Privacy Policy | Orasis Pharmaceuticals

Orasis Pharmaceuticals, Ltd (“Orasis,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites www.orasis-pharma.com,www.qlosi.com, and www.qlosiecp.com (collectively, our “Sites”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal data from users of our Sites, any related product or service that we offer described therein, and any other website, mobile application, or other digital service where this Privacy Policy is posted (collectively with the Sites, the “Services”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service (https://www.orasis-pharma.com/terms-of-service). This Privacy Policy does not address how we process “Consumer Health Data” or “Regulated Health Information” as that term is defined under applicable state law about consumers who reside in the states of Nevada, Washington, New York, and any other applicable U.S. jurisdiction. Please refer to our Health Data Privacy Policy for more details.

Information We Collect

Depending on your relationship with us, we may collect the below categories of personal data from or about you or your devices from various sources, as described below, when you access the Services:

Contact Information: Name, email address, postal address, and phone number. This may include your business and personal contact information.
Website Activity: We collect information related to your access to and use of our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you viewed before and after visiting our Services. We may also collect this type of information in visual form when you visit our Services, including video snippets of your activity on the Services. Some jurisdictions may consider some of this data to be “health” or related information if you are interacting with our health-related webpages or consumer-facing websites.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Health Related Information: We collect information that may relate to your health in the context of our regulatory responsibilities under the Federal Food, Drug, & Cosmetic Act (such as adverse event and product complaint reporting), health-related data that you disclose to us offline and online, such as through our consumer-facing websites, communications channels, or otherwise through the Services.
Employment and Professional Information: Place of employment, credentials, and occupation or professional membership.
Geolocation Information: Approximate location of your device from your IP address.
Commercial Information: Information about your product and service preferences and interests, including interests in our products or services.
Social Media Information: Account names, handles, biographies, and other details that you make available on social media networks.
Other information that you may provide to us (such as any attachments you send to us or provide to us in a message) or that we may infer based on the above.

How We Collect Information

We collect personal data directly from you in the below contexts. We also collect personal data from you using sources like advertising or marketing networks, data analytics providers, social networks, data brokers, and other service providers or third parties.

If you register an account with us or otherwise access the Services
In connection with your interactions, inquiries, or other requests
If you upload or share a photo or other digital content through one of our Services, or share content linking to any of our social media platforms
If you participate in a contest, promotion, or survey
If you contact us via e-mail or through our customer service, including through the use of online chat tools that we may make available
We and our third-party vendors may use tracking tools like browser cookies, flash cookies, pixels, and web beacons to collect information from you.

How We Use the Information We Collect

We use the personal data we collect:

To provide, maintain, improve, and enhance our Services;
To understand and analyze how you use our Services and develop new products, services, features, and functionality;
To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
For marketing purposes, such as developing and providing promotional materials that may be relevant, valuable or otherwise of interest to you;
To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences across our Services;
To protect the security or integrity of the Services, including to find and prevent fraud and abuse and respond to trust and safety issues that may arise and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our customers is among the assets transferred; and
For compliance purposes, including monitoring and enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; to protect our users, the public, and the rights, health, or safety of third parties; and for other purposes for which we provide specific notice at the time the information is collected.

How We Disclose the Information We Collect

Affiliates

We may disclose any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers

We may disclose any information we receive with vendors and service providers retained in connection with the provision of our Services. For example, this may include auditing and accounting firms, professional services consultants, providers of data hosting, storage, and analytics services, and IT and security vendors.

Marketing and Advertising

We work with companies that assist us in advertising our Services to you and others who may be interested in the Services. These companies may use tracking technologies on our Services to collect or receive information over time and across different websites or platforms, including the Sites and the Services and elsewhere on the internet, and use that information to provide measurement services and provide you with targeted ads. We do not rent, sell (for monetary compensation), or share information about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission. However, some jurisdictions may consider targeted advertising to be a “sale” of personal data, and some jurisdictions may consider data about your interactions with our health-related online Services to be considered “health information” or “sensitive” personal data. Thus, we may “sell” personal data, including “sensitive” personal data about you. Please see Your Privacy Rights, below, for more information about rights and choices that you may have with respect to this practice, including how to request to opt out.

Social Media Platforms

Where you choose to interact with us through social media, your interaction with these platforms typically allows the social media company to collect some information about you through cookies and other digital tracking mechanisms that they place on your device. In some cases, the social media company may recognize you through these technologies even when you do not interact with their platform. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.

Analytics Partners

We use analytics services such as Google Analytics to collect and process certain personal data for analytics purposes.

You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/

As Required By Law and Similar Disclosures

We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply or cooperate with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.

Consent

We may also disclose your personal data with your permission.

Your Choices

Marketing Communications

You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Information from Cookies and Similar Technologies

We and our third-party partners collect personal data using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

The Services do not recognize Do Not Track signals, and we do not respond to such signals. However, our Services may recognize certain opt-out preference signals, such as the Global Privacy Control, and will process such signals in accordance with applicable law, potentially including “do not sell”, “do not share”, “limit the use or disclosure of sensitive personal information”, and opt out of targeted advertising requests. You may set such a signal through your browser or browser extension.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your personal data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal data.

Children’s Privacy

We do not knowingly collect, maintain, or use personal data from children under 18 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal data in violation of this Privacy Policy, then you may alert us at info@orasis-pharma.com.

International Visitors

Our Services are hosted in the U.S. and intended for visitors located within the U.S. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data outside of those regions to the U.S. for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including personal data, on or to our Services, you consent to such transfer, storage, and processing.

Data Retention

We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us);
Whether there is a legal obligation to which we are subject (for example, we are required to keep records of your transactions for a certain period of time); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Your Privacy Rights

You may have the rights listed below (“Data Subject Rights”) with respect to the personal data that we collect or process about you. These rights differ depending on your place of residency, including the California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.

Right to Confirm Processing, Access, and/or Obtain a Copy: If you ask us, we will confirm whether we are processing your personal data. Additionally, upon request, we will provide you with a copy of all personal data you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
Right to Amend: If you believe your personal data is inaccurate or incomplete, you may request that we correct it.
Right to Delete: You may request that we delete personal data that we maintain about you.
Right of Portability: You may request that we move, copy, or transfer the electronic personal data that we hold about you to another organization.
Right to Revoke Consent and/or Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your personal data. This includes general requests and requests in specific contexts, such as if we process personal data that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
Right to Limit Use and Disclosure of Sensitive Personal Data: You may ask us to limit the use and disclosure of sensitive personal data.
Right to Opt Out of Targeted Advertising or “Sharing”: Targeted advertising is the practice of serving you tailored advertisements based your personal data gathered over time and across other businesses, websites, applications, or services. Some jurisdictions may refer to this activity as “sharing.” You have the right to opt out of this practice.
Right to Opt Out of Sales: Some jurisdictions may consider targeted advertising a “sale” of personal data. You may request that we not “sell” your personal data, including any “sensitive” personal data.
Right to Non-Discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your personal data.
Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination.
Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the country or state in which you live if you have any concerns about our processing of your personal data or if we deny your appeal to review a prior decision about your Data Subject Rights.

If you or your authorized agent would like to exercise a Data Subject Right, you may do so by following the instructions at the end of this Privacy Policy.

In order to process your request to exercise a Data Subject Right, we will ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as most recent interaction with us, if applicable.

Additional Disclosures for California Residents

If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act (or “CCPA”) (California Civil Code Section 1798.100 et seq.).

Categories of Personal Information Collected: In the previous 12 months, we have collected the personal information listed in the section “Information We Collect” above. This information falls into the following categories under the CCPA: identifiers; categories of personal information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories.
Sensitive Personal Information Uses or Disclosures: The data that we capture about your interactions with some of our health-related online Services may be considered “sensitive” personal information. We use this interaction data to support cross-context behavioral advertising. You may request that we limit this use of our “sensitive” personal information by following the instructions at the end of this Privacy Policy.
Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in “Information We Collect” and “How We Use the Information We Collect” above.
Categories of Sources of Personal Information: We collect personal information from and about you as described in “How We Collect Information” above.
Categories of Third Parties with Whom We Disclose Information: We may disclose your personal information with third parties as described in “How We Disclose the Information We Collect” above.
Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information listed in “Information We Collect” for the reasons described in “How We Disclose the Information We Collect” above.
Sale or Share of Personal Information: Because we engage in the practice of cross context behavioral advertising, also known as online targeted advertising, we may “sell” and/or “share” your personal information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, employment or professional information, health information (usage and interaction data with certain health-related webpages in our Services), and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks. We do not have any actual knowledge that we sell or share the personal information of users under the age of 16.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal data previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at info@orasis-pharma.com or write to us at Orasis Pharmaceuticals, Inc. 101 Marketside Avenue, Suite 404-324, Ponte Vedra, FL 32081.

Last Updated: November 2025