Privacy Policy

Last updated: 30 April, 2025

Erogenix Pharma, LLC., (“we,” “us,” or “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy. This Policy describes the types of information we may collect from you or that you may provide when you visit our Website or use our Services, and our practices for collecting, using, maintaining, protecting and disclosing that information. We also describe the measures we take to protect the security of the information and how to contact us about our privacy practices.

This Privacy Policy applies to information we collect:

  • On our Website;
  • In email, text, and other electronic messages between you and our Website
  • Our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Avagen or any third party;
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website, or any third party website or application that may redirect you to our Website (such as if you access our Website through Facebook, Inc. or Google, Inc.)

This Privacy Policy is part of and incorporated into the Terms and Conditions, found at https://www.ristenza.com which is a legally binding agreement between you and Erogenix.

Please review this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Website or our Services. By accessing and using the Website or our Services, you accept and agree to this Privacy Policy, whether or not you register for an account through the Website.

PERSONAL INFORMATION WE COLLECT:

The term “Personal Information” refers to any information about a natural person who can be directly or indirectly identified from that information. Examples of personal information include a user’s name, address, phone number, email address, online activity (such as browsing history), and other details that can be used to identify that person. When you use our Services, register for an account on our website, or choose to send us information online, we may collect personal information about you. We may also ask you for information when you report a problem with our Website; You may provide various types of personal information, such as:

  • Contact information (e.g., name, postal address, email address, and phone number);
  • Demographic information (e.g., date of birth, gender);
  • Physical attributes (e.g., height, weight);
  • Medical history;
  • Lifestyle information (e.g., smoking and drug use);
  • Payment information (e.g., payment card number, financial account numbers, bank account numbers, expiration date, and billing address for payment purposes only);
  • Photographic images submitted for identification or non-diagnosis purposes, including photographs of your driver’s license or passport (or other government identification);
  • Username and password.

In addition, when you visit our Website, we may collect certain Personal Information by automated means, such as cookies and web beacons. The information we obtain in this manner includes: IP address; browser characteristics; device characteristics; operating system; referring URLs; geographic location; information on actions taken on our Website; error information; Internet connection; and dates and times of website visits. A “cookie” is a small text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, single-pixel gifs, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website or opening an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

Finally, the information we collect includes protected health information which is protected by our Notice of Privacy Practices and will only be used and/or disclosed in accordance with state and Federal laws.

Some of our business partners with whom we contract to carry out the Services (e.g., website/content providers, ad networks and servers, and social media sites) may use their cookies on our Website. Although we may not have direct access to or control over such cookies, this Privacy Policy governs the use of cookies by us and such third party business partners on our Website. We may also allow social media companies (e.g., Facebook) to put “widgets” on our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal data, about your online activities over time and across different websites and other online services. For example, so long as you are logged in to Facebook, every time you land on a webpage that has a Facebook widget, Facebook will know you are on that webpage. They may use this information to provide you with interest-based (behavioral) advertising and other targeted content. We do not control the privacy practices of these third parties. If you have any questions about advertisement or other targeted content, you should contact the responsible provider directly.

Some internet browsers allow you to limit or disable the use of tracking technologies that collect unidentified information, such as a “Do Not Track” (“DNT”) setting. Currently, we do not respond to DNT signals.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT:

We may use the Personal Information we collect or that you provide to us to:

  • Create and manage your account;
  • Display content on the Website;
  • Facilitate telehealth and related services;
  • Communicate with you about, and administer your participation in, surveys, events, programs, newsletters, promotions and other Website features;
  • Respond to and communicate with you about your inquiries and requests, and provide Services, information, and products you request;
  • Process, fulfill, and administer transactions and orders for products and services ordered by you;
  • Send periodic emails to market and promote our products and Services and for non-marketing or administrative purposes;
  • Operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; targeting advertising for our products; performing data analytics; and performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
  • Perform data analyses and processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information);
  • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • Comply with and enforce applicable legal requirements, relevant industry standards and our policies.

In addition, we may use Personal Information collected online through cookies, web beacons and other automated means for purposes such as: (i) customizing our users’ visits to our Website; (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Website; and (iii) managing our business. We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, there will be an option to stop all communications.  We may also use this information to help diagnose technical and service problems, administer our Website, identify users of our Website, and gather demographic information about our users. We may use clickstream data to determine how much time users spend on web pages of our Website, how users navigate through our Website, and how we may tailor our Website to better meet the needs of our users.

We may use third party service providers to assist us in better understanding our Website visitors. These service providers use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Website. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the Website.

DISCLOSURE OF PERSONAL INFORMATION WE SHARE:

We do not sell, trade or otherwise share Personal Information about you, except as described in this Privacy Policy. We may share your Personal Information with third party health care providers to provide you with health care services as part of our Services and for other treatment, payment, and health care operations purposes. We may share Personal Information with other third parties, including health care organizations and pharmacies, who perform services on our behalf. These third parties are not authorized by us to use or disclose the Personal Information except as necessary to perform services on our behalf or comply with legal requirements. We also may share the Personal Information we obtain with our affiliates, subsidiaries and partners.

We may disclose personal information about you:

  • If we are required to do so by law or legal process;
  • To law enforcement authorities or other government officials based on a lawful disclosure request;
  • To fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider;
  • For any other purpose disclosed by us when you provide the information;
  • With your consent;
  • When we believe disclosure is necessary or appropriate to prevent physical harm, protect the rights, property, safety, or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; or
  • When you authorize us to do so.
  • We reserve the right to transfer any information we have about you in the event we sell, transfer, or merge all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

AGGREGATE AND DE-IDENTIFIED INFORMATION:

We sometimes aggregate or de-identify Personal Information we collect, and the types of systems and browsers of users for internal purposes, so that we may better understand the Ristenza user population. Personal Information does not include “aggregate” or “de-identified” information. Aggregate or de-identified information is data we collect about a group of users, from which individual identities have been removed. In other words, information about how you use the Services, or the results of such use, may be collected and combined with similar information from others, but no Personal Information will be included in the resulting aggregate or de-identified data. We can extract statistical data from your content in order to provide it to other users or partners without connecting it to any personal data such as name or email address. Aggregate or de-identified data helps us understand trends and user needs so that we can better consider new products and services, and tailor existing products and services to customer desires. You understand that we may commercialize aggregate or de-identified information by any and all means, and that you will receive no payment or other consideration in respect of such use. In addition, we may share and disclose aggregate or de-identified information for any purpose.

PERSONAL INFORMATION RETENTION:

We are subject to multiple laws on the retention of Personal Information and will retain your Personal Information, even if you have closed your account, for as long as is reasonably necessary to comply with our business and legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. Similarly, our third party partners may retain your Personal Information for as long as is necessary for them to comply with their legal and business obligations.

HOW WE PROTECT YOUR PERSONAL INFORMATION:

We take reasonable and appropriate measures to protect your Personal Information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement certain physical, administrative, and technical safeguards that are designed to protect the integrity and security of your Personal Information.

Unfortunately, no methods used to transmit Personal Information via the internet or methods of data storage are completely secure. Although we do our best to protect your Personal Information, we cannot guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or administrative safeguards. Any transmission of information is at your own risk. You agree that Erogenix is not liable for the unauthorized release of your Personal Information, unless such release was the result of gross negligence or willful misconduct on the part of Erogenix.

The safety and security of your Personal Information also depends on you. You are responsible for maintaining the confidentiality of your password and account, and are fully responsible for all activities that occur under your password or account. You should not share your password with anyone. When accessing your account from a public or shared computer, you should use particular caution so that others are not able to view or record your password or your other information. Please notify us immediately of any unauthorized access or use of the Website or the loss or unauthorized use of your account information (e.g., username or password).

LINKS TO OTHER WEBSITES:

Our Website may provide links to other websites for your convenience and information. These websites are not operated or controlled by us and may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content, privacy policies, or practices of any third parties. Where possible, we will warn you when you are leaving our Website and connecting to a website operated by a third party.

AGE AND GEOGRAPHIC RESTRICTION:

Our Website is intended for individuals who are 18 years of age or older. We will never knowingly request information or collect Personal Data from anyone under the age of 18. Any person who provides their information through the Website represents that they are 18 years of age or older.

We are concerned about the safety and privacy of children online.  Because of this, we will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying FTC regulations establish United States federal law that protects the privacy of children using the internet. We do not and will not knowingly contact or collect Personal Information from children under 13. Our Website is not intended to solicit information of any kind from children under 13, and we will develop our Website with the capacity to block acceptance of information from children under 13 whenever age-related information is requested.

It is possible that by fraud or deception by others we may receive Personal Information given to us or pertaining to children under 13. If you believe the information of anyone under the age of 13 has been provided to Ristenza, and you are the parent or guardian of that individual, you may contact us to request that we delete any such information, at support@ristenza.com.

Our Website is intended to comply with the laws and regulations of the United States of America. We make no representations that our Website is appropriate or available for use in any location outside of the United States. If you are a resident of another country, or are accessing the Website from outside of the United States, please note that you are transferring your data to the United States of America which does not have the same data protection laws as the European Union and other regions.

CONSENT TO COMMUNICATIONS:

By using the Services and providing your contact information, such as your name, phone number, and email address, you consent to receiving email and text messages to tell you about our Services, such as important information about your requested Service(s) and reminders to log back in to complete surveys and forms that you left incomplete. We may share your contact information with partner organizations whose products or services are important for our Service objectives. For example, we may provide your contact information to third parties that assist us with hosting our databases, for data processing services, or so they can contact you with information that you requested as part of the Services. However, we do not exchange, trade, rent, or give phone or email lists to unaffiliated third parties, and third parties that receive your contact information from us are restricted from using this information in any way other than to provide services to us, or services for a collaboration in which they and Erogenix are engaged. You may opt-out from receiving email communications at any time by emailing support@ristenza.com. You may opt out from receiving text message communications at any time by replying to the text message with “STOP”. At that time, we will send a final text message confirming receipt of your opt-out notification. Opt-out requests will be honored promptly.

YOUR CHOICES:

Your use of our Website and Services is voluntary. We offer you certain choices about how your Personal Information is collected, used, and shared, from deleting or correcting Personal Information you include in your profile to advertising opt-outs and communication controls. You can review and change your preferences by logging into your account. You may also update your preferences, remove your Personal Information, or deactivate your account at any time.

You can review and change your Personal Information by contacting us at support@ristenza.com to request access to correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

How to Submit a Data Privacy Request:

You may exercise your Right to Know and Right to Deletion by emailing us at support@ristenza.com. To process your request to exercise your Right to Know and Right to Deletion, we must be able to verify your identity to a reasonable degree of certainty. To verify your identity, we will ask you to provide your contact information and additional identifiers based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.

You may designate an authorized agent to make a request to exercise your Right to Know or Right to Deletion on your behalf.  When you use an authorized agent to submit such a request, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us.  We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

CHANGES TO OUR PRIVACY POLICY:

At our sole discretion, we may make changes to this Privacy Policy at any time. When changes are made, we will post an updated Privacy Policy on our Website. The changes will apply to all Personal Information we have about you. All changes are effective immediately upon posting; the date the Privacy Policy was last revised is identified at the top of the page. If you access and use our Website or Services after the date on which the Privacy Policy has changed, we will treat your use as acceptance of the updated Privacy Policy. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

QUESTIONS AND COMMENTS:

We commit to resolve questions and comments about your privacy and our collection and use of your information. Individuals with inquiries or comments should contact us at: support@ristenza.com.