PRIVACY POLICY
Last Updated June 22, 2023
Pasithera Therapeutics Corp. and its affiliates (“Pasithera,” “we,” “us,” or “our”), know that data privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe how we collect and process information from and about you through our website (https://www.pasithea.com) (the “Site”), and any other website, application or digital property that links to this Privacy Policy (collectively with the Site, “Digital Properties”), and when you interact with us in any other way.
Pasithera Therapeutics Corp. is a public company traded on the Nasdaq under symbol KTTA. Personal information collected and/or received by Pasithera from and about investors who are natural persons is regulated by U.S. federal law and not by this Privacy Policy.
By accepting this Privacy Policy, accessing or using the Digital Properties, interacting with us, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Use, which together make up the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Digital Properties. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Use.
The Information We Collect
In the course of operating the Digital Properties, we may collect or receive the following types of information about you, which may include personal information.
Contact Information
We may collect contact information through our Digital Properties, which typically includes your name, email address, and any information you provide in messages to us. We use your contact information for purposes such as providing you with information about our company, responding to your inquiries, or sending you email alerts and our press releases.
Automatically Collected Information
We may automatically collect certain information each time a device accesses our servers, such as the nature of such access, Device ID and IP address, carrier and network type, user agent string (e.g., operating system and browser type/version), the pages you’ve clicked on while on our Digital Properties, and other performance and usage data. We may use this information for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.
Additional Information
We may also collect or receive your personal information from third parties, such as when you visit, use, or access the Digital Properties from third-party websites. We will do so in accordance with the terms of use and privacy policies of the third-party websites and applicable law. This includes any social media pages we may have on third-party services such as Twitter and LinkedIn. For example, we may collect the information you shared on our social media pages through an application or form, which will have a hyperlink to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about their visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. This Privacy Policy does not cover personal information collected by such third-party sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites. As permitted by applicable law, we may also collect or receive your personal information from publicly available government records, directories, and sources such as courts, tax authorities, government agencies, regulatory authorities, and law enforcement.
How We Use Your Information
We use your information as set forth above, and for the following purposes:
- To provide and personalize the Digital Properties for you;
- To monitor, support, analyze and improve the Digital Properties,
- To conduct marketing and advertising programs, provided that, where required under applicable law, we will obtain your prior opt-in consent to send electronic marketing communications;
- To offer and provide newsletters and updates regarding our research and development programs and products;
- To protect the safety and security of our Digital Properties, business, and visitors to our Digital Properties;
- To fulfill legal and regulatory requirements, and protect or exercise our legal rights; and
- As otherwise permitted by applicable law or with your consent.
How We Share Your Information
We may share your information with third parties as described below:
- Vendors and service providers, such as hosting services, technical assistance, cloud platforms, marketing/advertising companies, database managers, data back-up services, and analytics providers;
- Our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control;
- As part of the sale or other transfer of our business such as a merger, dissolution, reorganization or the sale of all or substantially all of our assets; the information we have collected or received, including personal information, will be transferred to the surviving entity in a merger or the acquiring entity;
- To protect the rights, interests, safety, and security of our business, visitors to the Digital Properties, or the public;
- To comply with applicable law and legal process, such as a search warrant, subpoena, or court order, respond to an investigative body, or as otherwise required by law.
- To exercise or enforce our legal rights or defend claims against us.
- As otherwise permitted by applicable law, or with your consent.
Cookies and other Tracking Technologies
We may collect information using “cookies” and other similar technologies such as pixels, and web beacons. Cookies are small packets of data that are stored on the hard drive (or other storage medium) of your device so that your device “remembers” information about your use. We may use both 1st and 3rd-party session cookies (which expire when you close the Digital Properties), and persistent cookies (which remain on your device for an extended period of time or until you delete them). The information collected by each cookie depends on its particular purpose. For more information, please see the information regarding analytics providers and advertisers/remarketers below.
If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of the Digital Properties may not function properly or as intended.
Third Party Advertisers/Remarketers
We may share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers, or similar partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content on our Digital Properties or other websites, applications, or online properties. These third parties may use cookies, pixel tags, or other technologies to collect information in furtherance of such purposes, including tailoring, tracking, targeting (i.e., behavioral, contextual, retargeting, and remarketing), analyzing, reporting on and/or managing advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Information that we may receive from these third parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data. By accessing and using the Digital Properties, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy.
Third Party Analytics Providers
We may use one or more third–party analytics services to evaluate your use of the Digital Properties by compiling reports on your activity and use of the Digital Properties (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, mobile and internet usage, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Digital Properties you visit, number of links clicked, search terms, demographic data, analyses of performance metrics, and other similar usage data), and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.
By accessing and using the Digital Properties, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the websites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Digital Properties.
For Google Analytics, please visit: https://www.google.com/analytics
Your Rights and Choices
If the information you have provided changes, you may correct or update it by contacting us as set forth in the section below entitled “Contact Us.” You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases.
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 reasonable 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 Digital Properties.
Information for Users from Outside of the United States
If you visit the Digital Properties or provide us with your information from outside the United States, your information will be transferred to, stored and processed in accordance with this Privacy Policy and applicable law in the United States and other countries where Pasithea or its service providers operate. 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 visiting the Digital Properties or providing us with your information, you agree that your information will be transferred to and processed in the United States and other countries where Pasithea or its service providers operate subject to applicable law in those jurisdictions.
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 Websites and Applications
Our Digital Properties may contain links to other websites or applications that we do not own or control. If you visit such other website or application, we encourage you to review its privacy policy to understand how that website or application will treat your information. Our Privacy Policy does not apply to any such linked website or application.
Changes to this Privacy Policy
This Privacy Policy is effective as of the “Last Updated” legend at the top of this page. We may update this Privacy Policy from time to time without notice to you. 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. Your continued use of or access to any of the Digital Properties following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.
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 +1 786-977-3380
- Email us at info@pasithea.com
- Write to 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: Graham Scott
1111 Lincoln Road, Suite 500
Miami Beach, FL 33139
PRIVACY POLICY
Last Updated June 22, 2023
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;-
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- 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.
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- 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