Privacy Policy
BioXcel Therapeutics, Inc. is a commercial-stage biopharmaceutical
company utilizing artificial intelligence, or AI, approaches to develop
transformative medicines in neuroscience and immuno-oncology.
BioXcel Therapeutics privacy policy
Updated October 7, 2022
Introduction
BioXcel Therapeutics, Inc. is committed to protecting and respecting your privacy. We are located in the United States with a registered office at 555 Long Wharf Drive, 12th Floor, New Haven, CT 06511. The websites we operate are directed at persons located in the United States. Clinical trial participants located in the United Kingdom and Europe should be sure to read the important information provided here.
This “Privacy Policy” describes the privacy practices of BioXcel Therapeutics and our subsidiaries and affiliates (collectively, “BioXcel,” “we,” “us,” or “our”). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with the website(s) on which we post or link to this Privacy Policy (the “Sites”), information you provide directly to us or through our service providers and business partners, and explains the rights and choices available to individuals with respect to their information.
BioXcel may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describe our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide in connection with the trial.
Personal Information We Collect
Whose Personal Information We Collect
In general, you can visit our Sites without telling us who you are or creating an account, but we may collect personal information you provide as described below. We collect personal information about the following types of individuals: clinical trial participants, patients, patient family members, caregivers or advocates, investors, physicians and other healthcare professionals, clinical trial investigators, researchers, pharmacists, users of our Sites, job applicants, and other individuals who interact directly with BioXcel, or our service providers or business partners
How We Collect Personal Information
We collect personal information:
- Directly from individuals when they contact us
- Through the Sites
- From healthcare professionals
- From contract research organizations and clinical trial investigators
- From government agencies or public records
- From third party service providers, lists we may purchase, or business partners
- From industry and patient groups and associations
- From social media or other public forums (including adverse event information and product quality complaints)
Types of Personal Information We Collect
The types of personal information we collect and share depends on the nature of the relationship you have with us and the requirements of applicable laws. We may collect:
Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatment for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency) in connection with managing clinical trials, conducting research, managing compassionate use and expanded access programs, and tracking adverse event reports.
Personal and business contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information).
Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding parents or legal guardians).
Professional credentials, educational and professional history, and institutional affiliations
Payment-related information we need to pay for professional services, such as consulting, that individuals may provide to us (such as tax identification number and financial account information). Marketing information (such as your preferences in receiving materials regarding products and services from us and our third parties and your communication preferences)
If you are a health care professional, we collect information about the programs and activities in which you have participated, your prescribing of our products and the agreements you have executed with us.
Publicly available information (such as comments describing support for and experience with BioXcel products or therapies)
Other information you provide to us when you opt in, (such as in emails, on phone calls, in market research surveys, or in other correspondence with us or our service providers or business partners).
We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide through the Sites, our service providers, or business partners
Information automatically collected
We may automatically log information about you and your computer or mobile device when you access our Sites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language or plug-ins, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Sites. We may also automatically collect technical information (such as internet protocol (IP) address, time zone setting and location, and other technology on the devices) used to access our Sites. We may also use other automatic technologies such as web server logs, pixels and web beacons.
Please refer to our Cookie Notice for more details about our use of cookies and other tracking mechanisms.
Do Not Track signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com
How We Use Your Information
We use your personal information for the following purposes and as otherwise described to you in this Privacy Policy or at the time of collection:
To operate the Sites
If you use our Sites, we may use your personal information to:
operate, maintain, administer and improve the Sites
better understand your needs and interests, and personalize your experience with the Sites
provide support and maintenance for the Sites
respond to your Service-related requests, questions and feedback
To perform and administer clinical trials, research and product-improvement activities
We may use your personal information when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including to:
staff and manage clinical trials, including by recruiting investigators and participants
track and respond to safety and product quality concerns (including product recalls)
support public health initiatives, symposia, conferences, and scientific, educational and volunteer events
develop our products
define and manage appropriate patient engagement activities, and patient support programs (including to provide co-pay and other financial assistance where available)
identify and engage thought leaders and external experts
award scholarships and grants
attribute authorship to academic and promotional materials
To provide the Sites, Products, and Services
We may use your personal information as necessary to provide BioXcel products and services, including to:
manage access to our products, including where access is limited by law to licensed physicians
pay for services that physicians, researchers and other individuals may provide to us
deliver our products
maintain and develop our business or professional relationship with you, if applicable
To communicate with you
If you sign up through our Sites to receive information about our companies or our products, or fill out our “Contact Us” form, you acknowledge that by voluntarily providing your personal information, including email and telephone number(s), you agree to receive automated calls, text messages, and emails from us and our service providers who may send these messages on our behalf, concerning the products
and information you requested. Message and data rates may apply. See the “Your Choices” section below to learn about how you can opt out of future communications from BioXcel.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
To comply with regulatory monitoring and reporting obligations
We use your personal information as we believe necessary or appropriate to comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, patient safety, and financial disclosures.
With your consent
In some cases, we may ask for your consent to collect, use or share your personal information, such as when required by law or our agreements with third parties.
To create de-identified or anonymous data for analytics
We may create de-identified or anonymous data from your personal information and other individuals whose personal information we collect. We de-identify personal data by excluding information that makes the data personally identifiable to you and use that de-identified or anonymous data for our lawful business purposes.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our websites, mobile apps, products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
Subsidiaries, Affiliates, and Related Companies
We may disclose your personal information to our subsidiaries, corporate affiliates and other related companies for purposes consistent with this Privacy Policy.
Service providers
We may engage third party companies and individuals to perform services on our behalf, including:
Contract research organizations that conduct clinical trials
Data storage and analytics
Customer service (including our medical information line) and patient support providers (including for product quality and adverse event reporting, patient co-pay assistance, medicine intake adherence programs, etc.)
Product recall administration
Technology services and support (including email and web hosting providers, marketing and advertising technology providers, email and text communications providers, mobile app developers)
Event planning and travel organizations that help facilitate Company programs
Payment, shipping and fulfillment service providers
These third parties may use your information only as directed by BioXcel and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
Healthcare providers and organizations
We may disclose your information to healthcare providers in connection with developing and delivering our products. We may also share your personal information with health care professionals, researchers, institutions, academics, public health organizations, and publishers for purposes consistent with this Privacy Policy.
Business partners
We may disclose your personal information to partners with whom we jointly develop products or services, in connection with the development and promotion of such products or services. We will ask for your consent before disclosing your information to our business partners where required by applicable law.
Professional advisors
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with laws and law enforcement; protection and safety
We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our websites, mobile apps, products and services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business transfers
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
How Long We Keep Your Information
We will keep your information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for regulatory reporting including to government entities who may oversee the safety and efficacy of Research, legal, tax, accounting or other purposes), whichever is longer. For information collected as part of Research, unless otherwise required in order for us to comply with industry regulations or law, we will
only retain your information for at least two years after the relevant drug candidate has been approved by regulators, or at least two years after an application for approval has been withdrawn.
To determine the appropriate retention period for your information, we will consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we use your information, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Additional Program Terms
In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your information, such as if you participate in a special program, activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information. We will honor these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating in any programs.
Your Choices
Changes to your personal information
If you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you may contact us at privacy@BioXceltherapeutics.com.
Opt-out of communications including marketing/investor materials
You may opt out of communications or marketing-related and investor emails by clicking the “Unsubscribe” link at the bottom of each such email. You may continue to receive service-related and other non-marketing communications by following the instructions in a particular communication (such as a text message) or by sending an email with your communication preferences to privacy@BioXceltherapeutics.com.
Choosing not to share your personal information
In general, you can visit our Sites without telling us who you are or creating an account. Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with our Sites and products and services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our products and services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means.
Your Rights
Your local laws may permit you to request that we:
provide access to and/or a copy of certain information we hold about you
prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
update or rectify information which is out of date or incorrect
delete certain information which we are holding about you
oppose, cancel, or restrict the way that we process and disclose certain information
transfer your information to a third-party provider of services
revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests, to comply with a legal obligation, or where the information provided in connection with Research is necessary in the public interest. We may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. If you would like further information in relation to your legal rights under applicable law, or would like to exercise those rights, please email privacy@bioxceltherapeutics.com. Please be sure to include your name, address (including the state where you reside), and email address so we can respond to your request in the time frame required under your state’s laws.
Security
The security of your personal information is important to us. We take a number of organizational, technical, and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information. We have implemented procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Children
We do not knowingly collect personal information from children under age 13 in any country through our Sites. If we learn that we have collected personal information directly from a child under the age of 13 through our Sites, we will take reasonable steps to delete that information as soon as practicable. If you believe someone under the age of 13 has provided us with personal information, please email privacy@BioXceltherapeutics.com.
International Data Transfers
The Sites are intended for use in the United States, where BioXcel is headquartered. We may engage certain service providers in other countries. Your personal information may be stored in and transferred to the United States, or locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Other Sites and Services
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by BioXcel. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third party websites or services and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by email or through the Sites as required.
Contact Us
If you have any questions or concerns about our Privacy Policy, or if you wish to submit a data subject access, deletion, or opt-out request according to the state law where you reside, please contact our privacy officer at:
BioXcel Therapeutics, Inc.
Attn: Privacy Officer
555 Long Wharf Drive, 12th Floor
New Haven, CT 06511
Please be sure to include your name, address (including the state where you reside), and email address so we can respond to your request in the time frame required under your state’s laws.
Notice to European Users
The BioXcel Sites and our products are not currently directed at or marketed to individuals located in the United Kingdom (UK) or the European Union (EU). Where trials are conducted in the UK or an EU member state, trial participants will be provided with a privacy notice along with their informed consent form, which will govern the processing of their personal information. In those instances, BioXcel is the controller of the personal information, and will treat UK or EU trial participant data in accordance with that privacy notice and applicable laws.
Cookie Notice
We use cookies to collect information about your browsing activities over time and across different websites following your use of our Sites. They allow us to recognize and count the number of users, to see how users move around the Sites when they are using it and assess our internal performance and functionality needs. This helps us to improve the services we provide to you and the way the Sites works. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.
In addition to cookies that are “strictly necessary” which are required for the proper operation of our Sites, we may use the following cookies:
Functionality cookies: these cookies record information about choices you’ve made and allow us to tailor our Sites to you. These cookies mean that when you continue to use or come back to our Sites, we can provide you with our services as you have asked for them to be provided.
These cookies allow us to:
Save your location preference if you have set your location on your homepage;
Remember settings you have applied, such as layout, text size, preferences, and colors;
Show you when you are logged in; and
Store accessibility options.
Performance and Analytics cookies: these cookies help us analyze how our Sites are accessed, used, or are performing in order to provide you with a better user experience and to maintain, operate and continually improve our Sites. They allow us to count visitors and traffic to our Sites. All information collected from analytic cookies is aggregated so it is not identifiable.
These cookies allow us to:
Better understand our Sites visitors so that we can improve how we present our content;
Test different design ideas for pages, such as our homepage;
Collect information about visitors of our Sites such as where they are located and what browsers they are using;
Determine the number of unique users of our Sites;
Improve our Sites by measuring any errors that occur; and
Conduct research and diagnostics to improve product offerings.
Marketing: We may use Google pixels and Microsoft Bing marketing cookies to help in our marketing efforts.
You may opt-out of functionality cookies and performance cookies at any time by clicking the “Manage Cookies” link at the bottom of the page. You can then adjust the available sliders to “On” or “Off,” then clicking “close”..
Alternatively, you can change your preferences by changing the settings in your browser. Most browsers will allow you to choose the level of privacy settings you want. This lets you control your cookie settings so that you can:
See what cookies or other locally stored data you’ve got and delete them on an individual basis;
Block third party cookies or similar technology;
Block cookies or similar technology from websites;
Block all cookies or similar technologies from being set; or
Delete all cookies or similar technologies when you close your browser.
For more information on how to manage the most popular browsers, please see below:
