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Privacy Policy

Last Updated: February 2025

This Privacy Policy (“Privacy Policy” or “Policy”) explains how ITF Therapeutics LLC (“ITF,” or “we,” or “us,” or “our”) collects personal information based on your interactions with us online, including on our website(s), (“app(s)”), and offline (collectively, the “Services”). ITF Therapeutics LLC is a subsidiary of Italfarmaco S.p.A. ("Italfarmaco"), which currently holds the New Drug Application (NDA) and labeler code for Duvyzat, which is supplied to ITF Therapeutics. ITF US Holding Inc is the sole managing member of ITF Therapeutics LLC. For purposes of this Policy, "Affiliate" means any entity that directly or indirectly controls, is controlled by, or is under common control with ITF Therapeutics LLC. This includes, but is not limited to, our parent company Italfarmaco S.p.A. and our managing member ITF US Holding Inc.

This Policy describes our practices with respect to the collection and use of personal information and describes rights you may have with respect to your personal information. By using this website and otherwise interacting with us, you agree to the terms of our Terms of Use, including this Policy.

This Policy addresses the personal information we collect about you in different interactions with ITF, including when you interact with the Services (“consumer personal information”), if you apply for a job (“job-applicant personal information”), if you are an employee or contractor (“employment personal information”), and if you are a business contact (“B2B personal information”). We may collect personal information about you under different interactions. For example, if you are a business contact that navigates to our website, we may collect consumer personal information about you while you navigate our website, or when you apply for a job through our website, we may first collect consumer personal information about you on the general-audience parts of our website before collecting job-applicant personal information when you apply for the job. The Policy clarifies where the treatment of your personal information will vary based on the type of interaction.

This Policy does not apply to personal information we may collect about you during clinical trials or testing of new or modified pharmaceutical products. We may provide specific privacy disclosures, including in an informed consent form, for such specific use cases.

If you are a Washington state resident, please see our Washington Consumer Health Data Privacy Notice.

Notice at Collection

We collect, share, sell, use, and retain personal information for various purposes related to the Services and your interaction with us.

Personal Information We Collect and Purposes for Collection

We collect the following categories of personal information for the purposes described below, depending on how you interact with us:

Category (Examples – not applicable to each type of interaction) Consumer Personal Information Personal Information of Business Contacts Job-Applicant Personal Information Employee Personal Information
Personal identifiers
name, email address, your home or billing address, telephone numbers, customer number, user alias, account name and password, information related to customer reviews, IP address, mobile advertising ID, Social Security number
To provide you with the information you request and our Services; to contact you from time to time; to provide you with information about our business; to deliver advertisements and marketing promotions and offers about products we think may be of interest to you, including ours and those of our Affiliates; to analyze the placement and effectiveness of our advertisements and other marketing efforts; for customer support; for quality assurance purposes; to monitor and improve our website to prevent fraud, activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others To provide you with the information you request and our Services; to contact you from time to time; to provide you with information about our business; to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent for customer support; for quality assurance purposes To provide you with the information you request; to contact you from time to time; to provide you with information about the position in which you are interested; to evaluate your application for employment; to conduct job interviews; to improve our promotional and recruitment efforts To administer human resources functions, payroll, benefits, insurance, and other benefits-related functions; to manage personnel communications; for network and system security; to manage access to IT assets
Protected class information
age; sex/gender; ethnicity; military or veteran status
Not collected Not collected To track hiring/employment initiatives; to comply with applicable law For benefits administration; to track hiring/employment initiatives; to comply with applicable law
Commercial and financial information
records of products ordered or considered; other purchasing or consuming histories; and payment information
To deliver advertisements and marketing promotions and offers about products we think may be of interest to you, including ours and those of our Affiliates; and to analyze the placement and effectiveness of our advertisements and other marketing efforts To prevent fraud or activities that are illegal; and to protect our rights and the rights and safety of others Not collected To administer payroll and benefits
Internet or other electronic activity information
your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website and our advertisements
To deliver advertisements and marketing promotions and offers about products we think may be of interest to you, including ours and those of our Affiliates; and to analyze the placement and effectiveness of our advertisements and other marketing efforts; to prevent fraud, activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others Not collected Not collected To monitor use of company IT assets
Professional information
job title, information about your employer
Not collected To engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent To evaluate your application for employment; to conduct job interviews; to improve our promotional and recruitment efforts To identify your role
Education information
educational institutions attended, degree information, grades or grade information, classes or courses taken, certificates obtained, honors received
Not collected Not collected To evaluate your application for employment; to conduct job interviews; to improve our promotional and recruitment efforts To maintain your employment file
Biometric information Not collected Not collected Not collected To control physical access to facilities
Audio, visual information
recordings of customer service calls for quality assurance purposes; recordings of video webinars; recordings of interviews; security camera footage
For customer support; for internal business analysis For customer support; for internal business analysis To evaluate your application for employment; to conduct job interviews For training and quality assurance; to maintain security of physical facilities
Inferences drawn from personal information we collect [X] [X] [X] [X]
Sensitive personal information
Social Security number; biometric information used to identify a consumer; consumer health data; precise geolocation information
[X] [X] To track hiring/employment initiatives; to comply with applicable law To maintain employment information, facilitate payment, withhold taxes, and administer benefits

We have collected the same categories of personal information in the 12 months prior to the “last updated” date of this Policy.


Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Services, operate our business, to comply with legal obligations, or to protect our legal rights.

Categories of Personal Information We Sell or Share or Use for Targeted Advertising

When we engage in digital advertising, we may sell the following categories of consumer personal information (according to the broad definition of “sell” under select state privacy laws), share them for purposes of cross-context behavioral advertising, or use them for targeted advertising: personal identifiers (including, for example, IP address, mobile advertising IDs, etc.) and internet or other electronic activity information.

These categories of consumer personal information are sold to or shared for cross-context behavioral advertising or targeted advertising with advertising networks, data brokers and other companies that facilitate or engage in digital advertising. We engage in such sales and sharing to facilitate personalized advertising. We do so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications. For more information about the use of cookies and other tracking technologies, see the section “Our Use of Cookies and Analytics” below.

We do not sell or share for cross-context behavioral or targeted advertising any of the other categories of personal information we collect.

Categories of Third Parties to Whom We Disclose Personal Information

We disclose consumer personal information to the following categories of entities that do not operate as our processors and are not our affiliates: Advertising companies and data brokers that process consumer personal information for purposes of providing advertising and marketing services to us and other parties.

Sources From Which We Collect Personal Information

We collect consumer personal information directly from our you when you visit our website or interact with us directly through another channel or a third-party vendor supporting our business, and representatives of entities with which we do business or may do business. We also collect personal information from data aggregators and data brokers.

We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services or related to your employment with us.

No Profiling to Facilitate Decisions with Legal or Other Significant Effects

We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information we disclosed for a business purpose in the 12 months prior to the date of this Policy:

Categories of Personal Information Categories of Persons/Entities to Which We Disclosed Personal Information for Business Purposes
Personal identifiers Consumer personal information / B2B personal information: Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide legal and accounting services.
Job-applicant personal information: Service providers that assist in providing human resource functions; facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; host or facilitate teleconferencing or video conferencing services; provide legal services
Employee personal information: Service providers that assist in providing human resource functions; provide and administer benefits; facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; provide workplace analytics; provide legal and accounting services; host or facilitate teleconferencing or video conferencing services
Protected class information Job-applicant personal information / employee personal information: Service providers that manage employment information and provide analytics information
Commercial and financial information Consumer personal information / B2B personal information: Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide accounting services
Employee personal information: Service providers that assist in providing human resource functions; provide and administer benefits; provide legal and accounting services
Internet or other electronic activity information Consumer personal information: Service providers that provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytics information.
Employee personal information: Service providers that provide security services and cloud-based data storage, host our website(s) and assist with other IT-related functions, and provide analytics information
Education Information Job-applicant personal information / Employee personal information: Service providers assist in providing human resource functions; provide workplace analytics
Professional information B2B personal information: Service providers providing customer relationship management and outreach functions; facilitate scheduling and email communications; provider workplace analytics
Job-applicant personal information: Service providers that assist in providing human resource functions; facilitate scheduling and email communications; provide workplace analytics
Employee personal information: Service providers that assist in providing human resource functions; provide and administer benefits; facilitate scheduling and email communications; provide workplace analytics; provide legal and accounting services
Biometric information Employee personal information: Service providers that support building access, security, and time entry
Audio information Consumer personal information / B2B personal information: Service providers that manage customer information and provide customer service (including through a call center).
Job-applicant personal information: Service providers that facilitate virtual interviews.
Employee personal information: Service providers that facilitate and manage internal employee training content and programs.
Inferences drawn from personal information collected All personal information types: Service providers that provide analytics for customer/applicant/employee profiling, segmentation, evaluation, and performance management; advertising and marketing services.
Sensitive personal information Job-applicant personal information: Service providers that assist in providing human resource functions; provide workplace analytics
Employee personal information: Service providers that assist in providing human resource functions; provide and administer benefits; provide legal and accounting services

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; to provide human resource functions and administer benefits; to facilitate scheduling and email communications; to process payments; to verify customers’ identities; to fulfill orders and transactions; to provide cloud-based storage; to operate our IT systems and secure our systems; to engage in advertising and marketing; to prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures

We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies and to judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And, we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, or reorganization of our entity or other restructuring.

Our Cookie Policy and Analytics

This Cookie Policy explains how we use these technologies, what types of cookies we use, and how you can control them. If you accept cookies from our website, we may use cookies to automatically collect information through our website. We may also use pixel tags, web beacons and other similar tracking technologies ("tracking technologies"). Tracking technologies are small text files placed on your computer, tablet, mobile phone, or other devices in conjunction with code that runs on our website, that record certain pieces of information when you visit our website. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as to make it possible for you to save your preferences and help us understand how you interact with our Services.

Cookies and Similar Technologies

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to the website owners. Cookies are stored on your device and can be accessed by the website on subsequent visits. Similar technologies, such as web beacons and pixels, may also be used for similar purposes.

Types of Cookies We Use

We use the following types of cookies on our website:

  1. Essential Cookies: These cookies are necessary for the website to function properly. They enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. You may not opt-out of these cookies as they are crucial for the website to operate. Without these cookies, certain services you have asked for cannot be provided.
  2. Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use this information to improve our website and services. These may be first-party cookies set by us or third-party cookies set by our analytics providers.
  3. Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. For example, these cookies may remember your language preferences or allow social media sharing.
  4. Advertising Cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. These cookies may track your browsing behavior across different websites and build a profile of your interests.

Third-Party Cookies

Some cookies are placed by third parties on our website. These include:

For more information about these third-party cookies, please refer to the respective privacy policies of these providers:

How We Use Cookies

We use cookies for various purposes, including:

Your Cookie Choices

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences in the following ways:

Please note that if you choose to reject certain cookies, you may not be able to use some features of our website, specifically:

Do Not Track (DNT): Some browsers have incorporated "Do Not Track" (DNT) features. We currently do not respond to DNT signals.

Data Retention

We retain cookie data for varying periods depending on the type of cookie:

Cross-Border Data Transfers

Your information, including data collected through cookies, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data to the United States and process it there.

Children's Privacy

Our website is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us.

Updates to this Cookie Policy

We may update this Cookie Policy from time to time. The date at the top of this policy indicates when it was last revised. Any changes will become effective when we post the revised Cookie Policy on our website.

Contact Us

If you have any questions about our use of cookies, please contact us at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

Legal Basis and Your Rights (for GDPR compliance)

For users in the European Economic Area (EEA), our legal basis for processing data collected via cookies is typically legitimate interest or consent, depending on the cookie type. You have the right to:

To exercise these rights, please contact us using the information provided in the "Contact Us" section.

Personal Information of Minors

Our website is not directed to minors under the age of 13 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age.

Third Party Websites

Our website may contain links to third-party websites, including social media buttons that link to social media platforms. This Policy does not govern how those third parties or social media platforms collect or use personal information, and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

How We Keep Your Personal Information Secure

We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

Changes to This Policy

We will review and update this Policy from time to time. If changes are made, we will update the Policy and reflect the date of such modification at the top of the Policy. If the changes are material, there will be a notice on our website.

Accessibility

To make accessibility-related requests or report barriers, please contact us at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

U.S. State Data Privacy Rights

Consumer Rights Under Comprehensive U.S. State Data Privacy Laws

Depending on your state of residence, you may have certain qualified rights with respect to many types of personal information we collect, with some exceptions. The rights provided under various state laws are similar in many respects, with some differences from state to state. These rights may include:

Right to Know: The right to confirm whether or not we are processing your personal information and to access such data, and in certain states, the right to know more detailed information. For example, California’s privacy law gives residents the right to request the following additional information: Categories of personal information we have collected about them; categories of sources from which such personal information was collected; categories of personal information that the business sold or disclosed for a business purpose about the consumer; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information. Oregon’s privacy law gives residents the right to request a list of third party entities to which we have disclosed personal information.

Right to Access / Copy: The right to access or request a copy of the personal information we have collected, subject to certain exceptions.

Right to Delete: The right to request deletion of the personal information that we have collected from or about you and to have such information deleted, subject to certain exceptions.

Right to Correct: The right to request that we correct inaccuracies in your personal information, considering the nature of personal data and purposes of processing such information.

Right to Limit the Use of Sensitive Personal Information: The right to request that we not use or disclose sensitive personal information for inferring characteristics about you or for purposes other than to provide goods and services, protect and investigate fraud and other security-related issues, nonpersonalized advertising, and similar purposes described in the law.

Rights to Opt Out: Various rights to request that we stop using your personal information for one or more of the following purposes:

Consumer Rights Under U.S. State Consumer Health Data Privacy Laws

This Consumer Health Data Privacy Notice that relates to rights provided under consumer health data privacy laws, such as in Nevada and Washington State, to residents of those states acting in an individual or household context with respect to their consumer health data. Washington’s law may also apply to individuals whose consumer health data is processed in that state.

This notice supplements ITF Therapeutics' Privacy Policy and applies to Consumer Health Data collected from residents of Washington, Nevada, and Connecticut. "Consumer Health Data" includes personal information linked to your past, present, or future physical or mental health status. ITF collects data that identifies consumers seeking healthcare and their use or purchase of prescribed medication. This data is used to provide requested information and for marketing purposes. Data is collected directly from consumers. ITF may share this data with its affiliate Italfarmaco S.p.A, third-party service providers, and when legally required. You have the right to know, access, and delete your Consumer Health Data, as well as to know which third parties it has been shared with. You can exercise these rights by contacting privacy@itftherapeutics.com.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents who have an established business relationship with us to annually request information about the personal information disclosed to third parties for their direct marketing purposes in the preceding calendar year. We do not and did not make such disclosures.

Exercising Your Rights

State Privacy Data Laws Applicable to ITF Therapeutics

As of 2024, several states have enacted comprehensive consumer data privacy laws that may apply to ITF Therapeutics' operations. We are committed to complying with applicable state privacy laws and respecting the rights of residents in states where these laws are in effect.

Exercising Your Privacy Rights

If you are a resident of a state with an applicable data privacy law, you may have the following rights regarding your personal information:

To exercise these rights, please submit a request at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States. We will provide a substantive response within 45 days of receiving your request. If we need additional information or time to process your request, we will notify you.

Opt-Out Rights

Some state laws provide consumers the right to opt-out of certain data processing activities. To exercise any applicable opt-out rights, please submit your request at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

Sensitive Personal Information

Certain states grant consumers the right to limit the use of sensitive personal information. If this right applies in your state, you may submit a request to limit use of sensitive data to: ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

Applicable State Laws

As of 2024, the following state privacy laws may apply to ITF Therapeutics' data practices:

We will honor consumer rights requests from residents of states with applicable privacy laws as of the effective date of each law. The specific rights available may vary by state.

ITF Therapeutics is committed to protecting consumer privacy and complying with all applicable data protection laws. We will continue to monitor the evolving privacy law landscape and update our practices as needed to maintain compliance.

Opt-out Preference Signals and Do Not Track

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of individuals and communicates an individual’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal for California and Colorado residents based on IP address and do so at the browser level and it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, please refer to the Global Privacy Control website (https://globalprivacycontrol.org).

We will respond to opt-out requests and requests to limit the use of sensitive information as soon as feasibly possible, but no later than 15 business days after receipt of your request. If we require additional information or time to process your requests, we will contact you.

We do not respond to the DNT or “Do Not Track” signal.

Exercising Your Rights Using Authorized Agents

Agents may submit opt-out requests on behalf of individuals under several state data privacy laws; this is not an option that is available under laws in certain states (for example, Texas, Utah, or Virginia). California residents can designate an agent to submit all other types of requests. If the agent submits an opt-out request on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. Agents can submit opt-out requests privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

If you are a California resident and you use an agent to submit other types of requests, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. You will also be required to verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Agents can submit requests on behalf of California residents (other than opt-out requests) at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney. For residents of California, Colorado, and Connecticut, you may designate an authorized agent to submit requests on your behalf. For other states, please check your state's specific privacy laws regarding the use of authorized agents.

Verification of Requests

When you exercise rights other than opt-out rights and the right to limit collection of sensitive personal information, we will take steps to verify your identity. We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request and will deny it. We will notify you to explain the basis of the denial.

When We Do Not Act on a Request – Appeal Process

In some cases, we may not act on your requests (for example, if we are prohibited from acting on your request under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (for example, correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at same method used to submit requests within 30 days after your receipt of our decision.

Non-Discrimination

If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

Contact Us

If there are any questions regarding this Privacy Policy, or to request a copy of this Privacy Policy in another format you may contact us at privacy@itftherapeutics.com or ITF Therapeutics LLC, 575 Virginia Road, Suite 201, Concord, MA 01742, United States.