This Privacy Policy describes how GNS Healthcare, Inc., d/b/a Aitia (“Aitia,” “we,” or “us”) collect, use, share, and otherwise process personal information when you visit our website at (the “Website”) or through other means that expressly reference this Privacy Notice. It also supplies additional information required under applicable privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act. Please note that if you are a participant enrolled in a clinical trial sponsored by Aitia, you will receive a separate notice at the time you enroll in the trial that applies to the processing of personal information collected about you in the course of the trial, and if you use the Website to apply for a job with Aitia, you will receive a separate notice at the time you make the application that applies to the processing of personal information collected about you during the recruitment process.

By accessing and using the Website, you agree and consent to the collection, use, processing and disclosure of your personal information as outlined in this Privacy Policy.

I. The Personal Information Aitia May Collect and How It Will Be Used

As used in this Privacy Policy, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We may collect and process the following categories and examples of personal information about you:

  • Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
  • Personal information categories including name, signature, address, and telephone number (some personal information included in this category may overlap with other categories);
  • Professional or employment-related information;
  • Geolocation data, such as geographic location information about a particular individual or device; and
  • Internet or other similar network activity, such as browsing history, search history, and information regarding your interaction with and use of our website.

We collect your personal information from a variety of sources, including information that you voluntarily provide to us, such as when you use our Website, communicate or otherwise interact with us, and information collected automatically about your use of the Website through the use of cookies and other electronic tools. We do not currently collect “sensitive personal information,” as that term is defined under applicable data protection laws, online.

We may use your personal information for our business purposes, including where it is necessary to do so for purposes such as verifying the identity of visitors to the Website, processing and responding to requests, improving our operations, maintaining details of our business contacts, facilitating business transactions and developing new business, sending announcements and communications, and complying with any legal, regulatory, or contractual obligation.

II. Cookies

We and our service providers use cookies and other online tracking mechanisms, which may include pixels and web beacons, to track information about your use of our Website.

Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website, while others allow us to track your activities while using our Website. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

We use third-party web analytics services (such as those of Google Analytics) and other technologies on our Website to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

III. How We Disclose Your Personal Information

We may disclose your personal information to the following categories of third parties for our business purposes:

  • Attorneys, auditors, accountants, consultants, and other professional service providers;
  • As required by law or in connection with a legal claim, dispute, or proceeding or in response to requests by governmental regulatory authorities, or as we may reasonably determine to be necessary or appropriate to protect our rights or the rights of others or to avert loss or harm to persons or property.
  • Third parties as needed to protect our legitimate interests, including to establish or defend our legal rights;
  • Third parties in the event that we sell all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger, restructuring or business transfer;
  • Certain other persons to the extent authorized by you.

In the preceding 12 months, we have not sold or shared for purposes of cross-context behavioral advertising any personal information to third parties.

Because the Internet and our operations are global, your personal information may be transferred to, processed in, and held in countries other than the one in which you reside. When we transfer personal data internationally, and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including: where the relevant country or recipient has been deemed to provide an adequate level of protection for your personal data by relevant authorities; using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards; obtaining your consent to transfer personal information after informing you about the possible risks of such a transfer; and transferring the personal information is necessary for the performance of (or to enter into) a contract between you and Aitia, or because the transfer is necessary for the performance of a contract between Aitia and a third party, and the contract was entered into in your interest.

IV. Data Retention and Security

Your personal information will be retained for as long as you maintain a business relationship with us and afterwards in accordance with our legal and regulatory obligations. When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

Aitia has implemented security measures designed to protect your personal information against loss, unauthorized disclosure or access, and other unlawful forms of processing. Despite the security measures that we have put in place to protect your personal information, no such measures can guarantee security or protect against unauthorized activity.

V. Data Subject Rights

Depending on your jurisdiction, you may have certain data subject rights. These rights vary by jurisdiction and may be subject to certain limitations and exemptions. These rights may include the right to:

  • Know what personal information we process about you and to obtain specific information about such personal information;
  • Correct or delete personal information;
  • Opt out of the sale of personal information or sharing of personal information for cross-context behavioral advertising—we do not sell personal information or share personal information for purposes of cross-context behavioral advertising, and so you are already opted out of such practices;
  • Object to or restrict the processing of your personal information in some circumstances; and
  • Receive a copy of your personal information in a portable format.

Individuals may also have the right to not be discriminated against for exercising applicable data subject rights and to lodge a complaint about the processing of their personal information with the relevant data protection authority or other regulator.

The rights described in this section are not absolute and we reserve all of our rights available to us at law in this regard. If you wish to exercise any of these rights, please email or call us at +1 617 374 2300. If you make a request related to personal information about you, we will need to verify your identity. For example, we may request that you match specific pieces of information you have provided to us previously to ensure that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time period provided by applicable law.

VI. California Shine the Light Disclosure

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

VII. Links to Other Websites

The Website may provide links to third-party websites. This Privacy Policy does not apply to those sites, which operate independently from the Website and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit them. We are not responsible for the content of these sites, any products or services that may be offered through these sites or any other use of these sites, nor for any data processing and privacy practices associated with such sites.

VIII. Children

The Website is not targeted at children under the age of eighteen (18) and we do not knowingly collect personal information from children under the age of 18. If we become aware of having collected personal information from a child under the age of 18 without valid consent, including as applicable, from their respective parents or guardians, we will take steps to delete the information from our records.

IX. Updates to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in our practices with respect to the processing of personal information or changes in applicable law. We encourage you to periodically review this Privacy Policy to stay informed about our information practices. We will indicate above the date on which this Privacy Policy was last modified. Your continued use of the Website constitutes your agreement to the Privacy Policy and any updates.

X. Contact Information

If you have any questions about how we process your personal information, please contact us at

Last Updated: December 12, 2023