PRIVACY POLICY

Effective date: March 6, 2026
Last updated: February 17, 2026

This privacy policy describes the personal data that we, Braeburn Inc. (“Braeburn”, “we”, “us”, or “our”) collect about you, why we collect it, how we use it, and when we disclose it with third parties or service providers.

This privacy policy covers our websites (including braeburnrx.com, brixadi.com., brixadihcp.com), any mobile or desktop application, our associated services, and any other future platforms or offerings that we may develop where this Privacy Policy is made available (collectively, the “Site”).

This Privacy Policy is incorporated into and is subject to the Braeburn Terms of Use. Your use of the Site and any personal data you provide on the Site is subject to the terms of this Privacy Policy and the Braeburn Terms of Use.

This Privacy Policy applies to personal data and does not apply to information that may be regulated by a different legal framework, such as information collected in the context of a clinical trial or that is governed by the Health Insurance Portability and Accountability Act (“HIPAA”). To the extent that we process deidentified data, we will maintain and use the data in deidentified form and will not attempt to reidentify the data unless permitted by applicable law. Deidentified data that remains deidentified is not personal data and we may use such data for any lawful purpose. Deidentified data that is reidentified and otherwise qualifies as personal data is subject to this Privacy Policy.

What personal data do we collect about you?

We collect the below categories of personal data from you when you access the Site:

  • Contact and Account Information: Name, email address, postal address, and phone number. If we provide an option to create an account with us, we also collect demographic information that we request at sign-up (such as your age or gender), in addition to your account username and password.
  • Website Activity: We collect information related to your access to and use of our Site, including the type of browser you use, access times, pages viewed, your IP address, and the page you viewed before and after visiting our Site. We may also collect this type of information in visual form when you visit our Site, including video snippets of your Site activity.
  • Device Information: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Health Related Information: We collect information that may relate to your health in the context of our regulatory responsibilities under the Federal Food, Drug, & Cosmetic Act (such as adverse event and product complaint reporting), health-related data that you disclose to us offline and online, such as through our consumer-facing websites like brixadi.com, communications channels, or otherwise through the Site.
  • Geolocation Information: We may collect the approximate location of your device from your IP address.
  • Commercial Information: Information about your product and service preferences and interests, including our products and services.
  • Social Media Information: Account names, handles, biographies, and other details that you make available on social media networks.
  • Other information that you may provide to us or that we may infer based on the above.

How do we collect personal data?

We collect personal data directly from you in the below contexts. We also collect personal data from you using sources like advertising or marketing networks, data analytics providers, social media platforms, data brokers, and other service providers or third parties.

  • If you register an account with us or otherwise access the Site
  • In connection with your interactions, inquiries, or other requests
  • If you upload or share a photo or other digital content through our Site, or share content linking to any of our social media accounts
  • If you participate in a contest, promotion, or survey
  • If you contact us via e-mail or through our customer service, including through the use of online chat tools that we may make available
  • We and our third-party vendors may use tracking tools like browser cookies, flash cookies, pixels, and web beacons to collect information from you. Please see “How do we use cookies and other tracking technologies?” for more information.

How do we use your personal data?

We may use your personal data in the following ways:

  • To provide, operate, maintain, and protect our Site;
  • To analyze and improve our Site, including developing new products or services;
  • To communicate with you, respond to your inquiries, and to send you information by email, postal mail, telephone, text message, notifications, or other means about our products and services;
  • To promote and conduct educational or promotional events, including those that may be in person and to support our marketing and advertising activities, including delivering personalized advertising;
  • To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences across our Site;
  • To protect the security or integrity of the Site, including to perform security analyses to verify that the Site is working properly and has not been compromised based on our legitimate interests;
  • To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts, including any agreements between you and us, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our customers is among the assets transferred.

How do we disclose your personal data?

We disclose your personal data to the following categories of parties:

  • Service providers: We engage vendors and consultants to assist with and perform certain functions on our behalf such as: auditing and accounting firms, professional services consultants, providers of data hosting, storage, and analytics services, and IT and security vendors.
  • Social media platforms: We use social networking services such as Twitter, LinkedIn, Facebook, and YouTube to communicate with the public about our work.  Where you choose to interact with us through social media, your interaction with these platforms typically allows the social media company to collect some information about you through cookies and other digital tracking mechanisms that they place on your device. In some cases, the social media company may recognize you through these technologies even when you do not interact with their platform. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.
  • Companies involved in advertising: We work with companies that assist us in advertising our Site to you and others who may be interested in the Site. These companies may use tracking technologies on our Site to collect or receive information over time and across different websites or platforms, including on this Site and elsewhere on the internet, and use that information to provide measurement services and provide you with targeted ads.
  • Corporate affiliates: We share personal data with our subsidiary companies.
  • Business partners: We may work with other companies to provide you with certain product or service offerings.
  • Law enforcement, government agencies, or parties in a legal proceeding: We may share your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, fight fraud, collect a debt, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers (e.g. lawyers, auditors, accountants), law enforcement, judicial, and regulatory authorities.
  • Third parties in the context of a merger or similar business transaction.

How do we use cookies and other tracking technologies?

We and our third-party vendors use cookies, pixel tags, and other tracking technologies on the Site in a variety of ways to enhance or personalize your online browsing experience. These tracking technologies help us better understand your needs and preferences and tell us which parts of our Site you have visited, facilitate and measure the effectiveness of our advertisements, and provide consistent and personalized services and experiences. These tracking technologies gather information over time and across different websites about you, some of which may be personal data as identified above in “What personal data do we collect about you”.

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. If you do not accept cookies, however, you may not be able to access your account information or utilize certain functionalities on our Site. Please note that our Site does not currently recognize “Do Not Track” signals. However, our Site may recognize certain opt-out preference signals, such as the Global Privacy Control, and will process such signals in accordance with applicable law, potentially including “do not sell”, “do not share”, “limit the use or disclosure of sensitive personal information,” and opt out of targeted advertising requests. You may set such a signal through your browser or browser extension.

Third-Party Links

Third-party links on the Site may direct you to third-party websites that are not affiliated with us, including social media platforms. We are not responsible for the content or accuracy of third-party websites, or for any other materials, products, or services of third parties.

We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third party’s policies and practices and make sure you understand them before you access their website. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third party.

How do you protect my personal data?

We maintain reasonable physical, electronic, and procedural safeguards designed to help us protect your information against: (a) accidental or unlawful destruction; (b) accidental loss; and (c) unauthorized alteration, disclosure, or access. However, no security systems are impenetrable. We cannot guarantee the security of our database, Site, or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet. We are not responsible for the actions of third parties.

Do we collect children’s information?

We will never knowingly request personal data from anyone under the age of 18. Our Site is not targeted to or intended for use by children. However, if we learn that we have received personal data from a child under the age of 18 without appropriate parental consent, we will delete that information from our database.

How long do we keep your personal data?

We will retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was obtained, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation and we believe the personal data is relevant.

To determine the appropriate retention period for personal data we consider: the necessity to retain the personal data; the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data; whether we can achieve these purposes through other means; and the applicable legal, regulatory, tax, accounting or other similar requirements.

What choices do I have about my personal data?

You can review and change certain personal data related to your use of the Site (such as your name and contact information) by signing into your account or by contacting us as described in the section entitled, “How to contact us?” below.

If you prefer not to receive promotional communications from us, such as information about special offers, you can let us know by contacting our customer service as described in the section entitled, “How to contact us?” below. You may also follow the instructions included with the message, such as by following unsubscribe or opt out links. Please note that we may still send you messages in response to your inquiries or about other non-promotional items, such as managing your account or relationship with us.

Do I have any rights to my personal data?

You may have the rights listed below (“Data Subject Rights”) with respect to the personal data that we collect or process about you, however, these rights differ depending on your place of residency, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.

  • Right to Confirm Processing, Access, and/or Obtain a Copy (referred to in some places as a Data Subject Access Request): If you ask us, we will confirm whether we are processing your personal data. Additionally, upon request, we will provide you with a copy of all personal data you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
  • Right to Amend: If you believe your personal data is inaccurate or incomplete, you may request that we correct it.
  • Right to Delete: You may request that we delete personal data that we maintain about you.
  • Right of Portability: You may request that we move, copy, or transfer the electronic personal data that we hold about you to another organization.
  • Right to Revoke Consent and/or Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your personal data. This includes general requests and requests in specific contexts, such as if we process personal data that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
  • Right to Limit Use and Disclosure of Sensitive Personal Data: You may ask us to limit the use and disclosure of sensitive personal data.
  • Right to Opt Out of Targeted Advertising or “Sharing”: Targeted advertising is the practice of serving you tailored advertisements based your personal data gathered over time and across other businesses, websites, applications, or services. Some jurisdictions may refer to this activity as “sharing.” You have the right to opt out of this practice.
  • Right to Opt Out of Sales: Some jurisdictions may consider targeted advertising a “sale” of personal data. You may request that we not “sell” your personal data.
  • Right to Non-Discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your personal data.
  • Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination.
  • Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the country or state in which you live if you have any concerns about our processing of your personal data or if we deny your appeal to review a prior decision about your Data Subject Rights.

If you or your authorized agent would like to exercise a Data Subject Right, you may do so by following the instructions in “How to contact us?” below. Please note that you may also login to your account to access and correct your account information at any time.

In order to process your request to exercise a Data Subject Right, we will ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as most recent interaction with us, if applicable.

If you exercise your right to appeal our determination with respect to your Data Subject Rights, and we deny your appeal, you may have the right to submit a complaint to your regulator. Information for your relevant regulator may be found below:

Additional Disclosures for California Residents

If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act (or “CCPA”) (California Civil Code Section 1798.100 et seq.).

  • Categories of Personal Information Collected: In the previous 12 months, we have collected the personal information listed in the section “What personal data do we collect about you?” above. This information falls into the following categories under the CCPA: identifiers; categories of personal information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories. Additionally, we collect the following “sensitive” personal information: precise geolocation, account credentials, and contents of messages that you send to our customer service providers.
  • Sensitive Personal Information Uses or Disclosures: The data that we capture about your interactions with some of our health-related websites, like brixadi.com, may be considered “sensitive” personal information. We use this interaction data to support cross-context behavioral advertising. You may request that we limit this use of our “sensitive” personal information by following the instructions at the end of this Privacy Policy.
  • Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in “What personal data do we collect about you?” and “How do we use your personal data?” above.
  • Categories of Sources of Personal Information: We collect personal information from and about you as described in “How do we collect personal data about you?” above.
  • Categories of Third Parties with Whom We Disclose Information: We may disclose your personal information with third parties as described in “How do we disclose your personal data?” above.
  • Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information listed in “What personal data do we collect about you?” for the reasons described in “How do we disclose your personal data?” above.
  • Sale or Share of Personal Information: Because we engage in the practice of cross context behavioral advertising, also known as online targeted advertising, we may “sell” and/or “share” your personal information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, employment or professional information, health information (usage and interaction data with certain health-related webpages like brixadi.com), and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks. We do not have any actual knowledge that we sell or share the personal information of users under the age of 16.

Cross Border Transfers

Braeburn is headquartered in the United States and uses service providers around the world. Please note that the Site is directed towards users who reside in the United States. It is not our intent to gather personal data from individuals residing outside of the United States. If you are located outside of the United States, the information you provide to us will be transferred to the United States whose laws may not provide the same level of protection for personal data as your home country. By using this website, you consent to this transfer. You also consent to the adjudication of any disputes arising in connection with this website in the federal and other courts of, and in accordance with the laws of, the state of Delaware.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Site. Any changes to this Privacy Policy will become effective when we notify you of the changes. Your use of the Site following any such updates will constitute your acceptance of such updates.

How to Contact Us?

For questions about our privacy policy, to make choices about receiving promotional communications, to request to exercise a Data Subject Right, or to update your personal data, you can contact us using the below information. For other inquiries, such as product partnerships or reporting a suspected adverse event or product complaint, please see our specific communication channels listed here.

Phone: 1 (610) 467-8680

Toll-free Phone: 1 (833) 274-9234

Email: info@braeburnrx.com

Address: 450 Plymouth Rd, Suite 400, Plymouth Meeting, PA 19462

If you would like to request to exercise a Data Subject Right, you may also use our webform, available here.

Additional Information for Job Applicants

This section supplements the information provided above and describes the additional personal information we collect when you apply for a job with Braeburn. We may collect the personal information in the below list in the following ways: directly from you; from publicly available sources, such as government entities, public records systems, and social media networks; data analytics providers and data brokers; or as you may otherwise authorize, such as a former employers or references.

Please note if you use our Site in the job application process, additional information is collected, as described above. We may collect the personal information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) in addition to the categories of personal information listed below. Items with an asterisk (*) may be considered “sensitive” personal information according to the CCPA.

For more details about how we use and disclose the personal information listed here, please refer to “How do we use your personal information?” and “How do we disclose your personal information?” above.