Alto Neuroscience, Inc.

Privacy Policy

This Privacy Policy (“Policy”) describes the privacy practices of Alto Neuroscience, Inc. and its subsidiaries (“Alto”, “we”, “us” or “our”) with respect to personal information that we collect in connection with the website maintained by Alto at www.altoneuroscience.com, including investors.altoneuroscience.com (“Website”), and any other websites, platforms or apps maintained by Alto (collectively, the “Services”).

This Policy does not apply to Alto’s clinical trials, including our mental health research registry and  information collected in connection with Informed Consent forms, and the term “Services” should not be  interpreted to refer to any such clinical trial(s). If you are interested in one of our clinical trials, you will be  asked to sign an Informed Consent form and provide certain additional information. We do not use your  personal information to assess your eligibility for, or other purposes related to, a clinical trial unless and  until we first obtain approval through an Informed Consent form. In addition, this Policy does not apply to  personal information that we collect from Alto employees, contractors or job candidates. Such information  may be subject to separate privacy policies. For example, you may find the privacy policy for Alto job  candidates here. 
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Protecting the privacy and security of your personal information is important to Alto. This Policy is designed to help you understand what personal information Alto may collect when you use the Service and how Alto uses and discloses that personal information. We may change this Policy at any time by updating it on our Website. The revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Website, by email, or other communication.

1. Personal Information We Collect

When you use the Services, you may provide certain personal information to us. For example, you may  provide us with certain personal information via the Website, such as your name and email address, to  receive updates from us.

In addition to the above, as you use the Services, we may collect certain passive information, including  internet protocol addresses, cookies, navigational data, the name of the domain and host from which you  access the Internet, the browser software you use and your operating system, the date and time you  access the Services, and the Internet address of the website from which you linked directly to the Services.

We may also collect personal information if we conduct or sponsor surveys, business or marketing events,  and when you contact us via e-mail for information or assistance. In these instances, we may ask you for  your name, email address, phone number, state of residence and/or mailing address.

We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our  third-party partners, such as analytics and advertising partners, may use these technologies to collect  information about your online activities over time and across different services. Cookies are small text  files containing a string of alphanumeric characters. We may use both session cookies and persistent  cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you  close your browser and may be used by your browser on subsequent visits to our Services. Please review  your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the  Service to their fullest potential.

2. Use of Personal Information

We may use the personal information we collect in the following ways:

• To communicate with you, provide you with updates and other information relating to our Services, provide you information that you may request, respond to comments and questions and otherwise provide support.

• To provide, maintain, improve and enhance our Services.

• To personalize your experience on our Services such as by providing tailored content and recommendations.

• To find and prevent fraud and abuse, and respond to trust and safety issues that may arise.

• To measure interest in our Services and business, perform internal quality control, and send communications regarding the Services and our business.

• To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for public health, research, and analytics.

• For compliance purposes, including enforcing our terms of service and legal rights or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.

• For other purposes disclosed to you at the time you provide personal information or with your consent.

3. Disclosure of Personal Information

We disclose the personal information we collect in the following ways:

‍Vendors and Service Providers
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We may disclose personal information we receive to our vendors and service providers retained in  connection with the provision of our Services.
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‍Marketing
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‍We do not rent, sell, or share personal information with non-affiliated companies for their own direct  marketing purposes, unless we have your permission.

‍Analytics Partners

‍Alto may also use Google Analytics or other analytics services to collect and process information regarding visitor behaviour and visitor demographics on our Services and to develop the Services. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our Services here: https://tools.google.com/dlpage/gaoptout?hl=en.

‍Advertising Partners

‍We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

‍As Required By Law and Similar Disclosures

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

‍Merger, Sale, or Other Asset Transfers
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We may transfer your personal information to service providers, advisors, potential transactional  partners, or their third parties in connection with the consideration, negotiation, or completion of a  corporate transaction in which we are acquired by or merged with another company or we sell, liquidate,  or transfer all or a portion of our assets. The use of your information following any of these events will be  governed by the provisions of this Policy in effect at the time the applicable information was collected.

‍Consent

‍We may also disclose your personal information with your permission.

4. Users outside of the United States

Alto is based in the United States of America (US). The Services are directed towards users who reside in  the US. If you are outside of the US, by submitting personal information to us, you are consenting to the  collection, storage and processing of that information in accordance with this Policy.

5. Security

Alto is committed to protecting the security of your personal information and we have implemented  security measures designed to protect your personal information that we collect. While we have  implemented security measures, please keep in mind that perfect security does not exist and no storage  or transmission of information is guaranteed to be completely secure.

6. User Choices and Changing Your Information 

While we do not yet meet the thresholds to be subject to US state comprehensive consumer privacy laws  (e.g., the California Consumer Privacy Act), we may provide you with certain choices with respect to your  personal information as a courtesy to you. If you decide that you do not want your personal information  used for the purposes described in this Policy, you may contact us (see the Contact Us section below) to  request removal of your personal information from our database. You may also contact us to correct or update any personal information you have provided us. You may also “opt-out” of receiving e-mails and  other communications from us by using the unsubscribe feature that may be included in the e-mails we  send or by contacting us. Even if you opt out of receiving promotional messages from us, you may  continue to receive administrative messages from us.

7. Minors

Alto does not intend, and the Services are not designed to, attract or collect any personal information  from or about children under the age of 18. If you are a parent or guardian of a child whom you believe  may have provided personal information to us, please contact us (see the Contact Us section below).

8. Third Party Websites

The Services may include hyperlinks to websites or other content maintained or controlled by others. Alto  is not responsible for such websites or other content and this Policy does not apply to such websites or  their content.

9. Contact Us

Alto Neuroscience, Inc.
650 Castro Street
Suite 450
Mountain View, CA 94041
privacy@altoneuroscience.com