Artelo Biosciences, Inc. and its subsidiaries (collectively “Artelo,” “us,” “we” or “our”) are committed to respecting your privacy. Because facts about a person’s demographic, health, health interests, and healthcare are private and sensitive, we know that you may have concerns about sharing information with us. This Online Privacy Statement (“Statement”) is designed to answer your important questions about privacy, whether you are a consumer looking for health information, or a healthcare provider mining the experience of Artelo to refine your expertise in meeting the needs of your patients. Included in this Statement are certain disclaimers regarding the website and the information provided herein. We strongly encourage you to read this Statement in its entirety.
If you are a consumer, you’ll want to know how we use the information you provide if you register with us as a site user or when you participate in activities on our site, and how we protect this information from unauthorized use or disclosure.
If you are a healthcare professional, you’ll want to know what steps we take to protect the sensitive data you may choose to share with us, and how we use information you provide about yourself and your professional services.
We urge all users of our sites to read this Privacy Statement to learn more about the policies and practices that we have developed to safeguard personal and health information, and to better understand our relationships with the third parties who may have access to this information.
CONSENT TO PROCESSING IN THE UNITED STATES AND ELSEWHERE
This site is owned and operated by Artelo in the United States, but the information you provide will be accessible to our affiliates, vendors and suppliers in other countries. Furthermore, if you are visiting this site from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries; however, we will take the security measures described in this Privacy Statement in an effort to keep your information secure. By using this site, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.
The contents of this website (“Site”), such as text, graphics, images, and other material contained herein (“Artelo Content”) are for informational purposes only. The Artelo Content is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on the Site.
Any and all product candidates referred to on this website are experimental, have not been approved by the U.S. Food and Drug Administration or any other regulatory agency, and are not available for sale. Nothing contained on this website is intended as a promotion of any product candidate or recommendation for the use of any product candidate in a way which conflicts with the laws and regulations of the country in which you are located. The medical information and other content provided on this website is intended for general educational purposes only and is not intended as a substitute for professional medical advice, diagnosis or treatment. We currently have no commercial products. There can be no assurance that further research and development, if any, will validate and support the results of our preliminary research and studies. Further, there can be no assurance that the necessary regulatory approvals will be obtained or that Artelo will be able to develop commercially viable products on the basis of its technologies. Any reference in the Statement to product(s) refers to products that Artelo may manufacture, distribute or otherwise disseminate to the public.
If you think you may have a medical emergency, call your doctor or 911 immediately. Artelo does not recommend or endorse any specific tests, physicians, products, procedures, opinions, or other information that may be mentioned on the Site. Reliance on any information provided by Artelo appearing on the Site is solely at your own risk.
The Site may contain health- or medical-related materials that are graphic. If you find these materials offensive, you may not want to use the Site.
THE SITE AND CONTENT ARE PROVIDED ON AN “AS IS” BASIS WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.
- Information We Collect
- Information That You Voluntarily Provide
- Site Registration Interactive Services
- Correspondence with Artelo
- Information That Is Routinely Collected By Our Site Technology
- IP Address Cookies and Other Technologies
- Third-Party Advertising
- How We Use Your Information
- Personally Identifying Information
- Health-Related Information
- Product Reports
- IP Address
- Law Enforcement
- Our Relationship to Third Parties
- Cookies and Web beacons
- Vendors and Suppliers
- Co-branded Sites
- Links to Other Sites
- Social Media Plugins
- Disclosure to Subsequent Owner or Operator
- Our Children’s Policy
- Your Privacy Choices
- Receive Email
- Accept Cookies
- Do-Not-Track Signals and Similar Mechanisms
- Correct/Update Personal Information
- Remove Personal Information
- Deletion Practices
- Communicate with Artelo by Email
- Our Security Measures
- Data Security
- Changes in Our Privacy Statement
- Your California Privacy Rights
- Unsolicited Submissions
- Forward-Looking Statements
- Information We Collect
We have access to the following categories of information regarding you and your visit to our website. Only some of these categories of information identify you directly, but each category offers some information about your interests and activities that could be used to make inferences about you. The next section of this Statement describes how Artelo uses the information we collect.
Information That You Voluntarily Provide
- Site Registration. We have constructed this website so that you may visit the site and review information about the services we offer without revealing your identity or volunteering any personally identifying information. If you register to use the website’s features and services, either as a consumer or a healthcare professional, we may collect “personally identifying information” from you. Personally identifying information includes information such as name, address, telephone number, and email address. When this information is combined with any information on health or medical status (pursuant to all applicable laws), we refer to the resulting information as “health-related personal information.” If you are a healthcare professional or an institutional healthcare provider, it is your responsibility to obtain your patient’s authorization and consent to provide his or her health-related personal information to Artelo through our websites. By submitting any such information, you represent and warrant that you have obtained your patient’s authorization to do so.
- Interactive Services. If you choose to participate in our interactive services such as questionnaires and surveys, you may disclose health-related information as well as personal facts that could be used to identify you or your family members. Providers who use our benchmarking services and quality of care assessments may choose to disclose facts about their practice and patients that include extremely sensitive personal data. We do not request or require you to disclose personally identifying information in these forums, but apart from warning you to be prudent in your statements, we do not have the ability to keep you from disclosing private facts.
- Correspondence with Artelo. You may use our site to ask questions or report problems regarding our products to healthcare professionals hired by Artelo to address consumers’ and healthcare professionals’ questions regarding use of our products. If you communicate with or request information from Artelo personnel, they will have your email address as well as whatever health-related and/or personal facts you choose to include in your email. If you are reporting a product experience, we may ask you for specific facts, including patient initials, age, and gender, and prescribing physician. U.S. regulations require us to collect patient-identifiable information in order to file reports with the U.S. Food and Drug Administration regarding the safety of our products.
Information That Is Routinely Collected By Our Site Technology:
- IP Address. We record the Internet Protocol (“IP”) address of your computer when you visit our site. Without more, the IP address does not identify you personally, but it is what allows us to maintain communications with your computer as you move about our site.
- Cookies and Other Technologies. We may also collect information about your use of our site through technology such as cookies and web beacons. A “cookie is a unique numeric code that we transfer to your computer so that we can keep track of your interests and preferences and recognize you as a return visitor to our site. Cookie technology allows us to collect “clickstream” data, which is not personally identifying information, but which reflects your activities on the site, including your interest in certain healthcare conditions. A cookie does not collect or keep your name or other personal identifying information, but when you revisit our site, the cookie allows us to bring you the content and features likely to be of greatest interest to you based on your previous activities on our site. A “web beacon” is a piece of code on our site that enables us to monitor things like user activity and site traffic.
- Third-Party Advertising. We use third-party advertising companies to serve ads on other websites. These companies may use information (not including your name, address email, address, or telephone number) obtained from cookies and web beacons about your visits to this site and other websites in order to measure advertising effectiveness and to provide advertisements about goods and services of interest to you.
- How We Use Your Information
Whether you are a consumer or a healthcare professional, we use the information about your use of the services and activities on our websites to monitor user traffic patterns and try to analyze what our users prefer so that we can design better services. The personally identifying information and health-related information that you provide may be used to create customized offers, information, and services tailored to your interests and preferences.
- Personally Identifying Information. You do not have to register to use most of the information and services available for consumers on our websites. If you choose to register, we may use the personally identifying information you give us to send you an email confirming your registration with our site and to respond to questions from you. Upon your request, we may also, from time to time, send you email with special promotions or newsletters with information that we think may be of interest to you.
- Health-Related Information. If you choose to participate in our interactive services, we will collect the information you choose to disclose and analyze it to discover new facts that could help us better understand how our products are used as a treatment for which they are marketed. We may offer interactive services such as health questionnaires and care management tools that ask you to furnish health-related information about you, your family members, or, if you are a healthcare provider, your patients. The information you disclose and provide in interactive services may be linked (pursuant to all applicable laws) with the personally identifying information you may choose to provide elsewhere on our site to provide us with personally identifying information about your health and healthcare. We may combine your health-related information with that from other site users to create summary data that we will use for our business purposes, including research to improve our products and analyses that may help us better market our products. If you submit health-related personal information through our website to participate in a clinical trial, we may use that information to assess whether you qualify for enrollment in the trial, to contact you about potential participation in the trial, and to provide you with additional information about the trial. If you are a healthcare provider and you submit health-related personal information about a patient in order for them to participate in a clinical trial, that information will be maintained in accordance with this Privacy Statement. If we determine that your patient is eligible for the trial, we will use the information you submit to contact you about your patient’s potential participation in the trial and to provide you with additional information.
- Product Reports. If you contact Artelo regarding your experience in using one of our products, we may use the information you provide in submitting reports to the U.S. Food and Drug Administration, and as otherwise required of us by law. We also may use the information to contact the prescribing physician to follow up regarding an unexpected event involving use of our product.
- IP Address. In addition to using the IP address of your computer to maintain communications with your computer as you move about our site, we also may use your IP address to personalize content provided on the website. We retain IP addresses, and we retain them together with personally identifying information.
- Digital Analytics. Our Web server will install a cookie on your machine in order to aid the accuracy of a statistical program. While a profile can be built up of a user’s surfing habits through the use of this cookie, the cookie itself contains no personal information. We use these profiles to establish common surfing patterns of our users, such as which links have been clicked or documents accessed, which helps us to maintain and enhance the service we provide. This cookie will remain on your computer indefinitely, even after you leave our site.
- Law Enforcement. In certain limited circumstances, Artelo may be called upon to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the health-related personal information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to others or their property.
- Our Relationship to Third Parties
We may use third parties to provide services and information on our Site and we may provide some co-branded services in partnership with others. We also may use third parties to analyze data collected on our site. We will not disclose your personally identifying information or health-related personal information to anyone other than Artelo employees and those third parties with whom we have a business relationship. If we allow a third party contractor to have access to your personally identifying information or health-related personal information, we will not authorize them to take it or use it for any purpose that is not consistent with this Statement.
We pledge that we will not sell or disclose any personally identifying information or health-related personal information you provide on our site to an unrelated third party without your express permission, except as explained in this Statement.
- Vendors and Suppliers. We have relationships with different vendors and suppliers who help us design and maintain our systems and our computer security, respond to email and customer inquiries, analyze our data and create special promotions. We will not authorize our vendors and suppliers to use your personally identifiable information for any purpose not related to Artelo’s business operation.
- Co-branded Sites. We may partner with other companies to provide you with content or services on a joint or “co-branded” basis. At a co-branded site you will see both the Artelo logo and the logo of the co-branded partner displayed on your screen. To access the services available on a co-branded site you may have to complete a new on-line registration form, and this registration information may be shared with Artelo’s co-branded partners. You should read the individual privacy policies of our co-branded partners, as these may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site. Remember, you can always opt-out of sharing your information with a partner site by choosing not to use the service or content provided by the co-branded site.
Other Important Information About Our Relationship With Third Parties
- Social Media Plugins. This website may use social media plugins (e.g., the Facebook “Like” button, “‘Share to Twitter’” button) to enable you to easily share information with others. When you visit our website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our website, the social plugins allow that social media website to receive information that you have visited our website. The social plugins also allow the social media website to share information about your activities on our website with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allows you to see your friends’ Facebook activity on our website. Artelo does not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.
- Advertisers. We do not permit advertisers to display their advertisements on our site.
- Disclosure to Subsequent Owner or Operator. If all or part of Artelo is sold or merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no personally identifiable information that is transferred will be used or shared in a manner inconsistent with this Statement without your consent. However, in the event of a sale or merger, your continued use of this site signifies your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.
- Our Children’s Policy
Artelo’s Site content and services are intended for users over the age of 13. Our sites are not designed to attract child users. If we learn that an under-13 user has volunteered personal or health-related personal information on our site, or that a provider has volunteered information about a patient who is identified as younger than 13, we will delete such information from our active databases in accordance with our deletion policy, which is described in the section below on Your Privacy Choices.
- Your Privacy Choices
When you access any interactive tool or service on a Artelo website, you will be asked to affirmatively choose (“opt-in”) to provide the requested information. You may always choose not to provide the requested information.
- Receive Email. When you register with our site, you will be given the option of requesting to receive email with information we think you might find useful, including promotions, announcements of new services and products, and newsletters on particular health topics. If you decide, at any later time, that you no longer wish to receive these emails you may unsubscribe from our email list.
- Accept Cookies. Your browser software can be set to reject all cookies, but if you reject our cookies, certain of the functions and conveniences of our site may not work properly. Cookies and similar technologies are how we ensure that we can promptly retrieve and deliver the information to you when you use our site.
- Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. As of the Effective Date of this Privacy Statement, an industry standard has not yet been established on how to respond to these signals. Therefore, Artelo does not currently respond to these signals, but Artelo will reassess its response approach once a standard is established. Correct/Update Personal Information. You may correct or update the personal and/or health-related personal information you previously provided to the website at any time.
- Remove Personal Information. You may request removal of previously provided personal and/or health-related personal information at any time. Please read about our Deletion Practices below.
- Deletion Practices. The information that you provide Artelo is stored in servers that are operated and maintained by Artelo and third parties under contract with Artelo. Website users should be aware that it is not technologically possible to remove from our servers each and every record of the information you have provided to Artelo. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you or your health-related interests may exist in a non-erasable form that will be difficult or impossible for us to locate. Nevertheless, we promise that upon receiving your request, Artelo will delete all personal and/or health-related personal information stored in the databases Artelo actively uses for research and daily business activities, or stored in other readily searchable media. In addition, we will use commercially reasonable efforts not to disclose any personal information stored in a non-erasable format after receiving your request for removal, except as required by law. Please be aware that Artelo cannot comply with a consumer’s request to amend or remove information that was provided to Artelo by a healthcare professional or a consumer regarding an adverse drug event.
- Communicate with Artelo by Email. At our website, consumers and providers may communicate with our staff to learn more about our products and services. We also offer interactive tools that enable consumers and healthcare professionals to submit customized email requests for information about diseases and therapies. Please be aware of the limits on the confidentiality of these email communications. We will not disclose personally identifiable information that we receive in email, but all email transmissions are vulnerable to unauthorized interception. In addition, we remind you that email sent or received through an employer’s computer or computer system is not confidential and may be the legal property of the employer.
- Our Security Measures
We want your and your patients’, if you are a healthcare professional, personal information to remain as secure as reasonably possible. Our success at improving our products and services depends upon your or your patients’ willingness to share information about patient health and healthcare with Artelo.
- Data Security. We use encryption practices to help insure the integrity and privacy of some of the personal and health-related personal information you provide to us. All personal and/or health-related personal information is kept physically behind firewalls that prevent intruders from gaining access. As an added security precaution, we deploy various methods of protection such as host intrusion prevention and detection systems to maintain the integrity and confidentiality of data. Although we will make reasonable efforts to protect personal and/or health-related personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could intercept an internet transmission, or that someone will find a way to thwart our security systems.
- Changes in Our Privacy Statement
We will only use personal information in the manner described in the Privacy Statement in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Statement at any time by posting revisions to our site. If we make any material changes to this Privacy Statement, we will either notify you or place a prominent notice on our website. If at any point, we decide to use personally identifiable information or health-related personal information in a manner different from that stated at the time it was collected, you will be given a choice to allow or disallow any additional uses or disclosures of your personally identifiable information or health-related personal information.
- Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents who are individual consumers of Artelo products to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to: Artelo Biosciences, Inc. at 505 Lomas Santa Fe, Suite 160, Solana Beach, CA 92075. Be sure to include your name, address, and email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.
- Unsolicited Submissions
It is our policy not to accept or consider submissions of research, ideas, inventions, concepts, techniques or know–how other than those we have specifically requested. The intent of this policy is to avoid the possibility of future misunderstandings when products we develop might seem to you to be similar to unsolicited submissions you have made to us. Accordingly, do not send us any unsolicited research, suggestions or creative materials. Unsolicited submissions you make to us despite our policy are on a non–confidential basis and will become our property; we will be under no obligation to refrain from using or disclosing them in any way or for any purpose. No unsolicited submissions will be returned to you.
- Forward-Looking Statements
We caution you that certain statements posted on or available through this Site are forward-looking statements about Artelo within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements, other than statements of historical fact, are statements that could be deemed forward-looking statements, including, but not limited to, statements regarding our business strategy, expectations and plans, our objectives for future operations and our future financial position. The words “believe,” “may,” “could,” “would,” “will,” “plan,” “continue,” “anticipate,” “intend,” “expect,” “indicate” and similar expressions are intended to identify forward-looking statements.
Forward-looking statements are based on our current expectations and projections about future events and trends that we believe may affect our financial condition, results of operations, business strategy, short-term and long-term business operations and objectives, and financial needs. The forward-looking statements we make are subject to known and unknown risks and uncertainties that could cause our actual results, performance or achievements to be materially different from expectations indicated by such forward-looking statements. Factors that could cause or contribute to such differences include, but are not limited to: timing and cost of investigational drug development; results of pending and future clinical and nonclinical studies; lack of regulatory approvals on a timely basis or at all; insufficient operating capital; competition; risks associated with protecting proprietary rights; and those factors described in our press releases and the “Risk Factors” sections of our periodic reports and registration statements as filed with the SEC.
You are cautioned not to place undue reliance on any forward-looking statement posted on or available through this website. Each forward-looking statement posted on this website speaks only as of the date the applicable section of this website was last updated, and each forward-looking statement contained in materials available through this website speaks only as of the date we initially issued such material. Except as required by law, we undertake no obligation to update publicly any forward-looking statement or to update the reasons actual results could differ materially from those anticipated in these forward-looking statements, even if new information becomes available in the future. All forward-looking statements posted on or available through this website are qualified in their entirety by this cautionary statement.