Welcome to Mind Medicine Inc. (“MindMed”, “we”, “us” , our )! The MindMed  website exists to provide information on the company, pipeline, and researchto the users (“you”). To provide this service MindMed collects some of your data, when you are using https://mindmed.co/ (“site”), or any MindMed website. This Privacy and Cookies Policy (the “Privacy Policy”) is intended to inform you about MindMed’s practices regarding the collection and use of your data that you may submit to MindMed. Please read the Privacy Policy carefully.

1. This Privacy Policy was last modified on 04 May 2022 and may be updated to reflect changes in legislation, so please review it now and then. You can always find the most recent version on the MindMed website . If substantial changes are made, we will try to provide at least a 30-day notice prior to any changes taking effect. What constitutes a substantial change will be determined at our sole discretion. By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Services.
2. The Privacy Policy only covers data processing carried out by MindMed. The Privacy Policy does not address, and MindMed is  not responsible for, the privacy practices of any other parties.
3. MindMed does not knowingly collect or ask for information from people under the age of 18. If you are such a person, please do not use our service or send us your information. Information that we learn is collected from a person under the age of 18 without verified parental consent is deleted.

 

1. Who is the Controller of your data?

1. 1. Your data are being collected and processed by Mind Medicine Inc. a Delaware corporation ( “MindMed“, “we”, “us” or “our”).
   2. To learn more about data management or if you have any other questions, please contact us at [email protected]

2. What data is processed?

We may collect the following types of information about you:

2.1. Personal Identifiable Information (“PII”)

Through the Services MindMedmay collect and process information that can be used to identify or contact you as an individual known as your PII , including but not limited to:

• name
• email address
• country of residence
• and other PII provided by you voluntarily when you use our Services.

2.2. Technical Information

2.2.1. MindMed and/or our authorised external service providers may automatically collect technical data when you visit or interact with our Services. Technical data may include, in particular:

• the URL of the site visited before using our Service
• the time and date of user visits
• IP address
• the browser name and type
• the type of computer or device accessing our Service
• time spent on the Service  and other similar technical information

In a limited number of cases it is possible to use technical data and identify you as an individual, thus making them PII, however, we never use technical data to identify you as an individual.

2.2.2. MindMed use technical data to:

• Provide, operate, and maintain our Site
• Improve, personalize, and expand our Site
• Understand and analyze how you use our Site
• Develop new products, services, features, and functionality
• Communicate with you, either directly or through one of our partners, including for customer service

3. Cookies

3.1. What are cookies?

3.1.1. To make our Services work correctly, we sometimes place small data files called cookies and similar technologies on your device.

3.1.2. A cookie is a small text file that the Service saves on your device when you visit it. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Permanent cookies last until you or your browser delete them or until they expire.

3.2. How do we use cookies?

3.2.1. We use our session-based and also permanent functional cookies which enable the Site to remember your actions and preferences (e.g., to remember that you are logged in) so you don’t have to keep re-entering them whenever you come back to the Site or browse from one page to another.

3.2.2. We also use cookies for analytics purposes to personalise your experience and to improve our Services.

3.3. Which cookies do we use? 

3.3.1. We use the following cookies:

• • • _ga: The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.This cookie lasts for 2 years.
    • _gid_: The _gid cookie stores information on how visitors use a website, while also creating an analytics report of the Site’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. This cookie lasst for 1 day.
    • _gat_gtag_UA_159451690_1: This cookie is set by Google to distinguish users and lasts for 1 minute.
    • XSRF-TOKEN: This cookie is set by Wix and is used for security purposes. It lasts for 1 year.

3.4. How can you control cookies?

3.4.1 MindMed informs you about the use of cookies on your device when you visit our Site for the first time and, if applicable, we ask for your consent to use the cookies. The cookies will not be used for any purposes other than the ones stated above. Later, you may choose to accept or refuse cookies by selecting the appropriate settings in your browser.

3.4.2. As mentioned above, in some cases MindMed also may use cookies provided by third-parties (service providers). The list of such third-parties cookies of which you might encounter through our service is listed below. We are not responsible for third-party sites and their privacy practices. These companies collect and use this information under their own privacy policies and are responsible for their practices concerning cookies.

4. What are the purposes and legal basis for processing your PII?

4.1. MindMed process your PII in order to:

4.1.1. Provide our services to you 

This purpose includes mainly the following processing activities:

• informing you about updates and new features of our Service;
• notifying you about updates of our terms & conditions of thisPrivacy Policy;
• responding to you in relation to any queries you may have with respect to our Services;

We process the email address, payment information and other data provided by you voluntarily when you use our Service.

4.1.2. Market our services

MindMed may market our current or future Services if you subscribe to our newsletter on our Site and by doing so, you provide us your consent with the processing of your email address for the marketing purposes.

There are several ways you can stop direct marketing communications from us:

• click the “Unsubscribe from newsletter” link in any email communication that we send you. We will then stop any further newsletter emails; or
• withdraw your consent through [email protected]

4.1.3. Improve our services 

This purpose includes the following processing activities using technical information:

• to influence current and future features;
• to prevent and detect security flaws and user interface issues.

4.1.4. Process an application as part of MindMed’s recruitment

During our application process we may collect and process PII including, but not limited to, the applicant’s:

• names
• photograph
• contact details
• professional background
• or any other PII contained in their CV

We also may be required to carry out a background check through a third party after notifying the applicant.

5. Who are recipients of your PII?

5.1. MindMed does not share your PII with any recipients outside of MindMed unless one of the following circumstances applies:

5.1.1. It is necessary for the compliance with our obligations towards you

To the extent that our external service providers (sub-processors) need access to your PII to help us perform our Services for you, we have taken the appropriate contractual and organisational measures to ensure that your PII are processed in accordance with all applicable laws and regulations.

Below is a non-exclusive list of our sub-processors:

[ LIST OF SUB-PROCESSORS IF APPLICABLE ]

• Greenhouse Software Inc. (U.S.)
• Intuit Inc. (U.S.)
• MailChimp (U.S.)

The list of external service providers we use may change from time to time as we change or remove some of the providers listed above and/or put in place other providers to assist us in providing the Services.

5.1.2. It is necessary for legal reasons

MindMed may share your PII with recipients outside of MindMed if we have a good-faith belief that access to and use of your PII is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of MindMed, our users or the public as far as in accordance with the law. When possible, we will inform you about such processing.

6. Where do we transfer your data to?

6.1. MindMed’s Services are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. If you use our Services, or otherwise provide us with your PII , from outside the United States, you acknowledge and agree that your PII may be transmitted outside your resident jurisdiction. In particular, please note that your PII is stored and processed in the United States.

6.2. If we are involved in a merger, acquisition or other reorganisation, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

7. What is the storage period?

7.1. MindMed stores your PII only if it is legally permitted and necessary for the purposes for which the data were collected, or we are legally obliged to do so.

8. California Consumer Privacy Act Notice

8.1. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your PII to third parties for their direct marketing purposes. Moreover, you have the right to restrict the sharing of your PII and with our affiliates (companies we own or control) and outside companies with whom we do business.

8.2. MindMed is aware of your rights afforded to California residents under the California Consumer Privacy Act (the “CCPA”). Even though the CCPA does not apply to us now, we are ready to protect your PII and give you an option to exercise your right under CCPA once it becomes applicable.

8.3. To contact us with questions about our rights under California privacy laws email us at [email protected]

9. What are your rights?

9.1. Right of access – MindMed offers you access to your PII we process. This means you can contact us and request from us a confirmation whether or not your PII are being processed and if so, you have the right to request access to your data, which we will provide to you in the form of a so-called “registry” (stating, in particular, purposes, categories of PII, categories of recipients of PII, storage periods or criteria for determining storage periods).

9.2. Right to erasure – You may also ask us to erase your PII from our systems. We will comply with such requests unless we have a legitimate ground to not delete your PII.

9.3. Right to restriction of processing -You may request us to restrict certain processing of your PII. If you restrict certain processing of your PII, this may lead to fewer possibilities to use our Services and Site.

9.4. How to use your rights -You may exercise your rights above, free of charge, in writing by sending a letter or email at  [email protected] . We may require confirmation of your identity depending on your request.

10. Is your data secured?

10.1. MindMed takes all reasonable, appropriate security measures to protect our customers from unauthorised access to or unauthorised alteration, disclosure or destruction of PII we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should, despite the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible. If you have any questions, feel free to contact us at  [email protected].