XELLA PRIVACY PRACTICES
Last Updated: January 6, 2024
Xella Health (“Xella,” “we” or “us”) respects privacy and is committed to protecting personal information. This Privacy Policy (the “Policy”) explains our practices for handling information we may collect and use about website visitors, prospective study participants, prospective clinical sites and partners, and others with whom we interact in making our website available (the “Website”). This Policy describes the types of personal information we may receive, how we may use and disclose the information, and certain rights and options individuals may have regarding their information.
Note, if you are a participant in one of our studies, your participation and the information collected in connection with such study, is subject to and governed by the Notice of Privacy Practices made available to you in connection with your enrollment in such study.
By providing us with personal information or using the Website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Website or provide us with your information.
Important Information About This Policy
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.
To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly.
Personal Information We Receive or Collect About You
For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. Our services are directed to business professionals and owners and, as a result, the personal information we collect is often the personal information of consumers acting in a commercial context.
1. Information You Provide Personal Information we collect from you can be categorized as follows:
We collect this information when you visit or navigate our website, fill in forms on through use of our Website, submit applications or inquiries to us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources and information about you that is publicly available.
1. Automatically Collected Usage and Device Information
Like most website operators, we use various technologies to automatically collect information about visitors. Those technologies include:
The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may disclose information about your use of our website to our advertising and analytics partners, who may combine it with other information that you previously provided to them.
1. Information from Other Sources
We may obtain both personal and non-personal information about you from our vendors, affiliates, business partners, contractors, suppliers, and other third parties and add it to other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across our Website, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
D. Social Media
If you interact with us on any social media platform (e.g., Meta, X, LinkedIn), depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy. In addition, where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
How We Use Personal Information
We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.
Our Marketing Efforts
We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.
Disclosure of Personal Information
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.
In addition, we may disclose your information to the following types of third parties:
We further reserve the right to refer or disclose your information to law enforcement or regulatory authorities in the event that we believe you, other individuals, our partners or service providers, or anyone else is in danger, at risk of harm, in violation of applicable laws, or representing a safety concern.
Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
Your Choices About Personal Information
We respect your right to make choices about the ways we collect, use, and disclose your information. We try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following.
In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.
Links to Third-Party Websites
Our website may contain links to third-party websites, including the websites of vendors we use to process information on our behalf. Such websites have separate privacy policies that you should review. We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.
Children’s Privacy
Our services are intended for a general audience and are not directed at, or intended for use by, children under the age of 13 years. Accordingly, we do not knowingly collect personal information from children under age 13. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.
Changes to this Policy
Please note that we may change this Policy from time to time.If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of our Website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
How to Contact Us
For questions or more information about our privacy practices, please contact us by using the contact information provided below:
Xella Health, PBC
info@xella.bio
[phone number]