VLP Therapeutics Privacy Policy
Version 1.0, Updated: May 8, 2025
This Privacy Policy discusses:
- Who We Are
- Scope of the Privacy Policy
- Information Collected
- Marketing, Cookies & Tracking
- Third Parties
- Your Rights Regarding Your Personal Information
- Safeguarding Information
- How Long Your Personal Information Will Be Retained
- Changes to This Privacy Policy
- Contact Us
For Residents of:
- California
- Colorado, Connecticut, Delaware, Florida, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia
* * *
Who We Are
VLP Therapeutics, Inc. (“VLPT,” “we,” “our,” or “us”) values your privacy and the protection of your Personal Information. This Privacy Policy (“Policy”) explains how we collect, store, use, share, transfer, delete, and process information collected from or about you known as Personal Information (defined further below in this Policy).
Scope of the Privacy Policy
This Policy describes the types of Personal Information that VLPT may collect or process, how we may use and disclose that Personal Information, and how you may exercise any rights you may have regarding our processing of your Personal Information.
This Policy applies to Personal Information collected or processed by us, which may include but not limited to:
- Our websites, microsites, and mobile sites operated by us from which you are accessing this Privacy Policy as well as applications, email, online messaging services/channels, and otherwise (“Online Services”);
- Our software applications made available for use on or through computers, mobile devices, and connected devices;
- Our social media pages and apps that we control from which you are accessing this Privacy Policy (collectively referred to as our “Social Media Pages”);
- Our business and vendor relationships;
- Our products and services;
- HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you;
- Related to activities we undertake in recruiting participants for participation in clinical trials or activities related to identifying and contracting with study investigators and their staff;
- When we provide clinical trial opportunities to you or your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, “Healthcare Provider,” which refers both to the Healthcare Provider institution, organization, or company, and individuals employed by or working for or with such organization) or, if you are a Healthcare Provider, your patients;
- When we provide products and services directly to you and in other situations where you interact with us, including but not limited to interacting with us through our telephone customer service centers, though email or SMS/text messages, or by visiting our sites and offices or our events (e.g., tradeshows and conferences) (such products and services, together with Online Services, are collectively, the “Products and Services”);
- When you interact with us in a professional capacity, for example, if you are a Healthcare Provider or an employee of a company with which we do business or provide Products and Services;
- When we undertake employment recruiting activities; or
- Anywhere this Policy is posted or referenced.
VLPT may provide you with a different Privacy Policy in certain specific situations, in which case that privacy Policy or policy will apply to the Personal Information collected or processed in that specific situation, rather than this one.
If you provide us with Personal Information of anyone other than yourself (such as a patient or family member), please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to VLPT (including obtaining consent, if required).
Please review this Policy carefully. To the extent permitted by applicable law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Policy.
Collectively we consider the above our “Services”.
This Privacy Policy does not apply to any third-party websites, service or applications, even if they are accessible through our Services. Please consult their respective privacy policies to learn more about how they process your Personal Information and how they make it available to others.
Information Collected
What is Personal Information?
“Personal Information” is information that relates to an identified or identifiable individual, including as such term is defined in the applicable law. We collect Personal Information through your use of our Services and in certain instances from third parties. We also use and combine data to infer insights about you, for example, predispositions, or online behaviors.
Personal Information We Collect From You
We collect Personal Information through your use of our Services, for example, when you contact us to access our Services, participate in our sponsored clinical trials, use our products, communicate with us, or become a partner or vendor.
Depending on how you use our Services, we collect different types of Personal Information from you:
- Identity and contact information, such as:
- first and last name or unique pseudonym
- email address
- postal address
- phone number
- Other personal information, such as:
- age
- gender
- marital status
- disability
- ethnicity
- date of birth
- written signature on a patient consent form or program enrolment form
- Technical Information, such as:
- Internet Protocol (IP) addresses (which may identify your general geographic location or company)
- browser type and browser language
- device type
- activity on our Products and Services and referring websites or applications
- data collected from cookies or other similar technologies
- Information regarding your treatment, such as:
- identification of pathologies/diseases
- areas of interest in medical research
- treatment dates
- medical history and treatment information
- user activity
- therapy completion and use details
- drug allergies
- prescriptions and dosing
- health values and sensor readings data, such as steps taken, blood glucose levels, heart rate, and blood pressure
Sensitive Personal Information
Personal Information may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information.
Marketing, Cookies & Tracking
To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we may engage in the following activities:
- We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us If you do not wish to receive emails, you may opt out by declining to receive such emails when registering or in our subsequent communications by following opt-out or unsubscribe instructions included in the email or at other information collection points on the Online Services.
Opt-out of Sale, Sharing, Targeted Advertising, or Limit the Use of Sensitive Data
- Certain of VLPT’s practices may be considered the sale or sharing of Personal Information under applicable law. You may have the right to opt-out of the sale of Personal Information, opt-out of sharing of Personal Information for purposes of cross-context behavioral advertising, which in other states is the right to opt-out of targeted advertising, and the right to limit the use of sensitive Personal Information. To exercise these rights, please email: opt-out@vlptherapeutics.com.
Third Parties
Service providers acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Information as necessary to perform their functions in a manner consistent with this Policy, other applicable Privacy Policies, and as explicitly permitted or required by applicable laws, rules, and regulations. We may combine information we collect, including Personal Information, with Personal Information that we may obtain from third parties.
Your Rights Regarding Your Personal Information
Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Information about you (e.g., your contact information). To the extent that the state in which you live has a data protection law that requires us to offer some or all of the following rights to you, we will provide the following rights to you based on your state’s law:
- To opt-out of sharing your Personal Information for cross-context behavioral advertising or, in other states, to opt-out of targeted advertising;
- To request access to and a copy or representative summary of your Personal Information, including to provide your Personal Information directly to another organization, i.e., a right to data portability;
- To request to know about the Personal Information we process about you or, in other states, to request to acknowledge our processing of your Personal Information or a list of the categories of third parties to which your Personal Information has been disclosed;
- To request that we correct your Personal Information;
- To request that we delete your Personal Information;
- To request that we limit the processing of your Sensitive Personal Information;
- To opt-out of processing of Sensitive Personal Information;
- To appeal the denial of a request; and
- To lodge a complaint with the data protection authority in your jurisdiction.
To make this request, you may email: opt-out@vlptherapeutics.com.
We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Safeguarding Information
Consistent with applicable laws and requirements, VLPT has put in place physical, technical, and administrative safeguards designed to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services.
How Long Your Personal Information Will Be Retained
We generally retain Personal Information for as long as needed for the specific business purpose or purposes for which it was collected or obtained, and as outlined in this Notice. In some cases, we may be required to retain Personal Information for a longer period of time by law or for other necessary business purposes. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Information; and (iii) whether retention is determined to be necessary or advisable for VLPT due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. VLPT takes reasonable steps to dispose of Personal Information upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.
Changes to This Privacy Policy
We reserve the right to change this Policy from time to time. We will alert you when changes have been made by indicating the date this Policy was last updated as the date the Policy became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Policy to learn of any changes.
Contact Us
Specific questions about this Privacy Policy may be directed to us at:
VLP Therapeutics, Inc.
704 Quince Orchard Rd., Suite 110
Gaithersburg, MD 20878
United States
Additional Privacy Policy for California Residents
Last Updated: 5/13/2025
We are providing the following additional details regarding the Personal Information that we collect, use, and disclose about California residents.
Additional Disclosures Under the California Consumer Privacy Act (“CCPA”) As Amended by the California Privacy Rights Act (“CPRA”)
The following chart includes: (1) the categories of Personal Information that we plan to collect and have collected and disclosed within the preceding 12 months; (2) the categories of third parties to which we disclosed Personal Information for our operational business purposes within the preceding 12 months, and 3) the business purpose for such disclosure.
|
Categories of Personal Information |
Disclosed to Which Categories of Third Parties for Operational Business Purposes |
Business Purpose for Disclosure |
|
Identifiers, such as name, contact information, online identifiers, IP address, account identifier, or email address. |
Affiliates; vendors |
Providing services, analytics, and legal compliance |
|
Personal information, as defined in the California customer records law, such as name, contact information, insurance policy number, education, employment, employment history, financial information, medical information and health insurance information. |
Affiliates; vendors |
Providing services, analytics, and legal compliance |
|
Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status. |
Affiliates; vendors |
Providing services, analytics, and legal compliance |
|
Commercial information, such as transaction information, purchase history and financial details. |
Affiliates; vendors; business partners |
Analytics and legal compliance. |
|
Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems. |
Affiliates; vendors; professional advisors, such as legal advisors; legal authorities, government agencies, and regulators |
Analytics and legal compliance. |
|
Geolocation data, such as device location, your physical location, and IP location. |
Affiliates; vendors; contest sponsors |
Providing services, analytics, and legal compliance |
|
Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities. |
Affiliates; vendors; professional advisors, such as legal advisors; legal authorities, government agencies, and regulators |
Providing services, analytics, and legal compliance |
|
Professional or employment-related information, such as employer. |
Affiliates; vendors; professional advisors, such as legal advisers, accountants, and financial advisers; legal authorities, government agencies and regulators |
Providing services, analytics, and legal compliance |
|
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. |
Affiliates; vendors |
Providing services, analytics, and legal compliance |
Please note that some of this Personal Information qualifies as Sensitive Personal Information under the CPRA. Specifically, in the past 12 months, we have collected and/or disclosed the following categories of Sensitive Personal Information:
- Financial account information; and
- Precise geolocation information.
We have also sold (as defined in CPRA) the following categories of Personal Information in the last 12 months:
- Geolocation data has been disclosed to business partners or third parties for commercial purposes
- Cookie data has been disclosed to our business partners for commercial purposes.
Additionally, pursuant to the definition of “sharing” under the CPRA, we have shared email addresses, to third parties in the last 12 months for commercial purposes.
Your Rights as a California Resident
Right to Disclosure of Information: You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
- The categories of Personal Information we have collected about you in the last 12 months.
- The categories of sources for the Personal Information we have collected about you in the last 12 months.
- Our business or commercial purpose for collecting 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.
- If we disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.
Right to Delete Personal Information: You have the right to request that we delete your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.
Right to Correct Your Personal Information: If you find that we maintain inaccurate Personal Information, you have the right to request that we correct such inaccuracy.
Right to Limit Use of Sensitive Personal Information: You have the right to instruct us to limit our use of your Sensitive Personal Information to that which is necessary to provide the Services.
Right to Out of the Sale or Sharing of Your Personal Information: You have a right to opt-out of the sale or sharing of your Personal Information. You may, at any time, direct businesses that sell your Personal Information to third parties not to sell or share your Personal Information.
Right to Non-Discrimination: You have the right not to be discriminated against for the exercise of your California privacy rights described above.
Your Rights Under California’s Shine the Light Act
We do not disclose personal information to third parties for their direct marketing purposes.
How to Exercise These Rights
If you wish to submit a request to exercise one or more of the rights listed above you can do this by:
- Emailing us at opt-out@vlptherapeutics.com.
- Calling us at 240-801-4456.
Authorized Agents
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent. In addition, we may require the individual on whose behalf you are making the request to verify their own identity or your permission to submit the request.
Additional Privacy Policy to Colorado, Connecticut, Delaware, Florida, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia Residents
Last Updated: 5/13/2025
This section provides additional details regarding the Personal Information that we collect or process about Colorado, Virginia, Utah, Oregon, Montana, Tennessee, Delaware, Iowa, Minnesota, Nebraska, New Hampshire, New Jersey, and Connecticut residents, and describes your rights pursuant to the privacy laws in those states.
Additional Disclosures
In the last 12 months, we have made the following disclosures of Personal Information to third parties. Please note that for the purposes of state law, these disclosures may constitute a “sale” of your Personal Information:
- Geolocation data has been disclosed to business partners or third parties for commercial purposes
- Cookie data has been disclosed to our business partners for commercial purposes.
Additionally, we have used your Personal Information for purposes of targeted advertising in the past 12 months.
Per certain state laws, you also have the right to know the categories of Personal Information shared with third parties listed above in the section titled “Recipients.” The list below outlines the categories of Personal Information we disclose to such third parties.
- Identifiers, such as name, contact information, online identifiers, IP address, account identifier, or email address.
- Personal information, such as name, contact information, insurance policy number, education, employment, employment history, financial information, medical information and health insurance information.
- Characteristics of protected classifications under state or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status.
- Commercial information, such as transaction information, purchase history and financial details.
- Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems.
- Geolocation data, such as device location, your physical location, and IP location.
- Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.
- Professional or employment-related information, such as employer.
- Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Your Rights
Under the laws of those states listed above, users who are residents of these states have specific rights regarding their Personal Information. These rights are subject to certain exceptions described below. When required and permitted, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time. Subject to certain limitations, you have the following rights depending on your state of residence. Please note that at this time, we do not process your Personal Information for purposes of profiling in furtherance of decisions that produce legally or similarly significant effects concerning a consumer, and therefore, such opt-out rights are not available.
Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Tennessee, Texas, Virginia
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- The Right to Opt Out: You have the right to opt out of targeted advertising, the sale of your Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects.
Florida
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- The Right to Opt Out: You have the right to opt out of:
- Targeted advertising, the sale of your Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects;
- The collection of sensitive data including precise geolocation data;
- The processing of sensitive data; and
- The collection of Personal Information collected through the operation of a voice recognition or facial recognition feature.
Oregon
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information. You may also obtain a list of specific third parties, other than natural persons, to which we have disclosed your Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- The Right to Opt Out: You have the right to opt out of targeted advertising, the sale of your Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects.
Maryland
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- Right to Opt Out: You have the right to opt out of targeted advertising, the sale of your Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects.
Minnesota
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- Right to Opt Out: You have the right to opt out of targeted advertising, the sale of your Personal Information and profiling in furtherance of decisions that produce legal or similarly significant effects.
- Further Rights Concerning Profiling: If we profile your Personal Information in furtherance of decisions that produce legal effects, you have the right to question the result of the profiling, to be informed of the reason that the profiling resulted in the decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision and the actions that you might take to secure a different decision in the future. You have the right to review your Personal Information used in the profiling. If the decision is determined to have been based upon inaccurate Personal Information, you have the right to have the data corrected and the profiling decision reevaluated based upon the corrected data.
Iowa
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
- Right to Correction: You have the right to correct inaccuracies in your Personal Information.
- The Right to Opt Out: You have the right to opt out of the sale of your Personal Information.
Utah
- Right of Access: You have the right to confirm whether we process your Personal Information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete Personal Information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your Personal Information in a portable format.
How to Exercise These Rights
You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by emailing us at opt-out@vlptherapeutics.com or calling us at 240-801-4456.
In order to protect your privacy and the security of your information, we verify consumer requests by requesting identification documents and other necessary documentation where legally permitted in order to confirm your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.
We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 45 days of receipt.
Authorized Agents or Other Authorized Parties in Colorado, Connecticut, Delaware, Oregon, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Texas.
If you want to make a request as an authorized agent on behalf of a resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent.