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Effective Date: July 2025
Elephas Biosciences Corporation ("Elephas," "us," "we," or "our") is committed to protecting your privacy. This Privacy Policy and Notice at Collection ("Privacy Notice") describes how we may collect and use information about you ("you," "user").
This Privacy Notice applies to: the Elephas website at elephas.com and other digital or online services that link to or reference this Privacy Notice; and your interactions with us in the ordinary course of business, such as communications by phone, email, or in person (collectively, the "Services").
Note: If you are a healthcare provider accessing our clinical laboratory services through Elephas Laboratories, please refer to the Elephas Laboratories Privacy Policy and HIPAA Notice of Privacy Practices, which govern our handling of protected health information.
NOTICE AT COLLECTION
What Types of Personal Information Do We Collect?
We collect and generate different types of Personal Information depending on how you use or interact with our Services. For purposes of this Privacy Notice, "Personal Information" means information that identifies, describes, or is reasonably capable of being associated with you that we collect or generate when you use or interact with our Services. The following describe various categories and sources of Personal Information we have collected, may collect, or generate, including in the past 12 months.
Demographic and Contact Information. Information you provide to us such as your name, mailing address, email address, and telephone number.
Professional Information. Information about your professional background, including your job title, employer or organization, professional credentials, and business contact information.
Webforms and Requests. Information you submit to us through online or interactive forms available within our Services, including "contact us" forms, feedback forms, newsletter sign-ups, requests for information about our products and services, and partnership or investor inquiries.
Website Information. Information such as unique identifiers, preference information, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data.
Device Information. Device-specific information including Internet Protocol ("IP") address, hardware model, operating system, unique device identifiers, browser type, and mobile network information. We may also associate the information we collect from your different devices, which helps us provide consistent Services across your devices.
Log Information. Usage details of our Services, including the address (or URL) where you came from before visiting us, which pages or features you visit or utilize, search terms you enter, and items you click on. We may also create usage statistics and monitor the traffic from your use or interaction with our Services.
Internet Protocol (IP) Addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We generally collect IP address information from visitors using or interacting with the Services and we log them for system administration purposes. In some cases, we may also use IP addresses to serve you advertisements on third party websites regarding our Services that may be of interest to you.
Location Information. Your general location information may be collected in a variety of ways depending on how you use or interact with our Services, including from your IP address, country or location selection, or other location-based components of our Services.
Business Interactions. Information derived from your business-related requests, communications, and dealings we have with you, or the company/organization you work(ed) for or are associated with. This may include information about products or services you expressed an interest in, partnership opportunities, investor relations, and career inquiries.
Social Media. Our Services may link to our pages or accounts on third party social media networks. If you choose to interact with us on social media, we may collect the information you publish or submit. Note that this information is also governed by the privacy policies of the respective companies offering the social media service.
Tracking Technologies. Our Services may incorporate tracking technologies to provide you with certain functionalities. These tracking technologies may collect or generate Personal Information about you when you interact with us. You may adjust your preferences at any time through your Cookie Settings or individual browser settings. Please review our Cookie Notice for more information. Our Services may incorporate the following tracking technologies:
HOW DO WE USE PERSONAL INFORMATION?
Depending on what Services you use and how you interact with us, we may use Personal Information about you in the following ways. We will generally rely on the following business purposes to collect and use Personal Information: performance of a contract, compliance with our legal obligations, pursuing our legitimate interests, consent, or protection of vital interests.
To respond to your inquiries and provide information about the Services. If you send us questions, make an inquiry or request, or ask for certain information, we may use Personal Information about you to respond to you.
To send you marketing information. We may use Personal Information about you to provide you with information about our Services, to send you marketing communications, newsletters, updates, or to enable you to participate in surveys or questionnaires.
To serve advertisements you may be interested in. We may use Personal Information about you to tailor and deliver relevant advertisements to you when you are using our Services, or when you are accessing a third-party service. For example, you may receive online advertisements, emails, texts, or social media notifications from us for promotional purposes.
To manage business transactions. During certain business interactions, we may use Personal Information about you to manage business transactions, partnership discussions, investor relations, and career opportunities.
To improve the Services and user experience. We may use Personal Information about you to gather and create statistics regarding your usage of our Services, to better understand our users, personalize users' experiences and interactions with us, and improve the content and performance of our Services.
To comply with applicable laws and our legal obligations. We may use Personal Information about you to comply with applicable laws, regulations, industry codes of conduct, and Elephas's internal policies and procedures, including:
Merger or Sale. If we are involved in a merger, acquisition, or sale of our assets (or a portion thereof), we may share Personal Information about you with a corporate purchaser, successor in interest, or prospect to the extent permitted by law.
Other uses. Where permitted by law, we may also enhance or combine information about you, including Personal Information about you, with information about you that we obtain from third parties for the same purposes described in this Privacy Notice.
Use of Non-Personally Identifiable Information. We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, or for security and compliance purposes.
DO WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
Links to Third-Party Websites. As a resource to our users, we may provide links to other unaffiliated websites or services within our Services. If you choose to visit such third-party websites or services, please note that any information you submit to them is not subject to this Privacy Notice.
Elephas Affiliates and Subsidiaries. Elephas shares Personal Information with its affiliates and subsidiaries, including Elephas Laboratories, LLC, for the purposes described in this Privacy Notice.
Service Providers. We may share Personal Information about you with third party service providers that we hire to help us administer and provide the Services to you. These third parties are required to treat Personal Information about you in accordance with appropriate contractual and legal privacy and security requirements.
Advertising and Analytics. We may engage third party service providers who utilize tracking technologies to serve you advertisements that you may be interested in. Some of these advertisements may be personalized to you based on what we, or the third-party service providers, know about you. Depending on where you live, we may be required to obtain your consent before we serve you with these types of advertisements.
DO WE SELL OR SHARE PERSONAL INFORMATION?
We may disclose Personal Information about you to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We may "sell" or "share" (as those terms are defined under applicable state privacy laws) certain categories of Personal Information to third parties for purposes of targeted advertising or cross-contextual behavioral advertising. To opt-out of such sales or sharing, please visit our "Do Not Sell or Share My Personal Information" page or adjust your Cookie Settings.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to the categories of third parties indicated in the chart below:
CATEGORIES OF THIRD PARTIES
|
Personal Information Category |
Commercial or Business Purpose |
Category of Third Party |
|
Identifiers |
Marketing, customer relationship management, web hosting, data storage |
HubSpot, Google Analytics |
|
Communications |
Customer relationship management, data storage |
HubSpot, Google Analytics |
|
Internet or Network Activity |
Marketing, web hosting, analytics |
HubSpot, Google Analytics |
|
Geolocation Information |
Marketing, web hosting |
HubSpot, Google Analytics |
We may also share Personal Information about you to:
HOW DO WE SECURE AND RETAIN PERSONAL INFORMATION?
We have reasonable security measures in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you. We maintain reasonable security standards to protect the Personal Information that we maintain. For more information about Elephas's information security program, please visit our Trust Center at trustcenter.elephas.com. If you have any questions about the security of Personal Information about you, please contact us.
We will only store Personal Information as long as necessary to fulfill the purposes for which the information is collected and processed or, where the applicable law provides for longer storage and retention period, for the storage and retention period required by law. After that, Personal Information will be deleted, blocked, or anonymized, as provided by applicable law. In particular:
DOES ELEPHAS TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?
To provide our Services, we may need to transfer and process Personal Information internationally (including to destinations outside the country in which you are located). As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for Personal Information as the country in which you reside. However, we have taken appropriate safeguards to ensure that Personal Information about you will remain protected in accordance with this Notice. Further information can be provided on request: please contact us using the details found in the section "How can you Contact Elephas?"
HOW OLD DO I HAVE TO BE TO USE THE ELEPHAS SERVICES?
Online components of our Services are not directed to children under the age of 13 (or 14, depending on where you reside), and we do not knowingly collect Personal Information via online Services from children under those ages. If you think that we have collected Personal Information via an online Service from a child under those ages, please contact us as described below.
California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly available content that you have submitted to us, you may request removal by contacting us at: security@elephas.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don't follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information.
WHAT ARE MY DATA PROTECTION CHOICES AND RIGHTS?
State consumer privacy laws may provide their residents with additional rights regarding our use of Personal Information. The following Section applies to individuals who reside in jurisdictions that provide additional privacy rights.
Your Rights and Choices
Right to Access Specific Information and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of Personal Information over the past twelve (12) months, including: the categories of Personal Information we collected about you; the categories of sources for the Personal Information; our business or commercial purpose for collecting or selling that Personal Information; the categories of third parties with whom we share that Personal Information; the specific pieces of Personal Information we collected about you; and if we disclosed Personal Information for a business purpose, the business purpose for which it was disclosed.
Right to Correct Information. You have the right to request we update Personal Information about you that is incorrect in our systems.
Right to Delete. You have the right to request that we delete any Personal Information about you that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the Personal Information from our records, unless an exception applies.
Right to Opt-out of the Sale or Sharing of Personal Information. You have the right to opt-out of the sale or sharing of your Personal Information for cross-contextual behavioral advertising. To exercise this right, visit our "Do Not Sell or Share My Personal Information" page.
Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive Personal Information regarding you.
Non-Discrimination. We will not discriminate against you for exercising any of your rights.
How to Exercise These Rights. To submit a request to exercise these rights, you may use one of these methods:
For all requests, please clearly state that the request is related to "Your Privacy Rights," indicate which type of request you are making, and provide your name, street address, city, state, zip code, and an email address or phone number where we may contact you.
Appeals. To appeal a decision regarding a consumer rights request, please submit your appeal using one of the methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Only you, or a person registered with the applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to Personal Information about you. You may only make such a request for access or data portability twice within a 12-month period.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Opt-out Preference Signals. Our website honors Global Privacy Control ("GPC") opt-out preference signals when such signals are configured through your browser. You can get further help in configuring your browser by visiting: https://globalprivacycontrol.org/
California Shine the Light Law. California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an email with "California Privacy Rights" in the subject line to security@elephas.com or write us at: Elephas Biosciences Corporation, Attn: Privacy Inquiries, 1 Erdman Place, Suite 100, Madison, WI 53717.
DOES THIS PRIVACY NOTICE CHANGE?
We may periodically update this Privacy Notice to describe new Services and how such Services may affect our collection and use of Personal Information. If we make material changes to this Privacy Notice, we will post a notice of the material changes on our website. If we use Personal Information about you for other purposes not specified in this Privacy Notice, we will notify you and obtain your consent, to the extent required by applicable law. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.
HOW CAN YOU CONTACT ELEPHAS?
If you have questions or concerns about this Privacy Notice, our information practices, or any other aspect of the privacy and security of Personal Information about you, please contact us using the information below.
Elephas Biosciences Corporation
Attn: Privacy Inquiries
1 Erdman Place, Suite 100
Madison, WI 53717
United States
Email: security@elephas.com
Phone: (608) 622-7954
Last updated: 9/6/2024
1. Introduction
The goal of the Elephas Information Security Program is to protect the Confidentiality, Integrity, and Availability of the data employed within the organization while providing value to the way we conduct business. Protection of the Confidentiality, Integrity, and Availability are basic principles of information security, and can be defined as:
Elephas has recognized that our business information is a critical asset and as such our ability to manage, control, and protect this asset will have a direct and significant impact on our future success.
This document establishes the framework from which other information security policies may be developed to ensure that the enterprise can efficiently and effectively manage, control and protect its business information assets and those information assets entrusted to Elephas by its stakeholders, partners, customers and other third parties.
The Elephas Information Security Program is built around the information contained within this policy and its supporting policies. For additional information regarding our Information Security
program, please visit https://trustcenter.elephas.com.
2. Purpose
The purpose of the Elephas Information Security Policy is to describe the actions and behaviors required to ensure that due care is taken to avoid inappropriate risks to Elephas, its business partners, and its stakeholders.
3. Audience
The Elephas Information Security Policy applies equally to any individual, entity, or process that interacts with any Elephas Information Resource.
4. Responsibilities
Executive Management
Information Security Team
All Employees, Contractors, and Other Third-Party Personnel
Policy
Elephas maintains and communicates an Information Security Program consisting of topic-specific policies, standards, procedures and guidelines that:
The information security program is reviewed no less than annually or upon significant changes to the information security environment.
5. Enforcement
Personnel found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and related civil or criminal penalties.
Any vendor, consultant, or contractor found to have violated this policy may be subject to sanctions up to and including removal of access rights, termination of contract(s), and related civil or criminal penalties.
Last updated: 9/25/2023
1. Introduction
This Cookie Policy outlines how cookies and similar technologies are used by Elephas when you visit our website. This policy provides information on the types of cookies we use, their purpose, and how you can manage your cookie preferences.
2. What Are Cookies?
Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work efficiently and to provide information to website owners. Cookies can be used for various purposes, including remembering user preferences, analyzing website traffic, and delivering targeted advertising.
3. Types of Cookies We Use
3.1. Essential Cookies
These cookies are necessary for the proper functioning of our website. They enable you to navigate our website and use its essential features. Without these cookies, certain services and functionalities may not be available.
3.2. Performance Cookies
Performance cookies collect information about how visitors use our website, such as which pages are visited most often and if they encounter error messages. These cookies do not collect personally identifiable information (PII), and the data they collect is used to improve the performance and user experience of our website.
3.3. Functional Cookies
Functional cookies allow our website to remember choices you make, such as your language preference, and provide enhanced, personalized features. These cookies may also be used to provide services you have requested, such as commenting on a blog post or remembering login details.
4. How We Use Cookies
We use cookies for the following purposes:
5. Information We Collect
Personal Information:
Non-Personal Information:
6. Managing Your Cookie Preferences
You have the option to manage your cookie preferences. You can typically do this through your web browser settings. Please note that if you choose to disable cookies, certain parts of our website may not function correctly, and your user experience may be impacted.
6.1. Browser Settings
Most web browsers allow you to control and manage cookies through their settings. You can typically find these settings in the "Options" or "Preferences" menu of your browser. The exact steps for managing cookies may vary depending on your browser.
6.2. Cookie Consent Tools
When you visit our website, you may be presented with a cookie consent banner or pop-up that provides you with options to accept or decline cookies. You can adjust your preferences through these tools.
7. Changes to this Cookie Policy
We may update this Cookie Policy to reflect changes in our use of cookies or in response to regulatory changes. Any updates to this policy will be posted on our website with a revised effective date.
8. Contact Information
If you have any questions or concerns about our Cookie Policy or the use of cookies on our website, please contact us at any means listed below. By using our website, you consent to the use of Cookies described in this policy.
Last updated: June 11th, 2025
1. Introduction
This Opt-Out Policy outlines the procedures and mechanisms for individuals to opt out of certain activities or communications conducted by Elephas. We respect the privacy and preferences of our customers, users, and other individuals with whom we interact and provide clear and accessible options for them to exercise their right to opt out of specific interactions.
2. Purpose
The purpose of this Opt-Out Policy is to ensure transparency, fairness, and compliance with applicable privacy laws and regulations. It serves as a commitment to respecting the choices and preferences of individuals regarding marketing communications, data collection, and other activities that may impact their privacy.
3. Scope
This policy applies to all individuals who interact with Elephas, including customers, users, website visitors, and any other parties whose personal information may be collected, processed, or used for various purposes.
4. Opt-Out Mechanisms
4.1. Marketing Communications
4.1.1. Email Communications
Individuals have the right to opt out of receiving marketing emails and newsletters from Elephas. Every marketing email will include a clear and prominent "unsubscribe" link that allows recipients to opt out of future email communications.
4.1.2. SMS and Text Messages
For SMS or text message communications, individuals will be provided with clear instructions on how to opt out by replying with a designated keyword (e.g., "STOP"). Opting out through this method should cease further SMS communications.
4.1.3. Postal Mail
Individuals who wish to opt out of receiving postal mailings can contact Elephas by phone, email, or postal mail to request removal from the mailing list. Elephas will promptly update its records accordingly.
4.2. Data Collection and Cookies
4.2.1. Cookies and Tracking Technologies
Elephas will provide information on its website about the use of cookies and other tracking technologies. Individuals can adjust their browser settings to manage or block cookies or may choose to opt out of certain third-party tracking services if available.
4.2.2. Data Collection and Analytics
Individuals may have the option to opt out of data collection for analytics purposes through the use of browser plugins or settings provided by Elephas. Additionally, Elephas will clearly explain data collection practices in its privacy policy and provide opt-out instructions if applicable.
4.3. Telemarketing Calls
Individuals who receive telemarketing calls from Elephas have the right to opt out of future calls. Individuals can request their phone number to be added to the organization's "do not call" list.
5. Timing of Opt-Out Requests
Opt-out requests will be processed promptly and in accordance with applicable laws. Elephas will make reasonable efforts to ensure that individuals' preferences are respected, and they are not contacted for the specific activities they have opted out of.
6. Compliance
Elephas is committed to complying with all relevant data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), with respect to opt-out requests and data privacy rights.
7. Contact Information
Individuals who wish to exercise their right to opt out or have questions about this policy can contact Elephas using the following contact information:
8. Review and Revision
This Opt-Out Policy will be reviewed and updated as necessary to ensure compliance with evolving privacy regulations and best practices. Any changes will be communicated to affected individuals as appropriate.
By implementing this Opt-Out Policy, Elephas aims to provide individuals with meaningful choices regarding their interactions with the organization while respecting their privacy preferences and rights.
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