Tortugas Neuroscience, Inc. (“Tortugas,” “we” or “our“) respects your privacy and recognizes the importance of protecting your personal information (“PI“). This Privacy Notice (“Privacy Notice“) explains our PI collection, use and disclosure practices.

1. Application of this Privacy Notice

This Privacy Notice applies to the PI we collect in connection with the Tortugas website at www.tortugasneuro.com (“Site“).

2. How we collect PI

The Site is informational and does not allow a user to input data. Accordingly you cannot provide to us, and we therefore do not collect, such PI via the Site. We may collect PI through automated processes, such as by cookies.

3. PI we collect

As noted, the Site is informational and does not allow a user to input data. We may collect your Internet Protocol (IP) address, and Site visit frequency through automated processes, such as cookies.

4. How we use PI

We use the PI we collect as follows:

• For our legitimate business interests: We may use PI for our legitimate business interests, for example, where it is advantageous for us to understand the effectiveness of the Site and how it is being used. We may use PI to perform analytics to improve, maintain and manage the Site and to ensure it is operating properly and productively. We may also use PI to protect our interests and to protect the interests of others.
• To comply with law: We may use PI for legal purposes, such as where we are subject to a claim, a legal obligation, or a law enforcement request, and PI is needed to comply with or otherwise address that obligation or request.

5. PI we disclose

We do not disclose your PI to third parties, except:

• To vendors, service providers and other third parties with whom we have a business relationship, such as the third-party assisting us with the development and management of the Site. We restrict these third parties by contract from using, disclosing or retaining your PI for any purpose other than for which they have been specifically contracted.
• To affiliates in connection with the purposes described in this Privacy Notice.
• To comply with law, rule, regulation, legal process or law enforcement, such as in response to a subpoena or request by law enforcement.
• For the purpose of facilitating and allowing a corporate financing, restructuring or reorganization, or another business transaction including, but not limited to, a merger, acquisition or sale of all or substantially all of our business, stock or assets, in which case the acquiring company should continue to utilize your PI in the manner for which it was provided and intended in accordance with this Privacy Notice.

6. Safeguarding your PI

We follow generally accepted standards to safeguard the PI we collect, both during transmission and when received, processed and stored, including utilization of encryption where applicable.

7. PI Retention

We retain PI only for as long as necessary for a legitimate legal or business purpose, such as:

• When mandated by law, rule, regulation, contract or similar obligations applicable to our business operations.
• For preserving, resolving, defending or enforcing our legal and contractual rights.
• When needed to maintain adequate and accurate business and financial records, including for historical data purposes.

8. Children

The Site is directed towards adults interested in biotechnology and pharmaceutical fields focused on neurological disorders. It is not intended for use by children under 18 years old. We do not knowingly collect PI from children under 18, nor do we target the Site to such children. If we become aware of PI collected from children under 18, we will delete that information. Please contact us if you have reason to believe we may have PI of children under 18.

9. Third-Party Websites

The Site may contain links to third-party websites. We are not responsible for the privacy practices of those websites. You should refer to the privacy notices of any other websites you visit for their privacy practices.

10. California Laws

10.1 California Online Privacy Protection Act (CalOPPA)

This section pertains to California consumers and addresses the CalOPPA.

“Do Not Track” Policy. The Site does not respond to Do Not Track (DNT) signals. Some websites keep track of your browsing activities. If you are using such websites, you may be able to set your preferences in settings to indicate that you do not want to be tracked. You may be able to enable or disable DNT by adjusting your preferences in the settings.

10.2 California Privacy Rights (California’s Shine the Light Law)
This section pertains to California residents, and addresses California’s Shine the Light law.
Requests Regarding Direct Marketing. Under California’s Shine the Light law, California residents with an established business relationship with us may request information once annually about sharing their PI with third parties for the third parties’ direct marketing purposes.
        We do not share PI with third parties for their direct marketing purposes.

 

11. Non-US Residents and the European Union and United Kingdom

Individuals in other countries outside the United States, such as in the European Union and United Kingdom, may have other rights granted by their local laws. This section pertains to those individuals.
The Site is neither intended nor designed for use outside the United States. Except where we expressly acknowledge otherwise or we are required by law, we make no assurances or representations of any kind that the Site is suitable for use in, or adheres to the requirements of, the country or jurisdiction in which you are located. By accessing and using the Site, you consent to the processing of your PI as provided in this Privacy Notice. You may withdraw that consent going forward by contacting us at info@tortugasneuro.com
We process PI in the United States (which has not received an adequacy decision from the European Commission or the United Kingdom Secretary of State) and may also process PI in other jurisdictions.
If at any point you believe the PI we process about you is incorrect, you may request to see the PI and to have it corrected or deleted by contacting us at info@tortugasneuro.com. If you wish to object to or raise a complaint on how we have handled your PI, you may contact us who will investigate the matter. You may also be able to receive a copy of your PI that we have on file or have your PI transferred by contacting us at info@tortugasneuro.com
If you are not satisfied with our response to an inquiry or believe we are processing your PI not in accordance with law, you may complain to the data protection authority in your jurisdiction.
The data controller for PI collected pursuant to this Privacy Notice is Tortugas Neuroscience, Inc., 405 Cochituate Rd Framingham, MA 01701.
Our person responsible for privacy is the Head of Information Technology (IT), who may be contacted at info@tortugasneuro.com Data protection matters will be addressed via e-mail at info@tortugasneuro.com

12. Changes to Privacy Notice

We may update this Privacy Notice from time-to-time. We will indicate the last revision date at the top of this Privacy Notice. Your use of the Site constitutes your acknowledgment of and agreement to this Privacy Notice in effect at that time.

13. Contact us

You may reach us by e-mail at:  info@tortugasneuro.com