Zynerba Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Zynerba Pharmaceuticals, Inc. (“Zynerba,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes information about you when you access or use our website located at https://zynerba.com/, and any other website or application owned and operated by Zynerba and its affiliates that links to this Privacy Policy (collectively, the “Site”).  This Privacy Policy describes how Zynerba handles and protects that information, and the rights and choices available to you with respect to such information.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

By using the Site and providing us with Information (defined below), you agree to the practices described in this Privacy Policy and the Cookie Notice referenced below and to the updates to these policies posted here from time to time.

If you are based in the European Economic Area (“EEA”) or European Union (“EU”), this Privacy Policy serves as notice of how we process your personal data (defined below) for which we are a controller.  If we require your consent, we will request it formally, in adherence to applicable data protection laws.

To the extent permitted by applicable law, by interacting with us and providing information to us, you agree to the collection and use of your Information in accordance with this Privacy Policy.

TABLE of CONTENTS

  1. INFORMATION WE COLLECT ABOUT YOU
    1. Information You Provide to Us
    2. Information We May Automatically Collect About You
      1. Use of Cookies and Other Technologies
      2. Do Not Track
    3. Information We May Receive from Third Parties
  2. HOW WE USE YOUR INFORMATION
    1. Use and Purpose of Processing Your Information
    2. Sharing of Information
    3. Your Rights and Choices

III. SECURITY

IV. CHILDREN UNDER 13

V. OTHER WEBSITES AND SERVICES

VI. NOTICE TO PERSONS IN THE EUROPEAN UNION OR EUROPEAN ECONOMIC AREA

  1. Your Rights
  2. Lawful Basis for Processing Your Information
  3. Consent to Transfer

VII.    HOW TO CONTACT US

VIII.       CHANGES TO THIS PRIVACY POLICY

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties.  All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.”

A. Information You Provide to Us

In using our Site, you may provide us with Information, including without limitation:

  • Contact information such as name, email address, company information, postal address, and telephone number(s);
  • Preferences for communications;
  • Access to your geo-location or to other data held on social media platforms (e.g., Twitter or LinkedIn) and other software (for example, access to your contacts, calendar, or photos);
  • When you visit the “Careers” portion of our website as a job applicant, we collect the information that you provide to us in connection with your job application. This includes personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume; and
  • Additional information as otherwise described to you at the point of collection or pursuant to your consent.

B.    Information We May Automatically Collect About You

Our Site may automatically collect certain Information about you.  We use this Information to help us design our Site to better suit our users’ needs.  This Information may include:

  • IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);
  • Date, time and length of your visit or use of our Site;
  • Domain server from which you are using our Site;
  • Type of computer, web browsers, search engine used, operating system, or platform you use;
  • Data identifying the web pages you visited prior to and after visiting our website or use of our Site;
  • Your movement and activity within the Site, including which sections of the Site have been accessed, which is aggregated with other information; and
  • Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).
1.     Use of Cookies and Other Technologies

We collect the above Information directly and through the use of third parties.  We collect this Information by using certain technologies like “cookies,” which are small data files that the Site places on your hard drive for identification purposes.  Your web browser may be programmed not to accept “cookies,” or it may allow you to be notified when you are receiving a “cookie,” thus giving you the option of accepting it or rejecting it.  You are free to decline our cookies if your browser permits but doing so may interfere with your use of the Site.  Note that unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website

We may also use technologies similar to cookies to track your interaction with the Site.  Some of these technologies may include web beacons, pixels, tags, web server logs, and Flash objects.  As with cookies, you are free to decline such technologies if your browser permits.  You should refer to your browser’s instructions to remove cached history and images from your device.  Deleting or disabling cookies will not remove Flash objects.  You should refer to Adobe’s website (http://www.adobe.com) for more information on how to disable these objects.

The Site may use Google Analytics (“Analytics Services”) to analyze and provide us with information about traffic to and use of our Site.  You can find out more information about Google Analytics cookies here:   https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.  Google may share this information with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.  To opt-out of Google Analytics relating to your use of the Site, you can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.

2.     Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not adjust the practices of our Site in response to a “Do Not Track” or similar signal.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

C.   Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as but not limited to, Twitter and LinkedIn (“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, evaluate the candidacy of job applicants and for internal marketing and research purposes.

Information we may access about you, with your consent, may include, but is not limited to, your basic Social Media Platform information, your location data, your list of contacts or followers, and certain information about your activities on the Social Media Platform.  Please keep in mind that when you provide Information to us on a third-party website, the Information you provide may be separately collected by the third-party website or the Social Media Platform.

The Information we collect is covered by this Privacy Policy, and the Information the third-party website or Social Media Platform collects is subject to that third-party website or platform’s privacy practices.  We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your Information.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

Zynerba may use the Information that it gathers for purposes that may include, but are not limited to the following:

  • to contact you to provide information about Zynerba offerings or provide email alerts (e.g., SEC alerts), including through third-party service providers who assist in disseminating this information;
  • to provide support for, promote, and improve the Site and Zynerba offerings;
  • to customize the Site to provide content most relevant to you;
  • to compare information for accuracy and verify our records;
  • to manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
  • to comply with applicable laws and regulations and respond to lawful requests;
  • to respond to your inquires;
  • to facilitate our employment recruitment activities and process employment applications;
  • to detect, investigate, and prevent activities that may violate our policies or rules or that may be otherwise illegal; and/or
  • for any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

B. Sharing of Information

We may share your Information as set forth in this Privacy Policy and in the following circumstances:

  • Zynerba may share and disclose your information with Zynerba’s business partners for our internal marketing and research purposes.
  • Third-Party Service Providers. We may share your Information with service providers who are authorized to use your Information only as necessary to support our business operations, such as those who provide data storage, technology support and services, risk solution provision, analytics, fraud prevention, employment recruitment services, legal services, and marketing/market research services.
  • Disclosure for Legal and Administrative Reasons. We may also share some of your Information without notice as otherwise permitted or required by law or as authorized by you.  Although Zynerba makes every effort to preserve your privacy, Zynerba may need to disclose or provide access to Information if Zynerba has a good faith belief that such action is necessary (i) to comply with the law, such as in connection with a judicial proceeding, court order or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to protect and defend the rights, property, or safety of us, our subsidiaries, affiliates, and any of our or their officers, directors, employees, attorneys, agents, contractors, and partners, and Site users; (iv) to enforce or apply our Terms & Conditions; and (v) to verify the identity of a user of our Site.
  • Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates.  If you do not want us to share your information with subsidiaries and affiliates, please email us at privacy@zynerba.com.
  • Business Transfers. In the event Zynerba goes through a business transition, such as a merger or an acquisition of its equity interests or assets, or a business reorganization, your Information contained or stored by Zynerba may be part of the assets transferred.
  • Aggregate and De-Identified Information. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).  We may use Aggregate/De-Identified Information for any purpose, including without limitation for our internal marketing and research purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

Except as provided in this Privacy Policy, Zynerba will not sell your Information, and Zynerba does not share your Information with unaffiliated third parties for their use for marketing purposes.

E. Your Rights and Choices

  • Email: By using our Site, you agree that we may contact you by email as set forth  If you do not want to receive emails from us such as email alerts, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of such email communications or see the section How to Contact Us.
  • Location Choices: You can change the privacy settings of your device at any time to turn off the sharing of location information with our Site.  If you choose to turn off location services, this could affect certain features or services of our Site.  If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

III. SECURITY

We use commercially reasonable efforts to maintain and provide access to the Site.  However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure.  Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure.  We do not guarantee that your Information will not be misused by third parties.  We are not responsible for the circumvention of any privacy settings or security features.  You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly contact us via the section How to Contact Us so that necessary measures can quickly be taken.

IV. CHILDREN UNDER 13

The Site is intended only for users over the age of eighteen (18) and is not intended for use by children, especially those under the age of 13.  We do not knowingly collect Information from children under the age of 13 (“Child”) through the Site.  If you are a parent or guardian and you learn that your Child has provided us with Information, please contact us.  If we discover that a Child has provided us with Information, we will take reasonable steps to delete such information from our servers.

V. OTHER WEBSITES AND SERVICES

We may provide links to other websites and online services operated by third parties, such as LinkedIn, Twitter, other third-party sites with resources for patients and caregivers, such as patient advocacy organizations, and other third-party sites that may provide access to press releases, securities filings, publications and other articles relating to our product candidates.  If you “click” on a link, the “click” may take you off our Site.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us.  We do not control third-party websites, mobile applications or online services, and we are not responsible for the privacy practices of these third parties.  Other websites and services follow different rules regarding the collection, use and sharing of your Information.  We encourage you to read the privacy policies and terms of use of the other websites, mobile applications, and online services you use.

VI. NOTICE TO PERSONS IN THE EUROPEAN UNION OR EUROPEAN ECONOMIC AREA

A. Your Rights

To the extent any European data protection laws apply, and we hold any of your “personal data” as defined in such laws (which may include some or all of your Information as defined in this Privacy Policy), and we hold such personal data in our capacity as a data controller as defined under those laws, you may request that we:

  • Restrict the way that we process and share your personal data;
  • Transfer your personal data to a third party;
  • Revoke your consent for processing of your personal data;
  • Provide you with access to your personal data;
  • Remove your personal data if no longer necessary for the purposes collected;
  • Update your personal data so it is correct and not out of date; and/or
  • Object to our processing of your personal data.

If you wish to object to the use and processing of your personal data or withdraw consent to this Privacy Policy, you can contact us in the following ways:

Contact our Compliance Officer at:
Via Email at: privacy@zynerba.com
Mail at:
Privacy
Zynerba Pharmaceuticals, Inc.
80 W. Lancaster Avenue, Suite 300
Devon, PA 19333Call us at:  484-581-7494

The requests above will be considered and responded to in the time-period stated by applicable law.  Note, certain Information may be exempt from such requests.  We may require additional information from you to confirm your identity in responding to such requests.  You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us through any of the means identified above with any concern as we would be happy to try and resolve it directly.

Representation for data subjects in the EU and the UK

We have appointed Prighter as our privacy representative and your point of contact.

If you want to contact us via our representative Prighter or exercise your data subject rights, please visit: https://prighter.com/q/16092587107/

B. Lawful Basis for Processing Your Information

As described throughout this Privacy Policy, we believe the foregoing handling of your Information, which may include your personal data, furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue.  Depending on what personal data we collect from you and how we collect it, we rely on various grounds for processing your personal data, including the following reasons:

  • To administer our contractual relationship, including setting up any services you may request;
  • Because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the information offered through the Site, other useful content, and for other marketing, design, and advertising purposes;
  • To process employee data, prevent against fraud, provide technology security, and other necessary Zynerba operational matters;
  • In order to fulfill any legal obligations, we may have to collect this Information from you; and/or
  • Because you have provided your consent for us to do so.

C. Consent to Transfer

Our Services are operated in the United States.  Please be aware that Information, including personal data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.  We collect and transfer to the U.S. only Information, including personal data: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Zynerba in a manner that does not outweigh your rights and freedoms.  We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.  We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.

VII. HOW TO CONTACT US

If you have questions or comments about this Privacy Policy, please contact us as follows:

Email: privacy@zynerba.com
Mail:
Privacy
Zynerba Pharmaceuticals, Inc.
80 W. Lancaster Avenue, Suite 300
Devon, PA 19333
Call us at: 484-581-7494

VIII. CHANGES TO THIS PRIVACY POLICY

Zynerba reserves the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by posting the amended Privacy Policy on the Site.  You should review this Policy periodically.  Your continued use of the Site after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to our privacy practices as described in the modifications.  If we decide to use particular Information collected about you in a manner materially different from that stated at the time it was collected, we will let you know through the Site, by email, or other communication.

Last updated: August 2021