Privacy Policy

Last Updated: October 7, 2025

SCOPE

This Privacy Policy is designed to help you understand how Alpha Cognition, Inc., and its parents, subsidiaries, and affiliates (collectively, “ACI,” “we,” “us,” or “our”), collect, use, process, and share your personal information in conjunction with our Services.

This Privacy Policy applies to personal information processed by us in conducting our business, including on our websites, mobile applications, other online communications, and through other platforms and programs that link to this Privacy Policy (collectively, the “Services”).

Note that additional or different terms and privacy notices may be provided at the time we collect personal information depending on the type of Services you use. For example, we may provide a specific privacy notice to participants that describes our privacy practices in connection with fulfilling a prescription ordered by your physician, conducting clinical trials, or if you submit your information for recruitment to one of our clinical trials. Such additional privacy notices may supplement, or apply in lieu of, this Privacy Policy. By using our Services, you accept the terms of this Privacy Policy.

1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depends on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain states, additional disclosures about the information we collect is available in our Notice at Collection and Supplemental Notice. If you work for ACI or apply for a job with us, please see our Applicant and Worker Privacy Notice. In states with laws applicable to consumer health data our Consumer Health Data Privacy Notice also applies.

A. Information You Provide to Us Directly

• Account Creation. If you enroll in our Services, we may collect your name, email address, mailing address, phone number, date of birth, insurance information and other similar information.
• Enrollment and Clinical Trial Referral Information. If you enroll in certain Services, such as our patient support programs, or if you request to be matched to one of our clinical trial sites through one of our referral websites, we may collect personal information such as your name, email address, phone number, physical address, date of birth, and relevant information about your medical history.
• Clinical Trial Participants. If you participate in clinical trials that we sponsor, our clinical trial sites may collect personal information such as your driver’s license, passport number, tax identification number, health information related to your medications, medical history, medical insurance details, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history, and other relevant information in connection with your participation in clinical trials. Please note that the clinical trial site may be a separate “controller” or “business” with respect to your personal information and your personal information may be subject to the clinical trial site’s privacy policy. We collect personal information about you from clinical trial sites only where you have provided your consent to disclose that information to us or as required by law.
• Regulatory Information. We may collect personal information where required to comply with regulatory requirements, including information relating to any adverse events you may have experienced when using our products or participating in a clinical trial we sponsor.
• Healthcare Professionals. If you are a healthcare professional, we may collect personal information such as your professional contact information, credential and institutional affiliations information, information about our programs and activities in which you have participated, information about our interactions with you, information about your published papers, your photograph, information about your prescribing of our products and services, and information contained in agreements executed with us.
• Your Communications with Us. We collect personal information from you such as name and email address when you request or register for information about our Services, inquire about a product, request customer or technical support or otherwise communicate with us. SMS opt-in and phone numbers collected for SMS communication purposes will not be shared with any third party and affiliates for marketing purposes.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you to other users.
• Enrollment in Savings Coupon Card Program. If you enroll in our Savings Coupon Card Program, we may collect your contact information, such as, your name and e-mail address, to provide you with notifications, promotions, or other information.
• Patient Assistance Programs. We may offer patient assistance programs. If you enroll in any of our patient assistance programs, we may collect your contact information and other personal information.
• Referral Programs. We may offer referral programs. If you decide to participation, you may be asked to provide certain information which may include personal information.
• Healthcare Provider Visits. We may have marketing or promotional materials at certain healthcare providers’ facilities. If you inquire or request additional information about our products and services, we may collect your contact information.
• Marketing Programs. We may conduct marketing programs through various channels online and in-person. If you engage with our marketing materials and inquire or request additional information about our products and services, we may collect your contact information.
• Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to contact you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly disclose information of winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

B. Cookie Policy and Other Personal Information Collected Automatically

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Cookies and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytics practices to help us understand how individuals use our Services;
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting-Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. We may use various advertising Technologies including, but not necessarily limited to, Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:
  • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
  • Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
  • Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
• Social Media Platforms. Our Services may contain social media buttons, such as Facebook and Instagram, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policies of the companies providing them.

C. Personal Information Collected from Other Sources

• Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, a third-party platform, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings or third-party platform to which you have provided consent to receive marketing materials.
• Healthcare Professionals. If you are a healthcare professional, we may collect personal information such as hospital affiliation, license information, areas of interest, contact information such as address, email, and phone number, and other due diligence related information from various sources.
• Marketing Partners. We may work with third parties to conduct marketing campaigns, collect data and/or identify users or potential users of our Services or other products or services. Such third parties may collect and provide us with information about you, such as, name, contact information, medical information (such as condition and prescription), demographic information, interest information, information regarding online activities across devices and online platforms. Such third parties may also display our marketing materials to you and provide us with your contact information if you consent to receiving such materials and agree to be contacted by us for more information about our products and services.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services. We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;
• Providing you access to certain areas, functionalities, and features of our Services;
• Answering your requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes through email, direct mail, our Services, mobile applications, as well as via text messaging;
• Undertaking activities to verify or maintain the quality or safety of our Services;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative and Business Purposes. We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest in and engagement with our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise privacy rights under this Privacy Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Disclosing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies;
• Supporting public health initiatives, symposia, conferences, and scientific, educational and volunteer events;
• Carrying out activities that are required to comply with our legal obligations, and
• For other legitimate business purposes as permitted by law.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. We may also use and share your personal information to measure and predict the effectiveness of advertising and marketing, to find audience for marketing and advertising, and other analytics and operations related to advertising and marketing.

We may also permit third parties to collect your information over time, your information with us or across third-party websites, mobile applications and/or online services, including those that assist us in operating our Services, including to serve ads or provide messaging to you on our websites and mobile applications or on third-party platforms. We also use third-party advertising companies to serve and load ads on certain parts of our Services, including an ad server to provide advertising when you use our Services. These companies may use internet or electronic information about our Services and other websites and mobile applications to provide advertisements about goods and services of interest to you.

Some of the ways we market to you include email campaigns, mobile push notifications, custom audiences advertising and “interest-based” or “personalized advertising,” including through cross-device tracking.

D. With Your Consent

We may use your personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law, including to create de-identified and/or aggregated information.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may disclose your personal information are described below:

• Clinical Research Organizations. If you participate in clinical trials and research, the clinical trial sites may disclose any personal information you provide in conjunction with your participation to the Clinical Research Organization (“CRO”) that we have engaged to manage the research or conduct the clinical trial. We endeavor not to collect clinical trial participant personal information directly, and other than pharmacovigilance data, all personal information we receive from CROs about clinical trial participants is de-identified or pseudonymized unless an exception applies.
• Clinical Trial Sites. If you request to be matched with a clinical trial site through our Services, we may disclose your personal information with the clinical trial site so that the clinical trial site can contact you about participating in the trial.
• Service Providers. We may disclose your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, business analytics, hosting, payment processing, customer service, and related services.
• Business Partners. We may disclose your personal information with business partners to provide you with a product or service you have requested. We may also disclose your personal information with business partners with whom we jointly offer products or services.
• Affiliates. We may disclose your personal information with our affiliated companies, for example for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
• Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with others (including individuals and third parties who do not use our Services and the general public).
• Advertising Partners. Through our Services, we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” or “personalized advertising.”
• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services.

B. To Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. We may also share your information with third parties as appropriate and permitted by law.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

4. YOUR PRIVACY CHOICES

The privacy choices you may have about your personal information are determined by applicable law and described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us.
• Mobile Devices. We may send you push notifications through a mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use a mobile application. You may opt-out of this collection by changing the settings on your mobile device.
• Cookies and Personalized Advertising.
• You may decline all or select the types of non-necessary Technologies that apply to your use of our Services by managing your preferences at any time on the Cookie Banner by clicking on the Cookie icon on our Services.
• You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. (Note you must separately opt out in each browser and on each device.) However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
• The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

5. YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to:

• Obtain Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information including specific pieces of personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”).
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information.
• Request Deletion of your personal information.
• Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes, including (i) the right to opt-out of the sale or sharing of personal information, (ii) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the use and disclosure of sensitive personal information, and (iii) opt out of the processing of your personal information for purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

Exercising Your Privacy Rights

• Generally. If you would like to exercise a privacy right, please Contact Us or as otherwise instructed in the additional privacy notices provided at the time we collect your personal information. We will process such requests in accordance with applicable laws and do not discriminate against any individual who exercises or seeks to exercise their privacy rights.
• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and Contact Us for additional instructions.
• Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.
• Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, please Contact Us for additional instructions.

6. INFORMATION SECURITY

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we will use safeguards acceptable under applicable law to support such transfers, such as the EU Standard Contractual Clauses.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.

9. CHILDREN’S INFORMATION

The Services are not directed to children under the age of 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to the Service without your consent, please Contact Us. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.

10. THIRD-PARTY SITES AND APPLICATIONS

Our Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

11. CONTACT US

ACI is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Legal Department
Alpha Cognition, Inc.
legal@alphacognition.com

12. CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law, such as by sending you an email. If you continue to access the Services after the new Privacy Policy takes effect, we will assume you have read and acknowledged the new terms.

13.NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES

This Notice at Collection and Supplemental Policy is for residents of states that have adopted comprehensive privacy legislation that apply to our Services (collectively, “Applicable State Laws”).

Personal Information: We may have collected the following categories of personal information from you: personal identifiers (e.g., name, alias, postal address, unique personal identifier or other similar identifiers), protected classification characteristics under California or federal law, financial information (e.g., age, race, national origin), employment information, commercial information (e.g., records of personal property, or other purchasing or consuming histories or tendencies), geolocation information, Internet or other electronic network activity information, biometric information, and inferences about you.

Sensitive Personal Information. We may have collected sensitive Personal Information, a type of Personal Information, from you, including details of health and disability, including medical information, health insurance information, and mental health (“health data”).

Sources of Personal Information. As more fully described in the section titled, “Personal Information We Collect,” the sources from which we collect Personal Information include directly from you when you interact with us, automatically from you when you use our Services (for example, through cookies and other Technologies) from third parties (for example, from third-party referrals).

Purposes for Processing Personal Information. We use the Personal Information we collect about you for the business purposes described above in the section titled, “How We Use Your Personal Information.” We do not process health data or other sensitive Personal Information without obtaining your consent and only process sensitive Personal Information for the purposes outlined above and to the extent permitted under law. Please review our Consumer Health Data Privacy Notice^A1 for additional information about our handling of consumer health data as defined under certain U.S. state laws.

Disclosures of Personal Information. We disclose your Personal Information to the parties described above in the section titled, “How We Disclose Your Personal Information.”

Global Privacy Control. Our use of certain online Technologies may be considered a “sale” or “sharing” with third parties under applicable law. If you live in certain U.S. States, you may opt out of such “sale” or “sharing” by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). You can find, download, and use a browser supporting the GPC browser signal here. (Note you must turn the GPC signal on for each supported browser or browser extension you use.)

Services Intended for Adults. Our Services are intended for adults and our marketing and business practices are targeted at individuals over 18 years of age. We have no actual knowledge that we “sell” or “share” Personal Information of individuals under 16 years of age.

Data Retention. The above section titled, “Retention of Personal Information,” outlines the criteria we utilize for determining how long to retain your Personal Information.