Privacy Policy

Effective date: October 2023

Eledon Inc. and its affiliates (collectively, We or Eledon) recognizes the importance of protecting your privacy. This Privacy Policy (Policy) discloses our information-gathering and dissemination practices for our websites at www.eledon.com, and any other program or service that includes an authorized reference to or link to this Policy (Services). If you do not consent to the practices described in this Policy, then do not use the Services.

Your use of other Eledon websites, program, or services may be subject to other privacy policies. Please review the applicable privacy policy before using any website, program, or service since, depending on your relationship(s) with Eledon, we also may collect, use, or disclose personal information in ways described in those other privacy policies.

Within this Policy you will find covered matters related to the following:

  • Children
  • Information We Collect
  • Cookies Policy
  • How We Use Your Personal Information and on Which Legal Basis
  • Disclosure of Your Personal Information
  • Choices
  • Links to Third Party Sites
  • Security
  • Changes
  • Contact Information
  • Special Notice to California Residents
  • Special Notice about the General Data Protection Regulation (GDPR) in general

Children

The Services are not directed at children and we do not knowingly collect personal information via the Services from children under the age of 13. If a child provides us with this type of information online, please contact us to have the account deactivated by sending us an e-mail at info@eledon.com.

Information We Collect

We collect and store information that you provide when using the Services, such as information that you provide during account registration, information you post to Services, and information you provide in response to surveys. For example, this information may include:

  • Personal identifiers, including your name, e-mail address, and phone number;
  • Professional information and educational information, such as information about your medical specialty;
  • Medical information and other health information;
  • Demographic information, including your date of birth;
  • Geolocation information; and
  • Other types of information that you may provide to us via the Services.

If you provide us with personal information regarding another person, you are responsible for providing them a copy of this Privacy Policy.

We may also collect certain other categories of information automatically, including internet and electronic network activity information from the devices and browsers you use, such as the pages of our websites you visited, length of user session, browser type, device type, device identifiers, and/or IP address, including through the use of cookies and other tracking technologies. See “Cookie Policy” below for more information.

We may receive information from commercial sources such as companies that maintain information about healthcare providers and their specialties. We may combine the information we collect from other sources with the information we collect directly from you under this Notice and generate inferences about you.

We and our third-party partners may use cookies or other technologies, including to help us deliver content specific to your interests, to process your inquiries or requests, to analyze your visiting patterns and use of the Services, and/or to serve or track advertisements, both on and off the Services.

Cookies are small files that are placed on your computer when you visit a website. Depending on your browser, you may be able to disable the use of cookies or remove them from your computer by adjusting your browser settings. Because each browser is different, please consult your browser’s help menu for further information about the choices available to you. If you disable browser cookies, it may interfere with the proper functioning of the Services.

We use certain cookies that are considered “strictly necessary” for the regular operation and security of our websites, as well as for the provision of the services and products you request. Without these cookies, we will not be able to offer you a secure browsing on our website or provide certain other core features. For these cookies, we do not ask for your consent but we do inform you about their presence on our website.

In addition, other categories of cookies that we use and for which we may be required to ask for your consent are:

  • “Functional” cookies that help personalize services by remembering your preferences and settings. For example, they may be used to keep track of what featured products or videos have been viewed so as to avoid repetition. Another function is to measure how users interact with website content, which helps us also to improve our websites and your browsing experience with us. We generally contract with independent measurement and research companies to perform these services for us and, when this is the case, these cookies may be set by a third-party company.
  • “Advertising” cookies that gather information about your activities on our websites and other sites in order to provide you with customized advertisements that are relevant to your interests. Disabling these types of cookies will not opt you out of being served ads. You will continue to receive generic ads.

We may use first-party cookies (cookies set directly by us to your device) as well as cookies served by third parties. Third-party cookies are most commonly used for website analytics or advertising purposes.

Cookies may collect personal data (which, in some jurisdictions, would include your internet protocol (IP) address). Please consult the other sections of this Privacy Policy for more information on how we process personal data.

We and our third-party partners may also collect data by using pixel tags, web beacons, clear GIFs or similar means (collectively, pixel tags) that allow us to know when you visit the Services. These are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties. We use these to enhance your online experience and understand traffic patterns.

We and our third-party partners also may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage in connection with the Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found here.

For further information about cookies including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org.

In Europe, you may also visit www.youronlinechoices.eu to exercise choices about certain cookies.

In the U.S. you may also visit the Network Advertising Initiative’s opt-out page at http://optout.networkadvertising.org/#!/ to learn how to opt-out of third-party, interest-based targeting cookies.

How We Use Your Personal Information and on Which Legal Basis

We may use the data we collect, including your personal information for the following purposes:

  • Provide you with products and services, such as to complete registration, fulfill transactions that have been requested, and to manage the Services. We do this on the basis of the performance of a contract we have with you or on the basis of our legitimate interests to be able to provide you with our services
  • Improve our products and services, including the Services, and identify, develop, and offer new or expanded products and services. We do this on the basis of our legitimate interests to be able to provide you with relevant offers and to improve our services;
  • Personalize your experience with the Services, including customizing the content and/or format of the pages of our websites that you visit. We do this on the basis of our legitimate interests to improve your experience and improve our relationship with you, or on the basis of consent received from you;
  • Notify you about updates, products, services, and/or special offers that may be relevant to you, both on and off the Services. We do this on the basis of our legitimate interests to improve your experience and improve our relationship with you;
  • Ask you to participate in brief surveys. We do this on the basis of our legitimate interests to improve our services;
  • To secure, protect, enforce, or defend the legal rights, privacy, safety, or property of Eledon, the Services, its employees, agents, or other users, or to comply with law. We do this on the basis of our legitimate interests to protect our people, assets and clients, or to comply with a legal obligation; and
  • Conduct analysis, generate aggregate data, which is not subject to this Policy, or otherwise conduct research related to our products and services and the use of the Services. We do this on the basis of our legitimate interests to improve our services.

Disclosure of Your Personal Information

We also disclose your personal information to certain third parties with whom we have a direct or indirect business or contract relationship:

  • We may share information within our family of affiliated companies.
  • We also may share your information with those providing contractual services to us. For example, we may disclose information to third parties that provide administrative or processing services for us, for example, printing, mailing, and/or payment processing, or to those providing hosting services to us.
  • We may share your information with business partners to provide the products and services you have requested.
  • We will not share end-user personal messaging data with third parties outside of our business partners. Business partners will not use your data for any other purposes other than to provide the products and services you have requested.

We may also disclose your personal information with third parties:

  • To secure, protect, enforce or defend the legal rights, privacy, safety, or property of the Eledon, the Services, its employees, agents, or users.
  • To comply with law and in response to legal processes such as subpoenas and to cooperate with law enforcement authorities and other governmental authorities consistent with applicable laws, including, for example, to comply with regulatory requirements relating to the safety and efficacy of our products and services.
  • In connection with a corporate transaction, such as a merger or acquisition, or in connection with a bankruptcy reorganization.
  • Otherwise with your consent or at your direction, such as when you use interactive features of our Services.

Choices

You may opt-out of, or if you are a resident of Switzerland or the EEA, opt-in to receiving certain communications from Eledon, including text messages, voicemail, or e-mail. In order to opt-out, please follow the unsubscribe instructions in our emails or text messages, or contact info@eledon.com. Remember, however, that Eledon may still send e-mail or call you in order to provide a product or service that you request and for other non-commercial purposes, where permitted by law.

Although the Services currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer you choices to manage your preferences as described in the sections above. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org

Links to Third-Party Sites

The Services may contain links to other third-party websites and services. Eledon does not control the privacy policies or practices of these third-party sites. You should review those policies before providing any information. Eledon is not responsible for the content or practices of any linked third-party sites, and we provide these links solely for the convenience and information of our visitors.

Security

Eledon has established commercially reasonable safeguards to help prevent unauthorized access to or misuse of your personal information that is stored on our systems. However, no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100 percent secure. If you use Services that require a password, you should never disclose your password to anyone. Eledon will never ask you for your password in an unsolicited phone call or e-mail. You are responsible for maintaining the secrecy of your passwords and any account information.

Changes

Eledon reserves the right to change this Policy to respond to new laws, regulations, technology, or for other business reasons. Please check this Policy from time to time to review any such changes.

Contact Information

Generally, Eledon is the controller in relation to the collection and processing of personal information through the Services. If you have any questions or concerns about this Policy, you may contact us by e-mail at info@eledon.com or write to us in care of: Eledon Pharmaceuticals, Inc., 19900 MacArthur Blvd., Suite 550, Irvine, CA 92612.

Special Notice to California Residents

This section supplements the description of our information collection and sharing practices elsewhere in this Policy to provide certain disclosures to California residents whose personal information Eledon processes pursuant to the California Consumer Privacy Act (“CCPA”). Please note that these disclosures do not apply to information that is not processed under the CCPA.

During the preceding 12 months, Eledon has collected, used, and shared the categories of information described above in this Policy. For example, depending on your use of the Services this may include identifiers (e.g., email addresses, IP addresses, and device identifiers), health information, demographic information, geolocation information, and internet or other electronic network activity information. This may also include inferences we draw from the other information we collect. See the following sections of our privacy policy for details:

  • Information We Collect
  • How We Use Your Personal Information
  • Disclosure of Your Personal Information

We do not treat the ways we share your information as a sale of your information to third parties for money or other valuable consideration, although we do share your information with third parties as discussed in this Policy.

Under the CCPA, California residents may have the right to request that a business that collects consumers’ personal information give consumers additional transparency and access to the specific pieces of personal information that the business has collected about the consumer. California residents also have the right to submit a request for deletion of information under certain circumstances. Please note that these rights are not absolute. For example, we may not delete information we are required to retain for regulatory reasons, certain internal business purposes, or where otherwise provided for by law. As another example, we will not respond to a request if we cannot verify you as the requestor.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending an email to info@eledon.com.

California Civil Code Section 1798.83 permits California residents once a year to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and wish to make such a request, please send an e-mail to info@eledon.com and include the phrase California Shine the Light Request in the subject line, and provide us with your name, address and e-mail address.

Special Notice about the General Data Protection Regulation (GDPR) in general

The rights you have regarding your personal data. You have certain individual rights regarding the personal data that we collect and process about you through this website. You have the right to access or receive certain information regarding the personal data we process. You also have a right to have your personal data rectified, to object to the processing of your personal data, or to ask us to restrict processing or delete your personal data. You also have a right to data portability and the right to withdraw your consent to a certain processing activity of your personal data. Please note, however, that your rights are subject to exceptions or derogations. Where legally permitted to do so, we may refuse your request to exercise these rights. Specifically, we may need to further process and retain your personal data to comply with contractual obligations relating to you or your company or organization, to comply with legal obligations or to protect our own legitimate interests. However, you have a right to lodge a complaint with a competent supervisory authority.

How we process and protect your personal data; how long we store it. We collect and process your personal data responsibly and only for the purposes for which it was intended, as set forth in this Privacy Notice and in accordance with applicable laws. We apply adequate technical and organizational security measures, commensurate with the level of known risk, in order to protect the confidentiality and integrity of the personal data we collect on this website. We store your personal data only for as long as necessary for Eledon to fulfil the purposes for which the data was collected, or when applicable, for as long as Eledon is legally required to retain the data.

With whom we share your personal data. In connection with the features available on this website, it may be necessary to share your personal data with Eledon’ group companies and service providers. Specifically, such sharing of data may be necessary in order to respond to your inquiry, to provide access to additional information, or to follow up on your inquiry and inform you about new developments. The data sharing may include transfers to companies or organizations in countries without an adequate standard of data protection. If we transfer personal data collected in the European Union to countries without an adequate standard of data protection, we will do this through the use of standard contractual clauses adopted by the European Commission.

If you have any general questions or concerns about data protection, the Data Protection Officer can be contacted under the following address / e-mail address:

Data Protection Officer (DPO) – Eledon Pharmaceuticals, Inc.
MyData-TRUST SA
Boulevard Initialis 7/3, 7000 Mons, Belgium
Phone number: +32 (0) 65 55 41 20
email: eledonpharmaceuticals.dpo@mydata-trust.info