Effective as of April 2021

WraSer Pharmaceuticals (”WraSer,” “we,” “us,” or “our”) is committed to the protection of your personal information that is about you and which identifies you. This Privacy Policy (“Privacy Policy”) explains how WraSer collects and uses personal information about you as part of our business activities, including information we collect when you access or use our websites, mobile sites, mobile applications, and other digital services and products controlled by WraSer that link to this Privacy Policy (collectively, our “Digital Services”). This Privacy Policy describes what personal information we collect, how we use such personal information, who we may disclose it to and your rights and choices in relation to your personal information. 

This Privacy Policy does not apply to third-party websites linked from our Digital Services.

Table of Contents

This Privacy Policy contains the following information:

• Information We Collect
• How We Use Your Information
• Legal Basis for Collecting and Using Personal Information
• How Long We Keep Your Information
• Selling and Sharing Your Information
• Third Party Sites and Social Media Plug-ins
• Co-Branded Sites
• Data Security
• Children’s Privacy
• Your Privacy Choices and Rights
• Notice to California Residents
• Changes to Our Privacy Policy
• How to Contact Us With Privacy Concerns

Information We Collect

For purposes of this Privacy Policy, “personal information” means information that identifies you or that could reasonably be used to identify you. While some of the information WraSer collects is required for business engagement purposes, other information is voluntarily given by the individual. The types of personal information that WraSer may collect include, but is not limited to, the following:

• Contact information such as your name, address, phone number, or email address
• Registration information such as your username and password
• Information about your employment such as employer name, title, address and contact information
• Education and other background information when you inquire about employment with WraSer
• Payment information (such as banking information, payment card number, expiration date, delivery address, and billing address)
• Information about the electronic device you use to access our Digital Services
• Details of products and services you have purchased from us or inquiries you have made
• Preference information, such as communications you receive from us
• Any other information relating to you (or other individuals) which you provide to us directly or indirectly through access and use of our Digital Services, by email or by phone, surveys or questionnaires, completing forms or contacting customer service

We collect this information:

• Directly from you when you provide it to us
• Automatically as you navigate through our Digital Services
• From third parties, for example, our business partners

Some countries consider some categories of information particularly sensitive or special. We do not intentionally collect or maintain any sensitive information, including ethnicity, nationality, gender, religious beliefs, political opinions, health or genetic information.

Information You Voluntarily Provide To Us

You do not have to register for a service or program to receive much of the information available through our Digital Services. However, some of our content is available only to registered or identified users and will require you to set up a profile or provide specific information about yourself in order to provide you the service. When you sign up to be a registered user, we may collect information such as your company name, address, phone number, email, and password.

We also collect information that you provide to us when you purchase a product, sign up or request to receive marketing products and information, contact WraSer customer service via email, phone, mail, or otherwise, or respond to WraSer questionnaires or surveys. This information may include personal information, such as your name and email address, or other contact information, and your payment information, or other information related to your business or your concerns regarding our products. 

Information Collected Automatically

When you use our Digital Services, we also may collect certain usage and device information automatically as described below.

IP Address. We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you access our Digital Services. An IP address identifies the electronic device you use to access the Digital Services, which allows us to maintain communication with your computer as you navigate through our Digital Services and to customize content.

Cookies and Other Tracking Technologies. We also collect information about your use of our website through tracking technologies such as cookies and web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “web beacon” is a transparent graphic image placed on a website, e-mail or advertisement that enables the monitoring of things such as user activity and site traffic. These technologies help remember your preferences and allow us to bring you the content and features that are likely to be of greatest interest to you on the basis of “clickstream” data that shows your previous activities on our website.

We may work with new technologies in the future that require cookies or web beacons to provide their services. As we work with new technologies, their descriptions will be updated in the Privacy Policy. Our website is not designed to respond to “do not track” signals received from browsers.

To learn more about cookies and other tracking technologies, including how to disable them, please visit http://www.allaboutcookies.org/. Please note that some cookies are essential to the functioning of our website and deleting or disabling them will reduce the site’s functionality.

Mobile Tracking. Our Digital Services are available as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use our Digital Services, we may collect the following mobile-specific information in addition to the other information described above: device or advertising ID, device type, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your mobile operating system, the platform used to access or download our Digital Services (e.g., Apple, Google, Amazon, Windows), location information and usage information about your device and your use of the Digital Services.

Information We Obtain From Third Parties

To provide you with our products and services, we may also collect information (including personal information) from third parties, including from your organization and representatives, public sources, our related companies, and other parties.

When you submit an application for employment with us, we may also collect from third parties personal information about you, such as your education, employment, and other background information.

How We Use Your Information

WraSer uses the information we collect for the following principal purposes:

• To provide you with the WraSer product and services you request and to respond to inquiries and communicate with you.
• To offer and provide information about similar and/or related products and services that may be of interest to you.
• To customize and improve your experience on our Digital Services.
• To generally improve our products and Digital Services to better meet the needs of our customers.
• To comply with legal obligations to notify and report to authorities.
• To manage our business relationship with you, including for billing and collection purposes.

Providing Products and Services You Request. If you choose to purchase a product or receive our services, we use the information that you provide through our Digital Services to manage your orders and invoices, to process payments, to respond to your questions, provide you the services you request and offer an optimal customer experience.

Marketing. You may also receive marketing information from WraSer and related third parties, such as offers regarding WraSer related products or services, invitations to participate in surveys about our products, or notifications about special promotions. In such cases, we will use your contact and other personal information to send you marketing information. You may opt-out of receiving marketing communications from WraSer at any time by using the opt-out options specified in our marketing communications or by contacting us as described in the “How to Contact Us” section below.

Customized User Experiences. The personal information that you provide may be used to create customized offers, information, or services tailored to your interests and preferences. Also, we may use your IP address and the data that we obtain automatically through the use of cookies or similar tracking technologies to make our Digital Services easier to use and navigate as well as to personalize the content provided on our Digital Services by anticipating the information and services that may be of interest to you.

Business and Product Improvement. In order to discover new facts that could help WraSer better understand customer needs and help improve, develop, and evaluate product, services, materials, and programs, WraSer analyzes the information that you have provided. For these purposes WraSer does not use information that can directly identify you.

Website Analytics and Improvement. We may use the information that you provide and the information we collect automatically about your use of our Digital Services to monitor user traffic patterns and preferences for site improvement, analytics and optimization.

Legal Basis for Collecting and Using Personal Information

We collect and process personal data about you only where we have a legal basis, such as when you have given consent, where the processing is necessary to perform a contract with you, and for legitimate interests such as protecting you or others from threats, complying with laws, and to conduct business. Where we rely on your consent to process your personal data, you have the right to withdraw or decline your consent at any time.

How Long We Keep Your Information

We will retain your personal information for as long as necessary to provide any services you request, for as long as you accept marketing communications from us, for as long as necessary to comply with legal obligations, and for as long as necessary to perform other legitimate business purposes.

Sharing and Selling Your Information

We only share your personal information with third parties as described below. We do not sell personal information to third parties.

Business Partners, Vendors, and Suppliers. We have relationships with suppliers and affiliated companies, who help us operate our business and for whom it may be necessary to have access to your personal information in the course of providing services to WraSer. We may combine, share and exchange your personal information with our related or affiliated companies in an effort to assist in managing and providing products and services to you. We do not authorize these parties to use your personal information for any purpose that is not related to WraSer and its related third parties business operations. We may also share your personal information with third parties to offer and provide information about affiliate products and services. We require these third parties to handle your personal information collected and used in accordance with this Privacy Policy, and we will only share your personal information to the extent reasonably necessary to perform their functions.

Legal Rights and Obligations. In certain limited circumstances, WraSer may need to disclose your personal information in order to comply with a legal obligation or demand, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, including the U.S. Food and Drug Administration. In such instances, we will take measures to protect your personal information to the extent possible. We also reserve the right to use personal information to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.

Change in Organization. In the event WraSer decides to reorganize or divest our business through sale, merger, or acquisition, or in connection with the sale or transfer of one of our product lines or divisions, which includes the services provided through one or more of our Digital Services, WraSer may share personal information about you with actual or prospective purchasers. We will require any actual or prospective purchasers to treat this personal information in a manner consistent with this Privacy Policy.

Third Party Sites and Social Media Plug-ins

This Privacy Policy does not apply to third-party websites that do not link to this Privacy Policy, or to third-party websites to which our Digital Services may link.

Our Digital Services may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our Digital Services, the operator of the social plug-in can place a cookie on your computer or other electronic device that enables that operator to recognize individuals who have previously visited our Digital Services. If you are logged into the social media website (e.g., Facebook, Twitter) while browsing on our Digital Services, the social media plug-in allows that social media website to receive information that you have visited our Digital Services. The social media plug-in also allows the social media website to share information about your activities on our Digital Services with other users of their social media website. These sharing settings are managed by the social media website and governed by its privacy policy.

Co-Branded Sites

We may partner with other companies to provide you with content or services on a joint or “co-branded” basis. At a co-branded site, you will see both the WraSer logo and the logo of the co-branding partner displayed on your screen. You should read the individual privacy policies of our co-branding partners, as they may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site.

Data Security

WraSer maintains reasonable technical, administrative and physical controls to secure any personal information collected through our Digital Services. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting personal information over the Internet, especially your financial-related information. WraSer cannot guarantee that unauthorized third parties will not gain access to your personal information; therefore, when submitting personal information through our Digital Services, you must weigh both the benefits and the risks.

Children’s Privacy

WraSer does not knowingly collect or use any personal information directly from children through our Digital Services (WraSer defines “children” as minors younger than 18). We do not knowingly allow children to order our products, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

Your Privacy Choices and Rights

With respect to personal information that we may have collected about you, you may:

• Ask us to erase or delete all or some of your personal data;
• Ask us for a copy of your personal data, including in machine readable form;
• Ask us to change, update, or fix your data if it is inaccurate; and
• Ask us to stop using all or some of your personal data (where we have no legal right to keep using it) or to limit our use of it.

You may contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Notice to California Residents

If you are a resident of California, in addition to the above described rights, you also have a right to know certain information regarding our use of your personal information over the past 12 months.

Categories of personal information collected and disclosed for business purposes in the preceding 12 months is described above in “Information We Collect” and “Sharing and Selling Your Information.”

Business or commercial purposes for collecting your personal information is described above in “How We Use Your Information” and “Legal Basis for Collecting and Using Personal Information.”

Categories of sources of personal information includes information that you voluntarily provide to us, information collected automatically, and information we obtain from third parties. For more information, see “Information We Collect.”

Categories of third parties with whom we share personal information is described above in “Sharing and Selling Your Information.”

Please note that WraSer does not sell your personal information.

To exercise any of your California personal data rights, please contact us using one of the two contact methods below in “How to Contact Us with Privacy Concerns.” Of course, if you do exercise any of these rights, WraSer will not treat you any differently.

Changes to Our Privacy Policy

We reserve the right to change the terms of this Privacy Policy at any time. Any changes to this Privacy Policy will be reflected on this page with a new effective date. WraSer encourages you to review this Privacy Policy regularly for any changes. Your continued use of our Digital Services after we post changes is deemed to be acceptance of those changes.

How to Contact Us with Privacy Concerns

WraSer is committed to resolving your privacy concerns and any complaint. If you have a concern or complaint about privacy at WraSer, please contact our Privacy Office by emailing us at Privacy@WraSer.com. You may also send a letter to the following address:

WraSer Pharmaceuticals

121 Marketridge Drive

Ridgeland, MS 39157

United States

In all communications to WraSer, please include your email address, the Web site address, mobile application, and/or the specific WraSer product to which you provided personal information (e.g., https://wraser.com), and a detailed explanation of your request. If you would like to delete, amend, or correct your personal information and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email. We will respond to all reasonable requests in a timely manner and may need to further confirm your identity in order to process certain requests.