NRx is committed to your privacy and wants you to be familiar with the way we collect, use and share information. This Privacy Policy explains our practices in relation to information that we or our service providers collect using the website or application (hereinafter referred to as the “Service”) that is operated and controlled by us and from which you can access this Privacy Policy. By providing us with personal data or using the service, you acknowledge that you have read and understood this data protection declaration.

USE BY MINORS

The service is not intended for use by anyone under the age of 16. These persons may only use the service with the consent of their legal guardians. We do not knowingly collect any data from minors unless their legal guardians have given their consent. If a minor has nevertheless submitted personal data without the required consent and the legal guardian(s) would like such data to be removed, please contact us as explained below under “Contact Us”.

COLLECTING INFORMATION ABOUT YOU

If necessary, we will ask you to submit personal data in order to use the functions described (such as registration for newsletters, tips / information or processing orders) or to be able to participate in special activities (such as competitions or other promotions). You will be informed which information is mandatory and which information can be provided on a voluntary basis. We are entitled to combine the information you provide with other information you have collected online or offline, such as your previous purchasing behavior, provided this is necessary for the fulfillment of contractual purposes and / or permitted by law. We will inform you accordingly. We can also combine this with information that we receive about you from our future product sites. If you provide us with personal data about another person, you declare that you are authorized to do so and allow us to use this information in accordance with this data protection declaration.

SENSITIVE INFORMATION

Unless we specifically ask or ask you to do so, we normally do not ask you to provide us with sensitive personal information (e.g. social security numbers, information on racial or ethnic origin, political beliefs, religious or philosophical beliefs, health, on sex life or sexual orientation, on criminal history or membership in trade unions or on biometric or genetic data for the purpose of uniquely identifying a person), nor to forward sensitive information to us using the service or in any other way.

PASSIVE COLLECTION OF INFORMATION AND ITS USE

We and our service providers may collect certain information in a passive way, that is, without your expressly entering it, while you are using our service. We and our service providers can also automatically collect and use information in the following ways:

Information about your browser:

Most browsers collect certain information, such as your Media Access Control (MAC) address, type of computer (Windows or Mac), screen resolution, the name and version of your operating system, and the type and version of your Internet browser. We can collect comparable information, such as your device type and the corresponding identification number, if you access our service with a mobile device. We use this information to ensure that our service is working properly.

Information about your IP address:

Your IP address is a combination of numbers that is automatically assigned to your computer by your Internet service provider. An IP address is always identified and automatically recorded in the log files of our server when a user calls up our service. The time of visit and the pages visited are also recorded. The acquisition of IP addresses is standard practice on the Internet and is carried out automatically by many online services. We use IP addresses, for example, to calculate the extent of service usage, to diagnose server problems and to administer the website or the application. We can also derive your approximate location from your IP address.

Information about your devices:

We may collect information about your mobile device, such as a unique device identifier (IMEI), to understand how you use the website or application. However, such collection only takes place if it is necessary for the provision of the respective service used.

HOW WE USE AND DISCLOSE INFORMATION

As far as legally permissible, we will obtain your consent to the use of your personal data at the time of data collection. We can also rely on other legal bases, in particular:

• To ensure the functionality of this service and to meet your requirements;
• To provide you with the functionality of this service and related customer support;
• To answer your inquiries and fulfill your requests, such as sending documents that you request or email notifications;
• To send you important information regarding our business relationship with you or on the website or application, changes to our terms, conditions and policies and / or other administrative information.

We will use these activities to manage our contractual relationship with you and / or to comply with a legal obligation.

Realizing our business purposes:

• For data analysis, for example to improve the efficiency of the service;
• For audits – to verify that our internal processes are working as intended and are in line with legal, regulatory or contractual requirements;
• For fraud and security monitoring purposes, for example to detect and prevent cyber attacks or attempts to commit identity theft;
• To develop new products and services;
• To upgrade, improve or modify our website or our products and services;
• To identify trends in service usage, for example to understand which parts of our service users are most interested in; and
• To determine the effectiveness of our advertising campaigns so that we can adapt our campaigns to the needs and interests of our users.

We will use these activities to manage our contractual relationship with you, to comply with a legal obligation and / or because we have a legitimate interest in doing so.

Analysis of personal information in order to be able to offer personalized services:

• To understand you better so that we can personalize our interactions with you and to send you information and / or offers that are tailored to your interests;
• For a better understanding of your preferences in order to provide you with the content of the service that we believe is relevant and interesting to you.

We offer personalized services either with your consent or because we have a legitimate interest in doing so.

We also share information collected through our service with the following third parties:

• To all of our NRx companies (hereinafter referred to as “companies”) for the purposes set out in this privacy policy. We remain the responsible body for the handling of the shared personal data;
• To our business partners, with whom we offer advertising with joint brands and joint marketing;
• To our service providers who offer services such as website hosting and moderation, hosting of mobile applications, data analysis, payment processing, order processing, provision of the infrastructure, IT services, customer service, delivery services for e-mails and direct mail, auditing and other services in order to be able to offer this service; and
• To the extent permitted by applicable law, to third parties in the event of reorganizations, mergers, sales, joint ventures, assignments, transfers or other dispositions with regard to our entire company or all of our assets or shares or parts thereof (for example in connection with bankruptcy or similar procedure).

In addition, we may use and share your information as we deem necessary or appropriate: 

1. To comply with legal process or applicable law, which may include laws outside your country of residence; 
2. To respond to inquiries from public and state authorities, such as side effect reports, possibly including public and state authorities outside your country of residence; 
3. To enforce our terms and conditions; and 
4. To protect our rights, privacy, safety or property, those of our affiliates or those of yourself and others. We can also use and pass on your information for other purposes, provided we have obtained your consent.

We can use and pass on information that we collect automatically as described above under “Automatic collection and use of information”.

In addition, to the extent permitted by law, we can use and pass on information that is not of a personal nature for purposes of any kind. When we combine information that is not of a personal nature with identifiable information (such as the association of your name with your geographic location), we treat the associated information as personal data for as long as it is associated.

RIGHT OF WITHDRAWAL / RIGHT OF OBJECTION

Objections to the use and disclosure of your personal data by us:

We give you options with regard to the use and disclosure of your personal data for marketing purposes. You can revoke your consent for the future in the following cases:

Receiving marketing communications from us: If you no longer wish to receive marketing communications from us in the future, you can withdraw your consent to receive them by contacting us via email at privacy@nrxpharma.com. When you contact us, please include your name, identify the type (s) of marketing communications you no longer wish to receive and the address(es) to which the communications will be sent. For example, if you no longer wish to receive marketing emails or direct mail from us, please let us know and provide your name and email address or postal address.

Receiving reminders from us: If you no longer wish to receive medical reminders from us in the future, you can withdraw your consent to receive them by contacting us via email at privacy@nrxpharma.com. In your email to us, please include your name and the email address or telephone number at which you receive reminders from us.

Use of your personal data by group companies and by our business partners: If you have previously chosen to receive marketing communications from our partners or group companies or third parties, you can opt out of your personal data being passed on to these parties for their direct marketing purposes by contacting us contact via email at privacy@nrxpharma.com. In your communication to us, please expressly state that we are no longer allowed to pass on your personal data to our group companies and / or our business partners for their marketing purposes and include your name and email address.

We will endeavor to comply with your request as soon as possible. Please note that in the event of the revocation described above, we can no longer remove your personal data from the databases of the group companies to which we have already passed on your data (i.e. up to the point in time at which we process your request to unsubscribe). Please also note that even if you have withdrawn your consent to continue receiving marketing communications, we may still send you important business and administrative communications.

Access to personal data and their modification or deletion (right of information)

If you would like to review, correct, update, limit or delete your personal data or if you would like to request an electronic copy of your personal data for the purpose of transferring it to another company (to the extent that these rights are made available to you by applicable law), contact us via email at privacy@nrxpharma.com. We will respond to your request as soon as possible, but no later than one month after receipt. If circumstances cause a delay in our response, you will be notified immediately and given a date for our response.

CROSS-BORDER TRANSMISSION

Your personal data can be stored and processed in every country in which we have branches or employ service providers, and with the use of our service or the giving of your consent to us (where required by law), your data can be transferred to countries outside your country of residence, including the United States, which may have different data protection rules than your country. Suitable contractual, and other, measures are in place to protect personal data if they are passed on to our group companies or to third parties in other countries. For transfers from the European Economic Area (EEA) to other countries, where such transfers are not considered appropriate by the European Commission, we have ensured that appropriate measures are taken, including by ensuring that the recipient adheres to EU standard contractual clauses and / or EU-US Privacy Shield Certification and is bound to protect your personal information. You can obtain a copy of these measures by contacting the company in accordance with the “Contact Us” section.

SECURITY

We take appropriate organizational, technical and administrative precautions to protect personal data that is collected and used in our area of responsibility. Unfortunately, there is no guarantee that data transmission over the Internet or a data storage system will be 100% secure. If you have reason to believe that your communication with us is no longer secure (for example, if you believe that the security of one of your accounts with us has been compromised), please report the problem to us immediately by contacting us accordingly in the “Contact Us” section below.

RETENTION PERIOD

We will keep your personal data for as long as is necessary and permissible with regard to the purposes for which it was collected. The criteria for determining our retention periods include: 

1. The length of time that we have an ongoing relationship with you and provide the service to you; 
2. Whether there is a legal retention obligation to which we are subject; and 
3. Whether retention is necessary in view of our legal situation (for example, with regard to applicable statute of limitations, legal disputes or regulatory investigations). 

For example, if we store your personal information to conclude a contract with you, we will keep the information for 15 years after the contract has expired. In cases in which you have given us your consent to receive marketing information, we will store your data until you revoke your consent or for 5 years, whichever is shorter. 

Please note, however, that this is not a comprehensive list of retention periods. Your personal data can be stored for a longer period of time, when the criteria mentioned in the first paragraph of this section, in particular points (ii) and (iii), apply.

THIRD PARTY WEBSITES AND SERVICES

This data protection declaration does not apply to the regulations on data protection, information or the like of third parties, including those third parties who operate a website or an online service (including, among other things, any kind of applications) that use this service is offered or to which this service contains a link. We are also not responsible for such third-party regulations. The availability of such websites or environments on our website or our inclusion of a link to the service does not constitute an endorsement by us or our group companies.

CONTACT US

NRx Pharmaceuticals, headquartered at 1201 N Market St., Ste 111, Wilmington, Delaware 19801, United States of, is the company that is responsible for the collection, use and disclosure of personal data in the context of this data protection declaration.

If you have any questions about this privacy policy, please contact us via email at privacy@nrxpharma.com or write to us at the following address:

NRx Pharmaceuticals 
1201 N Market St. 
Suite 111 
Wilmington, DE 19801 
United States of America

SUBMIT A COMPLAINT TO A REGULATORY AUTHORITY

You can lodge a complaint with a supervisory authority that is responsible for your country or region. Please contact us via email at privacy@nrxpharma.com for more information on these authorities.

UPDATES TO THIS PRIVACY POLICY

We can change this privacy policy at any time. Any changes to this privacy policy will take effect when revised and posted online. By using our services following such changes, you express that you accept the revised data protection declaration. We recommend that you read the data protection declaration regularly when you use our services. This policy was last updated on May 24, 2021.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in NRx Privacy Policy (above), and applies only to California residents (“You,” “your” or “consumer”).

Personal Information Collection and Purposes of Use

We collect and use information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your devices when you visit this website, provide us your personal information, or have a contractual or business relationship with us or any of our affiliates, (“Personal Information”). Such Personal Information includes direct identifiers like a name, postal address, email address, social security number or other government identifier, and indirect identifiers that may identify, relate to, or be associated with a particular individual, such as a telephone number, device identifier, IP address and browsing history, credit card information, or inferences about consumer preferences or characteristics.

We collect this Personal Information for the following purposes:

• To respond to your inquiries and to fulfill your requests;
• To send you important information regarding our relationship with you or regarding this website, changes to our terms, conditions, and policies and/or other administrative information;
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
• For fraud or crime prevention, and for technical security monitoring purposes;
• To facilitate the development of new products and services;
• To enhance, improve or modify our website or products and services;
• For data analysis that will allow us to understand website usage trends;
• To determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
• To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;

Our Personal Information Handling Practices in 2019

In the preceding 12 months, we have collected the following categories of Personal Information from California residents who have visited this website, provided us their Personal Information, or had or have a contractual or business relationship with us or any of our affiliates:

Direct identifiers as described above.

Indirect identifiers as described above.

We have collected such Personal Information from one or more of the following categories of sources:

• Information that you submit or share directly with us, through registrations, surveys, applications, or telephone calls, and email and postal communications;
• Information passively collected from cookies and other website analytics;
• Information collected through third parties or from your browsing activity on other sites, such as on social media platforms, and public databases;
• From one or more of our affiliates with which you have a business relationship;
• Service providers with which we have a contractual relationship and to which you have provided your Personal Information

We collected such Personal Information for the purposes noted above (see “Personal Information Collection and Purposes of Use”) and in the NRx Privacy Policy (see “How We Use and Disclose Information”):

We may have shared such Personal Information with the following categories of third parties:

• Service providers that help us to run our business, such as call centers and order fulfillment and distribution companies, credit card processing companies, web hosting and development companies, and direct marketing agencies;
• Vendors that help us track the effectiveness of advertisements on our Sites;
• Vendors that help us to provide you with program, services or educational information we believe may be of interest to you;
• third parties with which we jointly market a product;
• Affiliates and subsidiaries that may have or may want to seek a business relationship with you.

We collected one or more of the following specific pieces of personal information:

• Legal name, nickname, signature, email address, postal address, date of birth, number, physical characteristics or description, educational level, current employment or employment history, biometric information, and/or geolocation data;
• Any other medical information and/or health insurance information;
• Online identifier, Internet Protocol address, Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement;

Unless specifically stated, we do not share, disclose or sell personal information to third parties for their own use, but we do share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.

Your Privacy Rights

You have the following rights regarding our collection and use of your personal information. To exercise those rights, you must submit a request via email at privacy@nrxpharma.com. We may ask you to provide additional information to verify your request. We may not discriminate against you if you exercise your rights as described in this notice. For example, we may not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality of products or services.

Right to Information

You have the right to request the following information regarding the personal information we have collected about you:

• Categories of personal information collected about you, and sources from which they are collected;
• Our purpose for collecting personal information;
• Categories of third parties with which the personal information was shared; and
• Specific pieces of personal information collected about consumers.

You have the right to request the following information regarding the personal information we have sold or disclosed about you:

• Categories of your personal information sold in the preceding 12 months;
• Categories of third parties to whom your personal information has been disclosed;
• Categories of personal information that we disclosed about consumers for a business purpose.

Right to Opt Out of Sharing, Disclosure, or Sale of Personal Information

You have the right to direct us to not share, disclose, or sell your personal information. To exercise this right, you or your authorized representative may submit a request by sending an email to privacy@nrxpharma.com. Please include: “Do Not Sell My Personal Information” in the subject and body of the email. 

Right to Request Deletion

You have the right to request that we delete the personal information we have about you. However, we are not required to delete information if it is necessary to retain your information to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or a transaction reasonably anticipated within the context of our or one of our affiliate’s ongoing business relationship with you, or to otherwise perform a contract we have with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impact the achievement of such research, if you have provided informed consent;
• Facilitate solely internal uses that are reasonably aligned with your expectations based on your relationship with us or one of our affiliates;
• Comply with a legal obligation;
• Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which it was provided.

Contact Us

You can contact us with questions about this Privacy Notice for California Residents or to exercise your rights as described in this Notice.

Telephone number: +1 (484)224-9856 

Email address: privacy@nrxpharma.com

Contact Title: NRx Privacy & Data Protection

SUPPLEMENTAL PRIVACY NOTICE FOR NEVADA RESIDENTS

Effective: October 1, 2019

This Supplemental Privacy Notice for Nevada Residents adds to the information contained in the NRx Privacy Policy (above), and applies only to Nevada residents (“You,” “your” or “consumer”).

Personal Information Collection and Purposes of Use

We collect certain personal information of Nevada consumers through our Internet websites or other online service. This information includes one or more of the following elements of personally identifiable information:

• A first and last name;
• A home or other physical address that includes the name of a street and the name of a city or town;
• An electronic mail address;
• A telephone number;
• A Social Security Number;
• An identifier that allows a specific person to be contacted either physically or online;
• Any other information concerning a person collected from the person through the Internet website or online service of the operator and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.

We collect this personal information for the following purposes:

• To respond to your inquiries and to fulfill your requests;
• To send you important information regarding our relationship with you or regarding this website, changes to our terms, conditions, and policies and/or other administrative information;
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
• For fraud or crime prevention, and for technical security monitoring purposes;
• To facilitate the development of new products and services;
• To enhance, improve or modify our website or products and services;
• For data analysis that will allow us to understand website usage trends;
• To determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
• To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

Your Privacy Rights

Right to access and/or correct your personal information or opt out of sale of personal information.

If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request via email to privacy@nrxpharm.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

We generally do not disclose or share personal information for profit. Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may submit a request via email to privacy@nrxpharma.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Contact Us

You can contact us with questions about this Privacy Notice for Nevada Residents or to exercise your rights as described in this Notice.

Email address: privacy@nrxpharma.com

Mailing address: 

NRx Pharmaceuticals 
1201 N Market St.
Suite 111 
Wilmington, DE 19801 
United States of America