithea cannot and does not ensure or warrant the security of your information.

 

Children’s Privacy

Pasithea does not knowingly collect personal information from children under the age of 13 using the Site.

 

Information for Users from Outside of the United States

If you use the Site or provide us your information from outside the United States, your information will be transferred to, stored and processed in the United States and other countries where Pasithea or its service providers operate in accordance with this Privacy Policy and applicable laws. Please note that data protection and consumer protection laws of the United States and such other countries may differ from the data protection or consumer protection laws in your country. By using the Site or providing us with your information, you understand that your information will be collected from and processed in the United States and other countries where Pasithea or its service providers operate, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

 

Additional Privacy Disclosures for Individuals in the European Economic Area and the United Kingdom

Except as described in the “A Note about Health Information” section above, Pasithea Therapeutics Corp. is the data controller responsible for the processing of your personal information collected under this Privacy Policy. Our representative in the United Kingdom and European Union is Pasithea Therapeutics Limited, who you may contact at info@pasitheaclinics.co.uk.

We collect and process your personal information on the following legal bases:

  • Consent.
    With your consent, for example, by responding to your communications or when we need to collect and process special categories of personal information;
        • If our processing is based on your consent, you may withdraw your consent for that processing at any time. Your withdrawal of consent does not affect the lawfulness of processing that was performed before you withdrew your consent.
  • Contract.
    On the basis of the performance of a contract with you, for example, by providing you the products or services that you request from us.
  • Legitimate interests.
    On the basis of our legitimate interests, which may include: Monitoring and improving the quality of our services and business activities; monitoring and improving our services; verifying your eligibility to receive products or services; evaluating your interests and preferences to better target our communications and advertisements to you; protecting the privacy, security, and safety of our business, our property, and others; ensuring compliance with internal policies and other obligations; and pursuing or defending legal claims or for other use in legal proceedings.
  • Legal Obligations.
    On the basis of a legal obligation, for example, to respond to a government inquiry or to comply with record-keeping obligations.
  • Other.
    We may also process your personal information to protect the vital interests of your or another person or as needed to carry out a task in the public interest.

When we request your personal information, you do not have to provide it. However, if you choose to not give us your personal information, we may not be able to provide you with all of our products and services.

While processing your personal information, we may transfer it to a country outside of the UK or the European Economic Area. The European Commission has created a list of countries that it has determined meet certain data privacy standards. If we make a transfer to a country that is not on that list, we will do so in accordance with our obligations under the GDPR.

As an individual in the UK or the European Economic Area, you have rights with respect to your personal information. The rights that you may exercise depend on the circumstances that surround the collection and processing of your personal information. Depending on those circumstances, you may have the following rights:

  •   To request access to your personal information;
  •   To rectify personal information that is inaccurate or incomplete;
  •   To request a copy of your personal information in electronic format so that it can be transferred to third parties;
  •   To object to the processing of your personal information;
  •   To restrict processing of your personal information;
  •   To erasure of your personal information; and
  •   To lodge a complaint with a supervisory authority.

You may exercise these rights by contacting us using the information provided in the “Contacting Us” section below.

 

Additional Privacy Disclosures for California Residents

California residents are entitled to request and obtain from us once per calendar year information about the categories of personal information we have shared with third parties for their own direct marketing purposes. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us as explained below.

 

Linked Sites

Our websites may contain links to other websites that we do not own or control. If you visit another website, we encourage you to review that website’s privacy policy to understand how that website operator will treat your information. Our Privacy Policy does not apply to these other websites.  

 

Changes to this Privacy Policy

At times, it may be necessary for us to make changes to this Privacy Policy. We reserve the right to change this Privacy Policy and any of our policies or procedures concerning the treatment of information. Where we make material changes to this Privacy Policy, we will take steps to notify you of those changes by, for example, posting notice on the websites or emailing you using the contact information we have on file. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy. We encourage you to bookmark this page and to periodically review it to ensure familiarity with the most current version of our Privacy Policy.

 

Contact Us

Please feel free to contact us at any time if you have any questions or comments about this Privacy Policy.

You can contact us or otherwise communicate your privacy concerns by:

  •   Calling us at +1 (888) 664-7284 or 02038859197 (UK Clinics)
  •   Emailing us at info@Pasithea.com or info@pasitheaclinics.co.uk (UK Clinics)
  •   Writing us at the address below (please include your email address and phone number with your correspondence along with the information needed to support your request):
    Pasithea Therapeutics Corp.
    Attn: Legal Dept
    1111 Lincoln Road, Suite 500
    Miami Beach, FL 33139