ARIEL PRECISION MEDICINE, INC., (“ARIEL,” “we” or “us”) is committed to protecting the privacy of all visitors to the ARIEL website. ARIEL has established this Privacy Statement to inform you (“You”) of the specific practices and guidelines that help ensure the security and confidentiality of Your personal information. By using or accessing in any way the websites we control and operate, including www.arielmedicine.com (our “Websites”), our online physician portal “https://www.arielmedicine. com/physician” (our “Physician Portal”), our online medical professional portal “https://www.arielmedicine.com/mpro” (our “Medical Professional Portal”), our online patient portal (our “Patient Portal”) or by transmitting information to us by email or other electronic means, You agree to the terms of this Privacy Statement.
Any services and products provided to You by Ariel directly or through the Websites may be governed by the written agreement(s) entered into between You and Ariel, and, in the event of any conflict between this Privacy Statement and such written agreement, the written agreement shall apply for the services covered by such written agreement.

CONSENT

By accessing the Websites, You are consenting to Our collection, use, processing, and disclosure of Your information as set forth in this Privacy Statement, which may be modified from time to time.  You should review this Privacy Statement from time to time so that You are updated on any changes.  If You do not wish to consent to Our collection, use, processing and disclosure of Your information, , please do not access the Websites, create accounts or access any of the ARIEL portals.

DEFINITIONS

“NPI” is information that is not personally identifiable and that is obtained through Your use of the Website.
“PII” is non-public information that is personally identifiable and obtained in connection with providing a product or service to You, including personally identifiable information You provide during the registration process or during Your use of the Websites. It may include information such as name, email, phone number and address that You provide to Ariel. PII does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to contact or identify You. For the sake of clarity, PII does not refer to Protected Health Information (as defined at 45 C.F.R. § 160.103) or individually identifiable information of individuals, other than You, that is protected by state or federal privacy laws.

AGGREGATE DATA COLLECTION

ARIEL tracks visits to our Websites and uses visitor logs to compile anonymous aggregate statistics. This aggregate information is collected throughout the site, and includes anonymous website statistics. In addition, when You browse our Websites, our system automatically collects information such as Your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, the date and time of Your request and one or more cookies that may uniquely identify Your browser. This information is used to analyze trends, administer the Websites, improve the design of our Websites, and otherwise enhance the services we provide.

COOKIES

The Website may send a “cookie” to Your device. A cookie is a small piece of data that is sent to Your browser from a web server and stored on Your device. A cookie cannot read data off Your device or read cookie files created by other sites. Cookies do not damage Your system.  Every device accessing the Website is assigned a different cookie.  Cookies allow ARIEL to recognize You as a user when You access the Website using the same device and web browser. ARIEL uses cookies to identify which areas of the Website You have used, so the next time You use the Website, those pages may be readily accessible, and for authenticating purposes. ARIEL also may use this information to better personalize the content that You see while using the Website. Most browser software can be set to reject cookies. However, if You reject ARIEL cookies, certain functionality on the Website may not work correctly or at all. ARIEL may also use web beacons, pixels, anonymous ad network tags, cookies and similar technologies to collect NPI about Your use of the Website and the websites of selected sponsors and advertisers, to collect anonymized, aggregated auditing, research and reporting for advertising purposes, and to collect data related to Your use of special promotions or newsletters. The information that may be collected by web beacons may also allow ARIEL to statistically monitor how many people open ARIEL emails and for what purposes these actions are being taken. ARIEL web beacons will not be used to track Your activity outside of the Website.  However, because Your web browser requests advertisements and web beacons directly from ad network servers, these networks can view, edit or set their own cookies, just as if You had requested a web page from their site.

Do Not Track:  Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including ARIEL, do not respond to DNT signals.

PERSONAL INFORMATION USE

From time to time, We may disclose the information collected from You, including PII, in accordance with as described in the Section entitled “When ARIEL May Disclose Your Information”, below.

ARIEL uses and/or intends to use PII to:

Operate and improve the Website;
Track use of the Website;
Create Your account
Provide You with the Website and other products and services that You may request or that You have expressed interest in, including services provided to You under a written agreement entered into between You and ARIEL;
Evaluate Your interest and needs in order to improve the Website and make available other offers, products or services;
Evaluate the types of offers, products or services ARIEL makes available to You and potential customers;
Provide customer support;
Communicate and provide additional information that may be of interest to You through email or other means, such as special offers, announcements, and marketing materials;
Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing; and
Manage ARIEL’s everyday business needs such as Website administration, forum management, fulfillment, analytics, fraud prevention, enforcement of ARIEL’s corporate reporting obligations, Terms of Use or to comply with the law.

This Privacy Statement does not limit Our use of any NPI, and We reserve the right to use and disclose such information to third parties at Our discretion.

Except as set forth in this Privacy Statement or as specifically agreed to by You, ARIEL will not disclose any PII as gathered from You through the Website.

ARIEL may disclose aggregated and anonymized data to its business partners.
ARIEL may share Your account name, certain information You provide ARIEL, content You upload and messages to ARIEL and other users of the Website at Your request. For example, when You communicate on public forums or to other users of the Website, Your communications, account name, and other account information may be viewable by other users of the Website, in accordance with any distribution or viewing limitation options provided by ARIEL that You select.
ARIEL may share PII in limited fashion to ARIEL’s contractors and service providers that perform services on ARIEL’s behalf, including, but not limited to, operation of the Website technology, data analytics, marketing services, and other related services. Unless You have opted-out (see Paragraph E. below) of such sharing, these contractors also may have access to Your email address or mobile phone number to send newsletters or special promotions to You on ARIEL’s behalf or to send emails to You for purposes such as conducting market research on ARIEL’s behalf. Access to Your PII by such contractors and service providers is limited to the information reasonably necessary for the contractor to perform its limited function for ARIEL. ARIEL also contractually requires that such contractors and service providers: 1) protect the privacy of Your PII consistent with this Privacy Statement, and 2) not use or disclose Your PII for any purpose other than providing ARIEL with products and services as required by law.
ARIEL may share PII ARIEL collects, as permitted by law, to companies such as credit reporting agencies, or servicing and processing companies, or when required or advised to do so in response to a valid legal requirement to release this information such as a state or federal law, regulation, search warrant, subpoena, or court order; or in special cases, such as in response to a physical threat to You or others, to protect property, or if We determine such disclosure is legally advisable or necessary to defend or assert legal rights or prevent harm, to defend ourselves in litigation. In the event that ARIEL is legally compelled to disclose Your PII to a third party, ARIEL will attempt to notify You unless doing so would violate the law or court order.
If the entire or substantial ownership of the Website were to change, or in the event of another sale or transfer of some or all of ARIEL’s assets, Your user information, including PII, may be transferred to the new owner so the Website can continue operations. In any such transfer of information, Your user information, including PII, would remain subject to the promises of ARIEL’s then current Privacy Statement. If You prefer that ARIEL does not share Your PII as described in this Paragraph E, You can direct ARIEL not to share that PII by contacting ARIEL (support@arielmedicine.com).
If You prefer that ARIEL does not share certain information with third parties, as described above, You can direct ARIEL not to share that information by contacting Us (support@arielmedicine.com). Please note that an opt-out with respect to information sharing will not apply to information sharing arrangements described in Paragraphs D or E.

PERSONAL INFORMATION COLLECTED

ARIEL may collect, store and use PII about You from the following sources:

Information available to Us through weblogs about Your traffic on other websites; or
Information You give ARIEL on applications or other forms while using the Website, including, without limitation, the information You provide in creating Your account; or
Information You send ARIEL via any medium, including, but not limited to the Website email, telephone, and social media interaction; or
Information You, or a third party on Your behalf, send ARIEL to create or authenticate Your account; or
If You use a mobile device platform to access the Website or communicate with ARIEL, information transmitted from Your mobile device; or
Information purchased from or provided by third parties.

CHILDREN

The ARIEL Websites are directed toward adults. If You are under the age of 18, You must obtain the authorization of a responsible adult (parent, legal custodian, or teacher) before using or accessing our Websites. We will not knowingly collect or use any personal information from any children under the age of 18. If we become aware that we have collected any personal information from children under 18, we will promptly remove such information from our databases.

SECURITY MEASURES

Information that You provide to ARIEL through these Websites is encrypted using industry standard Secure Sockets Layer (SSL) technology, with the exception of information You send via email. Your information is processed and stored on controlled servers with restricted access. ARIEL cannot ensure or warrant the security of any information You transmit to our Websites, and You do so at Your own risk. As a consequence, ARIEL disclaims any warranties or representations relating to maintenance or nondisclosure of private information.

EXTERNAL LINKED WEBSITES

The ARIEL Websites may contain links to external websites. ARIEL does not maintain these sites and is not responsible for the privacy practices of sites that it does not operate. Please refer to the specific privacy statements posted on these sites.

CHOICE AND INFORMATION ACCESS

You may choose to provide information to ARIEL by completing the registration form, sending us an email or otherwise contacting us. In the registration form, You may have an opportunity to elect to receive certain communications from us. ARIEL email correspondence will include instructions on how to update certain personal information and how to unsubscribe from our emails and postal mail correspondence. Please follow the instructions in the emails to notify ARIEL of changes to Your name, email address and preference information. ARIEL will take reasonable steps, such as confirmation emails, to verify Your identity before granting access to Your personal information. ARIEL fully complies with the federal CAN-SPAM Act. If You choose to unsubscribe from our email and/or postal mail services, You will no longer receive this correspondence. However, ARIEL may retain Your information for a period of time to resolve disputes, troubleshoot problems or for other valid business or legal reasons.

THIRD PARTY INFORMATION

You agree that You have provided notice to, and obtained consent from, any third party individuals whose personal information You supply to us, including with regard to: (a) the purposes for which such third party’s personal information has been collected; (b) the intended recipients or categories of recipients of the third party’s personal information; (c) which of the third party’s information is obligatory and which information, if any, is voluntary; and (d) how the third party can access and, if necessary, rectify the information held about them.

GOVERNING LAW

Our Websites are controlled and operated by ARIEL. By choosing to visit our Websites or otherwise provide information to ARIEL, You agree that any dispute over privacy or the terms contained in this Privacy Statement will be governed by the laws of the State of Pennsylvania. If You are accessing our Websites from any location with regulations or laws governing personal data collection, use or disclosure that differ from United States laws or regulations, please note that through Your continued use of our Websites, which is governed by the laws of the State of Pennsylvania and the United States of America and this Privacy Statement, You are transferring personal information to the United States of America and You consent to that transfer and to the collection and processing of such information in the United States. You also consent to the adjudication of any disputes arising in connection with our Websites in the federal and state courts of Allegheny County in the State of Pennsylvania. You also agree to attempt to mediate any such disputes.

PHYSICIAN’S PORTAL / MEDICAL PROFESSIONAL PORTAL

ADDITIONAL RIGHTS UNDER EUROPEAN UNION LAW

ARIEL intends to comply with all EU law concerning personal data and collects data for the lawful purpose of providing healthcare services.  You may have additional rights under EU law.  For additional information or for actions to exercise these additional rights under EU law, please contact the Privacy Office.

UPDATES

From time to time ARIEL may revise this Privacy Statement. When revisions occur, all updates to this statement will be posted on this web page. ARIEL will notify You by posting a notice on the website if there are significant changes that have been made. Please check the website for the most current version of our Privacy Statement. Your continued use of the website after we have posted a notice on the website constitutes Your acceptance of such changes.

ARIEL Privacy Office:

5750 Centre Ave
Suite 270
Pittsburgh, PA 15206
(844) 692 7435

EFFECTIVE DATE: January 2021