Last Updated: November 30, 2022
This Privacy Policy ("
Policy") describes how Transposon Therapeutics, Inc., and its affiliates (collectively, "Transposon" "
we" "
us" or "
our") collects, uses, and discloses information related to the users of the website ("
Website") and any other related and connected platforms and other online interactions where a link to this Policy is provided (collectively, the "
Services"). However, this Policy does not apply to any research activities including enrolling or participating in clinical research or trials.
Your use of our Services is subject to the Terms of Use, available at
https://www.transposonrx.com/termsofuse.html, which includes applicable terms governing limitations on liability and the resolution of disputes. By using the Services, you accept and agree to the practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with any Personal Information (as defined below).
Personal Information. For purposes of this Policy, unless otherwise required by applicable law, "Personal Information" means any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable with a particular individual or household, including any information that is subject to applicable data protection laws.
Collection of Personal Information
The Personal Information we collect varies depending upon the nature of the Services provided or used and our interactions with individuals.
Categories of Personal Information. While the Personal Information we collect varies depending upon the circumstances, we
may collect the following categories of Personal Information (subject to applicable legal requirements and restrictions):
- Name, contact information and other identifiers: identifiers such as a name, username, account name, address, phone number, birth date, email address, and online identifier.
- Customer records: electronic customer records containing Personal Information.
- Device information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
- Communications: direct communication, web forms, online polls, or interactions with our blogs and posts.
- Usage data: internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement.
- Location data: location information about a particular individual or device, general location information (for example, your IP address may indicate your more general geographic region).
Sources of Personal Information. We may collect Personal Information about individuals:
- Directly from you: such as when you access our website, participate in contests and promotions we offer, register to receive marketing and other communications from us, or contact us for customer support purposes.
- From third parties: such as affiliate and other third parties, public records, third-party providers of services to us (e.g., fraud detection, identity verification and security), consumer data resellers, social networks, joint marketing partners and affiliate companies.
- Related to your use of our Services: including information we collect automatically when you use our Website or interact with us, or information we derive about you and your preferences or interests based on the Personal Information we collect and our interactions with you.
Information We Collect From You. We may collect Personal Information from you related to:
- Your communications and requests: when you email us, call us, or otherwise send us communications, we collect and maintain a record of your contact details, communications and our responses.
Information We Collect from Third Parties. We may collect Personal Information about you from third-party sources (which may be combined with other Personal Information we have collected about you), such as:
- Other: we may obtain Personal Information, such as demographic information or updated contact details, from third parties; we may also collect information from public records.
Information We Collect or Derive About You Automatically. We may collect or derive Personal Information about your use of our Services, or other interactions with us.
- Website: We and our third-party providers may use cookies, pixels, tags, log-files, and other technologies to collect information about a user from their browser or device, including, without limitation, your browser type, device type, operating system, software version, phone model, phone operating system, platform-dependent information, requested document, referring URL, date and time of your visit, clickstream data (e.g., about the pages you view, links you click and date and time stamps for your activities on our Website), and the IP address associated with your transactions in the system. The information that we collect automatically may be linked with other Personal Information we have collected.
Use of Personal Information
We and our authorized third parties will only process your Personal Information where we have legal grounds to do so. We may use Personal Information for a variety of purposes, including, without limitation:
- Providing support and services: including to provide our Services, operate our Website and online services, and interact with you on our Services; to respond to your inquiries; to provide troubleshooting; and for other customer service and support purposes.
- Analyzing and improving our business: including to better understand how users access and use our Services and Website, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Services; to troubleshoot problems that may arise on the Services; to improve the accuracy of our customer database; to increase our understanding of our customer database; to increase our understanding of our customers; and for other research and analytical purposes.
- Personalizing content and experiences: including to tailor content we send or display on our Website and other Services and to otherwise personalize your experiences. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences.
- Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services, products, or other information we think may interest you; and to identify potential new customers.
- Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third-party, or other unauthorized activities or misconduct.
- Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
- Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
- Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests.
- To perform any contracts in place between us and you: where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Aggregate and De-identified Data. We may de-identify information and create anonymous and aggregated data sets and reports to assess, improve and develop our business, products and Services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. This data is not Personal Information.
We may combine information from different sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third-party with information we already have.
If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and have informed that other person about the contents of this Policy.
Disclosure of Personal Information
We may share or disclose the Personal Information we collect as follows:
- Service providers: We may disclose Personal Information with third-party service providers who use this information to perform services for us, such as hosting providers, researchers, clinical investigators, clinical research partners (such as CROs), auditors, advisors, consultants, customer service and/or support providers.
- Subsidiaries, affiliates, and business partners: We may share your Personal Information with our affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); they may use such Personal Information for the purposes set out in this Policy.
- Legal compliance: We may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain Personal Information when we believe that doing so is reasonably necessary to protect the rights, property and safety of our company and/or others.
- Business transfers: We may disclose and/or transfer Personal Information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
- Protect our rights: We may disclose Personal Information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect our and our affiliates, partners, clients, customers and/or others' rights, property, or safety.
Aggregated and De-identified Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and/or other purposes.
What happens if you do not provide us with the Personal Information we request or ask that we stop processing your Personal Information?
If you do not provide the Personal Information we request, or if you withdraw your consent to the processing of your Personal Information, then you may be unable to use the Services.
Automated Decisions
Automated decisions are those made without human intervention that have a legal effect on you or other similarly significant effect. We do not carry out this type of processing activity.
Cookies and Analytics
Our Website uses automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Website and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to
www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at
https://tools.google.com/dlpage/gaoptout.
Children's Privacy
Our Website is restricted for users of legal age and children under the age of 13 are not allowed to use our Services. We do not knowingly collect or maintain Personal Information from children we actually know at the time of collection are under the age of 13. Should we discover that we have collected Personal Information online from a child who is under 13, we will promptly delete that Personal Information. If you have concerns over the collection of children's Personal Information on the Website, please contact us at the information provided in the Contact Us section below.
Security
The security of your Personal Information is important to us and we have put in place reasonable safeguards to protect the Personal Information we collect. However, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
Links to Third-party Websites
The Website provides links to various websites operated by third parties including, but not limited to, third-party sites that display our trademarks. This Policy does not apply to third-party websites that are accessible through our Services, unless such website directs users or visitors to this Policy. When you click on one of these links, you will be transferred out of the Website and connected to the website of the organization or company that maintains that website. Even if an affiliation exists between the Website and a third-party website, we exercise no control over linked websites. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. We encourage you to read the privacy policies of those other websites to learn how they collect, use, share, and secure your information before providing any Personal Information.
Retention
Except to the extent prohibited by law, and subject to this Policy, we will retain and use your Personal Information for as long as it is needed to provide you with any services, communications, information you have requested, or access to the Website, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. As soon as it is reasonable to assume your Personal Information is no longer needed or required, we will cease to retain your Personal Information, or remove the means by which the data can be associated with you.
California Shine the Light Law
Under California's "Shine the Light" law (Cal. Civ. Code

1798.83), California residents who provide us certain personal data are entitled to request and obtain from us, free of charge, information about the personal data (if any) we have shared with third parties during the immediately preceding calendar year for their own direct marketing use. We do not share your Personal Information with third parties. California residents who would like to make such a request may submit a request to the contact information provide below.
Supplemental Notice for Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at
inquiry@TransposonRX.com with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not sell Personal Information. If you have any questions, please contact us as set forth below.
Do Not Track
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Third parties may be able to collect information, including Personal Information, about your online activities over time and across different websites or online services when you use the Services. You may opt out of online behavioral ads at
http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Changes to this Policy
This Policy is kept under regular review and may be updated from time to time. When we make changes to this Policy, we will change the "Last Updated" date above. If a material change is made to this Policy, we may choose to provide notice to you in advance of such change, such as by posting notice of that change on the first page of this Policy or on our homepage, or by emailing your email address of record with us.
Changes to your Information
It is important that the information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Information changes or is inaccurate during your relationship with us by using the contact details set out below.
Contact Us
If you have any concern about our privacy practices, please contact us by email at
inquiry@TransposonRX.com, or by writing to us at: 4660 La Jolla Village Dr Suites 100 and 200, San Diego CA 92122.