Privacy Policy

Last Updated Feb 5, 2026

  1. Introduction. This privacy policy (the “Policy”) intends to inform users of this website (www.aurionclinicaltrials.com) and other websites that we operate and that link to this Policy (collectively, the “Site”), participants in our clinical research trials (each a “Trial”) or other studies, and other customers, patients, subscribers, and individuals with whom we interact and from whom we collect personal information, about how Aurion Biotech, Inc. (“Aurion”) collects, uses, and/or shares personal information in connection with the services that we provide. Aurion takes individual privacy seriously and we endeavor to inform you of the uses that we have for information that we obtain from you (collectively, “Personal Information”). We will take reasonable commercial steps to protect your privacy consistent with the guidelines set forth in this Policy and with applicable federal and state laws. In this Policy, “user,” “your,” or “you” refers to any individual from whom we obtain Personal Information, whether by browsing our Site, submitting any request to us (including through our Site), creating any account with us, participating in any Trial or other activities or services that we offer, or otherwise engaging with or requesting services from us. As the manners in which we obtain Personal Information and our uses for Personal Information may change, we encourage you to return to and reread this Policy from time to time. By accessing or using our Site, participating in any of our Trials, or otherwise engaging or requesting services from us, you acknowledge that you have read, understand, and agree to be bound by this Policy. If you do not agree to the terms of this Policy, do not use our Site.
  2. What Information Do We Collect? We may collect two types of Personal Information from you: (i) Individualized Information, and (ii) Device Information:
    • Individualized Information. We may collect certain Individualized Information from you when you use our Site; submit any request for information, press or media inquiry, or job application to us (including through our Site); request information about, enroll in, or participate in any Trial that we manage or sponsor; purchase any service from us or request that we provide any service; or otherwise interact or engage with Aurion. Depending on the circumstances, this “Individualized Information” may include: your first and last name, email address, telephone number, postal address, zip code, education or work history or background, preferences for receiving marketing communications or newsletters, or other information related to your individual interest in or need for Aurion’s services. If we obtain your Individualized Information from other sources, we may add it to the Individualized Information that we have already collected from you in order to improve our Site, Trials, or other services to the extent permitted by applicable law.
    • Device Information. We may collect certain web tracking information about the device that you use to connect to and browse our Site. Depending on the circumstances, this “Device Information” may include, but is not limited to: information about your computer’s or mobile device’s operating system type and version or manufacturer and model; screen resolution; RAM and disk size; CPU usage; web browser (e.g., browser type, domain names, access times, and operating system); Internet protocol (“IP”) address; individual web pages you have viewed; web pages or search terms that referred you to our Site; how you interact with or how much time you spend viewing our Site or our marketing communications or newsletters; your time zone; or information about the cookies installed on your device. As described in Section 3, we may use cookies and navigational data like Uniform Resource Locators (“URLs”) to gather information regarding the date and time of your visit and the information for which you searched and viewed.
  3. Cookies.
    • Automatic Data Collection Tools. A cookie is a small file containing a string of characters that is sent to your browser when you visit a website. When you visit the website again, the cookie allows the website to recognize your browser. Cookies also may store user preferences and other information. Cookies offer a form of convenience in that they save the user time by allowing the website to identify preferences that the user has displayed or selected in the past. Similarly, local storage technologies, e.g., HTML5, provide cookie-equivalent functionality but may have the ability to store larger amounts of data; and web beacons (sometimes known as pixel tags or clear GIFs) are sometimes used to demonstrate that a website or email was accessed or opened or that certain content was viewed or clicked. Aurion uses cookies, local storage technologies, and web beacons, and we refer to these tools collectively as “cookies” in this Policy.
    • Why Does Aurion Use Cookies? Aurion may use cookies from time to time for several reasons. Some cookies are required for technical reasons for our Site to operate. Other cookies enable us to track and target the interests of users to enhance their experience on our Site. For example, depending on the circumstances, Aurion may use cookies to collect data regarding the specific pages you visit on our Site. This data is used to determine which pages are most helpful to you or popular to our users in general, and to deliver customized content on our Site to customers whose behavior indicates that they are interested in a particular subject area.
    • What Types of Cookies are Used on our Site? The specific types of cookies utilized through our Site include:
      • Essential Cookies. Required to enable basic Site functionality. They cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
      • Functionality Cookies. Allow our Site to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced and more personal features.
      • Analytics Cookies. Help us understand how our Site performs, how visitors interact with our Site, and whether there may be technical issues. This storage type usually doesn’t collect information that directly identifies a visitor.
      • Advertising Cookies. Deliver advertisements that are more relevant to you and your interests and to track your behavior across different websites. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited our Site and this information is shared with other organizations such as advertisers. However, advertising cookies are not included or used on sections of our Site that are dedicated to any Trial (including inquiries about a Trial).
    • How Can You Control Cookies? You can decide whether to accept, block, or reject cookies. You can generally select to accept, block, or reject cookies through your own browser controls, and you should visit your browser’s help menu for instructions on how to do so and additional information. Aurion is not responsible for making this selection for you. If you choose to reject cookies, you may still use our Site, but your access to some functionality and areas of our Site may be restricted. For more information on how cookies work and how to control them, you may visit www.allaboutcookies.org.
  4. How Do We Use Your Information?
    • Use of Personal Information. We may use Personal Information for a variety of purposes including, but not limited to: operating and maintaining our Site; providing, managing, or communicating with you regarding our Trials or services (including responding to any inquiry or service order you have initiated); assisting you to find a healthcare provider; establishing and maintaining customer, patient, or Trial participant accounts; providing customer service and updates regarding our services; processing orders and transactions (including payments); verifying customer, patient, or Trial participant information; detecting security incidents that may compromise the confidentiality of Personal Information in our possession; maintaining or improving the quality or safety of our Trials or other services; processing job applications; or enforcing our legal rights or as required by applicable law or requested by any judicial process or government agency.
    • Use of Device Information. We may also specifically use Device Information for a variety of purposes including, but not limited to: helping us screen for and prevent potential risk and fraud (in particular, through any IP address we collect from you); diagnosing and mitigating Site errors; administering and optimizing our Site; making our services more useful to you; generating analytics about how our customers browse and interact with our Site; assessing the success of any marketing or advertising campaigns; or storing user preferences. Using Device Information for these purposes allows us to determine which Site features users like best and generally helps us improve and secure our Site and personalize each user’s experience.
    • Minimum Amount Necessary. Aurion (including our individual staff members) will not use your Personal Information beyond the minimum amount and scope necessary to achieve the above purposes without first obtaining your consent.
    • License to Use Your Content. Please note that you grant us a license to use, reproduce, publish, distribute, and otherwise exploit in any manner any questions, feedback, messages, or inquiries you send us, files you upload, data you input, or other information you include in any communications through the Site (collectively, “Your Content”). This license to Your Content is granted to us without restriction and without the requirement that we compensate you in any way. We are under no obligation to maintain any of Your Content in confidence, or to provide you with any response or confirmation of receipt regarding Your Content. Notwithstanding the foregoing, Your Content generally shall not include, and the license described in this Section 4.4 generally shall not apply to, any information that you submit to or share with us, or any of our Contractors, in connection with a Trial (including any inquiry about a Trial).
    • Aggregated Data. To the extent permitted under applicable law, we may also create statistical, de-identified, anonymized, or aggregated data (collectively, “Aggregated Data”) relating to our Site users, customers, patients, or Trial participants, and use such data for analytical, Trials or other research, or any other legal purposes (whether related to our business or otherwise). Aggregated Data generally means data derived from Personal Information and data collected by Aurion from other sources that has been anonymized so that it does not relate to and could not reasonably be used to identify any individual.
    • Marketing Communications. If you provide us with your email address or telephone number or otherwise sign up for our marketing communications, we may in the future begin to send you marketing communications, including newsletters, via email or text message. If you wish to opt out of these marketing communications, you may do so by following the “unsubscribe” instructions in the email or text message or contacting us as provided in the “Contact” section below.
  5. What Information Do We Share or Disclose?
    • Disclosure of Personal Information. We generally will not share or disclose Personal Information with any third-parties, except in accordance with applicable law under the following circumstances:
      • When you have consented to us sharing or disclosing your Personal Information.
      • When the Personal Information is shared with or disclosed to a parent company, subsidiary, joint venture, or other entity under common control with us to achieve any of the purposes described in Section 4.
      • Subject to the terms of a confidentiality agreement, in connection with, and for the purposes of, a business deal (or negotiation of a business deal) involving the sale or transfer of all or a part of our business or assets. These deals may include any merger, financing, acquisition, or bankruptcy proceeding.
      • With a third-party contractor engaged to provide management, administrative, or support services on our behalf (a “Contractor”), which require the Contractor to have access to Personal Information. In this instance, we enter into an agreement with the Contractor limiting their use of the Personal Information to the minimum amount necessary to perform the services for which we have engaged them; requiring the Contractor to report any suspected or actual breach of security or other incident related to the Personal Information to us; and requiring the Contractor to adhere to the same level of privacy requirements that are required of us by all applicable law. By accessing or using our Site, participating in any of our Trials, or otherwise engaging or requesting services from us, you consent to our sharing your Personal Information with any Contractors and to the Contractors’ use of your Personal Information in accordance with all applicable law, this Policy, and the other terms and conditions applicable to our Site.
      • If you submit an inquiry regarding or enroll in a Trial, we may specifically share your Personal Information with our Contractors (as described in Section 5.1.4) who are engaged to assist with the management or administration of the Trial, or with healthcare providers or other third-parties who are tasked with treating you, reviewing your personal or health data, or otherwise providing services to you in connection with the Trial.
      • To detect, prevent, or otherwise address security, fraud, or technical issues.
      • To ensure the personal safety of any individual, including our staff members or job applicants and members of the public.
      • To the extent required to comply with legal obligations, processes, or requests; enforce our policies, contracts, and agreements (including this Policy); or protect or defend our legal rights.
    • Aggregated Data. To the extent permitted by applicable law, we may in our sole discretion disclose any Aggregated Data that does not contain Personal Information to any third-parties for any legal purpose.
    • Network Operators. Use of our Site may involve the use of third-party search engine operators or telecommunications carriers. These operators are not our Contractors, and any information that these operators collect in connection with your use of our Site is not a part of our collected Personal Information and is not subject to this Policy. We are not responsible for the acts or omissions of these operators.
  6. Your Rights Regarding Your Information.
    • Privacy Settings / Right to Remove. If you would like your Personal Information to be permanently removed from our database, please contact us as provided in the “Contact” section below. We may ask you to provide a copy of your driver’s license or other identifying documents to assist us in processing your request. Aurion may still contact users who have requested that their Personal Information be permanently removed for administrative purposes. The removal of your Personal Information may take some time to complete and may be subject to certain restrictions, consistent with applicable law. Please also note that the removal of any Personal Information will not necessarily result in the removal of records of past transactions or the deletion of information stored in our data archives. Aggregated Data is not subject to requests for removal.
    • Access / Updates. Aurion will, to the best of our ability and in accordance with applicable law, allow you to access, review, correct, or add to your Personal Information held in our database. To make any such request, please contact us as provided in the “Contact” section below. We will make our best efforts to process your request promptly once we receive it. Please note that we may ask you certain follow-up questions prior to processing your request to confirm your identity and the specific Personal Information that is the subject of your request, in accordance with applicable law.
  7. Additional Policies.
    • Security. To the extent required by applicable law, Aurion will utilize appropriate, commercially reasonable physical, electronic, and managerial procedures and security precautions to protect Personal Information against unauthorized access, deletion, loss, alteration, or misuse. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. We are not responsible for the actions of hackers and other unauthorized third-parties that breach our reasonable security procedures. Additionally, to the extent that your use of our Site, participation in any of our Trials, or use of any of our services requires you to create an account and password, you are solely responsible for maintaining the secrecy of this login information. This Policy is not intended to confer, nor does it confer, any rights or remedies to users.
    • Third-Party Activity. Our Site or other materials that we make available to you may contain links to other websites, cookies, or other materials from, or which may be operated by, third-party entities. The information practices and privacy policies of these third-party entities may be different than those of Aurion. We are not responsible for any actions or omissions by any such third-party entities. This Policy applies only to Personal Information collected by Aurion.
    • Data Retention. Unless you ask us to delete your Personal Information sooner, we will maintain it until such time that we determine, in our sole discretion, that: (i) it is no longer necessary for any purpose for which Aurion may use it in accordance with this Policy; and (ii) it may be destroyed or deleted in accordance with applicable law.
    • Accessibility. Any person with a disability that prevents or restricts them from accessing this Policy through Aurion’s website may request a copy in an alternative format by contacting us as provided in the “Contact” section below.
    • Children. Aurion does not knowingly collect or maintain Personal Information from persons under 18 years of age, and no part of our Site is directed at persons under 18. Please do not use our Site if you are under 18. If Aurion learns that Personal Information of persons under 18 has been collected without verifiable parental consent, Aurion will delete the Personal Information.
    • Website Visitors from Outside the United States. Aurion and its servers are located and operate in the United States, subject to the applicable state and federal laws of the United States. Those who choose to engage with us do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. We may limit our Site’s or our services’ availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that our Site or services are appropriate or available for use in any other jurisdiction. If you choose to access or use our Site or our services, you consent to the use and disclosure of information in accordance with this Policy and subject to all applicable laws.
    • Amendments. Aurion will review this Policy from time to time and may modify or amend it as necessary to comply with applicable law. We may also update the Policy to reflect changes to our practices or for other operational reasons. If we make any material changes to how Personal Information is collected, used, disclosed, or transferred, we will notify you of these changes by modifying the version of this Policy that is available for your review on our Site. Accordingly, we encourage you to review this Policy from time to time. Notwithstanding any modifications we may make, all Personal Information will be treated in accordance with the version of the Policy that is/was in effect at the time the Personal Information was collected, unless we obtain your consent otherwise.
  8. Notice for Residents of European Economic Area, United Kingdom, or Switzerland.
    • No Marketing to Such Residents. We do not market our Site or our services to residents of Europe, the United Kingdom (UK), or Switzerland, and are not subject to Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Information and free movement of Personal Information, known as the General Data Protection Regulation, or the similar laws of the UK and Switzerland (collectively, “GDPR”). If you reside in the European Economic Area (“EEA”), UK, or Switzerland, please be aware that if you voluntarily provide us with any Personal Information, that information will be transferred from your location to data centers located in the United States for processing, and this transfer will be deemed to have been made with your consent.
    • Rights Honored. Although we are not subject to the GDPR, we will generally make commercially reasonable efforts to honor your data privacy rights upon request, subject to certain limitations. If you reside in the EEA, UK, or Switzerland, you have the rights, as applicable under the GDPR, to:
      • Request an accounting of Personal Information that we possess that pertains to you in an electronically portable format.
      • Request that we correct or update Personal Information that pertains to you.
      • Request that we delete Personal Information that pertains to you.
      • Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.
    • Requests and Complaints. Please contact us as provided in the “Contact” section below to request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information. We will make our best efforts to process your request promptly once we receive it unless there are legitimate grounds for further processing the Personal Information that override your interests, rights, and freedoms, or unless we further process the Personal Information only for the establishment, exercise, or defense of legal claims. If you believe we are unlawfully possessing, using, or disclosing your Personal Information, you have the right to complain to your local data protection supervisory authority. You can find contact details here: https://edpb.europa.eu/about-edpb/board/members_en.
  9. Contact. Please contact us by email at [email protected] if you have any questions for us, wish to submit a complaint about how we have processed any Personal Information, or would like to contact us for any other reasons. We will deal with any complaints or requests as soon as possible, and without prejudice to you. If you submit a complaint to us, you may of course also file any complaint with a relevant government agency in the state or jurisdiction in which you live or work.

AURN001 is investigational and not approved by the FDA. Participation is voluntary, and you may leave the study at any time. Declining to participate will not affect your standard medical care.