Tourmaline Bio, Inc., on behalf of its affiliates and subsidiaries (collectively, “Company,” “us,” “we,” or “our”) has prepared this Tourmaline Privacy Policy (“Privacy Policy”) to describe to you as an individual, or if you represent an entity or other organization, that entity or organization (in either case, “you”) our practices regarding the personal information that Company collects, uses, and shares on behalf of visitors to our website available at https://www.tourmalinebio.com/ or other websites operated by Company (each, the “Website”).
Company reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Website following posting of changes constitutes your acceptance of such changes.
1. COLLECTION OF PERSONAL INFORMATION
1.1. Personal information you may provide to us through the Website or otherwise includes:
- Activity data that we collect automatically when you visit our Website, such as IP address.
- Contact details, such as your first and last name, email and mailing addresses, and phone number.
- Business data, such as such as the company you work for, company description and job title.
- Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
- Cookies and internet activity, such as text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns.
- Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
- Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed on the Website at the time of collection.
1.2. Deidentified or Aggregate Information – Personal information does not include Deidentified and Aggregate Information. “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Company has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.
1.3. Sources of Personal Information. We obtain personal information from the following categories of sources:
- Personal Information You Provide. Company collects personal information when you voluntarily submit it to us.
- Personal Information that is Automatically Collected. In addition to personal information that we may receive directly from you, Company may indirectly collect other information from you automatically, such as log information about you, your computer or mobile device, and your activity on our Website, including pages you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Personal Information Obtained from Third Parties. Company may receive personal information about you from other third party sources, including from business partners or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
2. USE OF PERSONAL INFORMATION
Company may also use personal information for various purposes, including, without limitation, to:
- Provide, operate, maintain, and improve our Website.
- Understand and analyze the usage trends and preferences of visitors to our Website to make our Website better, diagnose technical issues, prevent fraud, and develop new features and functionality for our Website.
- Personalize your experience on the Website.
- Verify your identity.
- Communicate with you, including responding to any of your requests or questions.
- Provide you with support including responding to your feedback.
- Send you materials, updates and information from us.
- Respond to requests from law enforcement and as required by applicable law, court order, or government investigation.
3. SHARING OF PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Privacy Policy, Company may share your personal information in the following circumstances:
3.1. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.2. Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
3.3. Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, and to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of our Website; and to prevent a violation of our Terms of Use located at https://www.tourmalinebio.com/terms-of-use.
3.4. Service Providers. We may share your personal information with third parties who perform services for use or on our behalf that are reasonable for the orderly operation of the Website. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, marketing, or any other use set out in this Privacy Policy.
4. SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
5. YOUR CHOICES
You can make the following choices regarding your personal information:
5.1. Modifications to Your Personal Information. We rely on you to update and correct the personal information provided to us. Note that we may keep historical information in our backup files as permitted by law. If our Website does not permit you to update or correct certain personal information, please contact us as described below.
5.2. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, and other promotional materials related to our Website. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, to deliver notifications directly to you through the Website.
5.3. Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, the Website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
5.4. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6. NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code Sections 1798.83-1798.84, California residents who have an established business relationship with Company are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with third parties and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the Section titled “CONTACTING US” below.
7. OTHER SITES AND SERVICES
The Website may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Company is based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service.
9. CONTACTING US
If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at: info@tourmalinebio.com
Effective Date: October 3, 2022
