Introduction

Galt Pharmaceuticals, LLC (referred to as “Company,” “Galt,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy (“Privacy Policy”) describes the types of information we may collect from you, or that you may provide, when you visit the website NorgesicForte.com (our “Site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Site is intended for patients and visitors in the United States.

This Privacy Policy applies to information we collect on this Site and in email and other electronic messages between you and this Site. It does not apply to information collected offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries), information you provide through voluntary responses to emails, or information collected by any third party whose website, application, or content may link to or be accessible from this Site.

Please read this Privacy Policy carefully. By accessing or using this Site, you agree to it. If you do not agree with our policies and practices, your choice is not to use our Site. This policy may change from time to time; your continued use of this Site after we post changes is deemed acceptance of those changes, so please check this page periodically for updates.

Children Under the Age of 16

Our Site is not intended for children under 16 years of age, and no one under 16 may provide any personal information on the Site. We do not knowingly collect personal information from children under 16, and we do not sell or share the personal information of consumers under 16 years of age. If you are under 16, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will use commercially reasonable means to delete that information. If you believe we might have any information from or about a child under 16, please contact us by emailing galtdirect@galtrx.com or by calling (855)-965-2783.

Information We Collect and How We Collect It

This Site collects very little information. It contains no forms, no login, and no interactive features that ask anything of you. What we do collect falls into two groups: information you choose to send us, and information our web servers record automatically.

Information You Provide to Us

• Records and copies of your correspondence, including your email address, if you choose to contact us.

This Site does not host any forms. Links on this Site that relate to requesting drug samples, or to contacting us, lead to separate websites operated by Galt or by third parties. Those websites have their own privacy policies and their own practices, and this Privacy Policy does not apply to any information you provide there.

Galt does not knowingly collect, request, or obtain any personally identifiable information related to your medical history, health, or finances. Nothing on this Site is intended to solicit any such information, and by interacting with our Site you agree not to provide any sensitive or personally identifiable medical, health, or financial information.

Information We Collect Automatically

As you navigate through and interact with our Site, our servers record standard web server and error log data, including your IP address, the approximate general location it suggests, your operating system and browser type, the resources you access and use on the Site, and the dates and times of your visits. Some of this information, such as your IP address, is treated as personal information under applicable privacy laws.

This information helps us improve our Site, diagnose and repair errors, protect the Site against attacks and abuse, and deliver a better service, including by enabling us to estimate our audience size and usage patterns. We do not use it to build advertising or marketing profiles.

Cookies and Other Technologies

This Site does not use cookies. Galt sets no cookies of its own anywhere on this Site, and because no third-party content is embedded in our pages, no third party sets cookies through this Site either. We use no advertising, analytics, or tracking technologies of any kind. We do not use cookies to advertise to you, to build a profile about you, or to track you across other websites or over time.

No third-party content is loaded into our pages. Browsing this Site therefore does not disclose your IP address or your browsing activity to any third party.

We do not use tag managers, advertising or conversion pixels, web beacons, social media widgets, session-replay or heatmap tools, or device fingerprinting on this Site. This Site loads its images, fonts, scripts, and stylesheets from our own servers rather than from Google or any other third-party domain, and it is not protected by a CAPTCHA service. No part of this Site writes entries to your browser’s local storage or session storage.

You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. Because this Site does not set cookies, changing that setting will not affect any part of this Site.

How We Use Your Information

We use the information we collect about you, or that you provide to us, including any personal information:

• To present our Site and its contents to you, and to provide the information, products, or services you request.
• To secure the Site, to detect and investigate fraud and abuse, and to diagnose and repair errors.
• To comply with our legal and regulatory obligations.
• To fulfill any other purpose for which you provide the information, in any other way we describe when you provide it, or for any other purpose with your consent.

Notice at Collection – Categories of Personal Information

The table below summarizes, using the categories defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), the personal information we have collected through this Site in the preceding twelve months, why we collect it, and who receives it. Retention for every category is described under “How Long We Keep Your Information” below.

We do not collect the other categories of personal information listed in the CCPA — customer records information, protected classification characteristics, commercial information, biometric information, sensory data such as audio or video recordings, professional or employment-related information, education information, or inferences drawn to create a profile about you. We also do not collect, use, or disclose sensitive personal information as that term is defined in the CCPA, so the right to limit the use and disclosure of sensitive personal information does not apply to us. We do not use or disclose any personal information for purposes other than those disclosed in this Privacy Policy.

Disclosure of Your Information

We may disclose aggregated or de-identified information that does not identify any individual, such as the number of visitors to this Site, without restriction.

We may disclose personal information that we collect, or that you provide, as described in this Privacy Policy:

• To our parent company, subsidiaries, and affiliates.
• To contractors, service providers, and other third parties we use to support our business, who are bound by contractual obligations to keep personal information confidential and to use it only for the limited purposes for which we disclose it. This includes the providers that host this Site and supply our IT and email services.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Galt's assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information we hold about our Site's users is among the assets transferred.
• To fulfill the purpose for which you provide it, for any other purpose we disclose when you provide it, or with your consent.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request; to enforce or apply our Terms of Use; or where we believe disclosure is reasonably necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

In the preceding twelve months, we disclosed the categories of personal information listed in the table above to our service providers and affiliates for the business purposes described in this Privacy Policy.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising or targeted advertising. We have not done so in the twelve months preceding the revision date at the top of this page. We also do not disclose personal information collected through this Site to third parties for those third parties' own direct marketing purposes.

Any non-personal communication or material you transmit to the Site by electronic mail or otherwise — including data, questions, comments, or suggestions — is, and will be treated as, non-confidential and non-proprietary, and may be used by the Company for any purpose. This does not apply to personal information, which we handle only as described in this Privacy Policy. Any personal information you provide is provided voluntarily and is not required to access or use this Site.

How Long We Keep Your Information

We keep personal information only for as long as reasonably necessary for the purpose it was collected for, and then delete it or de-identify it. Because this Site collects very little information, we do not apply a single fixed retention period to everything. In deciding how long to keep information, we consider how long we need it in order to respond to you or to complete what you asked us for; any period we are required to keep records for by law or regulation; and whether we still need it to resolve a dispute or enforce our agreements. Web server and error logs are kept only for as long as they are needed for security monitoring and troubleshooting. Where a legal hold or a regulatory obligation requires us to keep information longer, we will do so, and will delete it when that obligation ends.

Your Privacy Rights

Depending on where you live, privacy laws — including the CCPA — may give you rights over the personal information we hold about you. We extend the following rights to all visitors to this Site, regardless of where you live:

• To know. You may ask us to tell you what personal information we have collected about you, the categories of sources it came from, the business purpose for collecting it, the categories of third parties to whom we disclosed it, and the specific pieces of personal information we hold.
• To delete. You may ask us to delete personal information we collected from you. We will do so, and direct our service providers to do so, unless we are required or permitted to keep it — for example, to comply with a legal obligation, to detect security incidents, or to establish or defend legal claims. If we deny a request in whole or in part, we will tell you why.
• To correct. You may ask us to correct inaccurate personal information we hold about you.
• To obtain a copy. Where you ask us what personal information we hold, you may receive it in a readily usable, portable format where technically feasible.
• To opt out of the sale or sharing of your personal information. As stated above, we do not sell or share personal information, so there is nothing to opt out of, and no third party collects information through this Site in order to serve you interest-based advertising. There is no industry-agreed standard for how websites should respond to browser “Do Not Track” signals, and this Site does not currently respond to them. If we ever introduce analytics or advertising technologies to this Site, we will update this Privacy Policy first, and we will treat opt-out preference signals sent by your browser, such as Global Privacy Control, as valid requests to opt out of the sale and sharing of your personal information.
• To limit the use and disclosure of sensitive personal information. We do not collect or process sensitive personal information, so this right does not apply to us.
• To be free from discrimination. We will not deny you goods or services, charge you a different price, or provide a different level or quality of service because you exercised any of these rights. We do not offer financial incentives in exchange for personal information.

How to Submit a Request

To exercise any of these rights, email galtdirect@galtrx.com with “Privacy Rights Request” in the subject line, or call us toll-free at (855)-965-2783. Please tell us which right you wish to exercise and give us enough information to locate any records we may hold about you. If you need this Privacy Policy or a response to your request in an alternative, accessible format, tell us and we will provide one.

How We Verify and Respond

Before we act on a request, we must verify that it comes from you. Because this Site collects so little information, this is usually straightforward: we will ask you to confirm details that match information we already hold, such as the email address you corresponded with us from. We will not ask for more information than is necessary to verify you, and we will use anything you provide for verification only for that purpose. You may also use an authorized agent to submit a request, in which case we will ask the agent for written permission signed by you. We will confirm receipt of your request within 10 business days and respond within 45 days; if we need more time, we will tell you and may take up to an additional 45 days. If we decline to act on your request, we will explain why, and you may appeal by replying to our response.

Data Security

We use commercially reasonable means to protect any personal information you provide. However, the transmission of information via the internet is not completely secure, and we cannot guarantee the security of personal information transmitted to our Site. Any submission of personal information is at your own risk, and we are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page and to update the “Last Revised” date at the top. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Site's home page. We review this Privacy Policy at least once every twelve months. You are responsible for periodically visiting our Site and this Privacy Policy to check for any changes.

Other Terms

Third party websites linked to from this Site may each have different terms of use, privacy policies, and practices. You should review them carefully to determine how each site may use any personal information you provide. This Privacy Policy applies solely to information collected through the Site and not through any other website or source.

In addition to the rights and privileges described in this Privacy Policy or the Terms of Use (hereby incorporated herein), Galt Parties reserve the right to electronically monitor areas of the Site and may disclose any information, content, or records of any kind if required to do so by law, regulation, or government request, or if such disclosure is necessary or appropriate to operate the Site or to protect our rights or property, or the rights of users, partners, affiliates, licensors, or other third parties.

You expressly agree that the exclusive jurisdiction for any dispute with Galt Parties, or in any way relating to your use of the Site, shall be the courts in Cobb County in the State of Georgia, and you expressly consent to the exercise of personal jurisdiction there. This Privacy Policy shall be construed under and governed by the laws of the State of Georgia, without respect to its conflict of laws principles. Nothing in this paragraph limits any right you have under applicable privacy law, or your ability to submit a complaint to a regulator. If any provision of this Privacy Policy is found unenforceable by a court of competent jurisdiction, the invalidity of that provision shall not affect the validity of the remaining provisions, and no waiver of any term or condition shall be deemed a further or continuing waiver of that or any other term or condition. This Privacy Policy and the Terms of Use for this Site constitute the entire agreement between you and Galt with respect to the use of the Site.

Contact Us

If you have any questions or comments regarding this Privacy Policy or our privacy practices, or to submit a privacy rights request, please contact Galt Pharmaceuticals, LLC by emailing galtdirect@galtrx.com or by calling (855)-965-2783.