Privacy Policy

Last Revised: February 22, 2024

Atai Therapeutics, Inc. (fka IntroSpect Digital Therapeutics, Inc.) (“atai,” “we,” “us” or “our”) provides a mobile application and website (the “Application”) for purposes of an initial study of the effectiveness of the functionality provided through the Application (the “Study”). This Privacy Policy describes the information that we may collect, use and disclose in connection with the Application and any other related content, software, applications, and materials thereon.

Please review the following carefully so that you understand our privacy practices. When you use the Application, you understand that we may collect, use and disclose information about you in various ways subject to the terms of the Privacy Policy. By using the Application, you are indicating your agreement with the terms of the Privacy Policy. If you have questions about this Privacy Policy, please contact us at the contact information listed in Section X below.

I. Eligibility Requirements / Access to the Application

The Application permits participants to participate in surveys regarding depression and anxiety, watch short informational videos regarding depression and anxiety and/or take a short informational course regarding cognitive behavioral therapy (CBT) as part of the Study. The Application also allows Supported Providers (as defined below) to access information that participants provide to the Application during the Study. Participants and Supported Providers are referred to herein as “you,” “your,” or “user”.

Access to the Application is provided only in conjunction with the Study. This may or may not include certain health care providers that utilize the Application in connection with the Study (each a “Supported Provider”). In order to be eligible to use the Application, you must receive an authorization code from a Supported Provider, or otherwise in the context of the Study, which you must provide to authenticate your use of the Application.

You must 18 years of age or older (or the age of legal majority in your jurisdiction) to participate in the Study and to use the Application. We do not knowingly collect or solicit Personal Information (as listed in Section II below) from anyone under the age of 13 or knowingly allow such persons to register on the Application. In the event that we learn that we have collected Personal Information from a child under age 13, we will make commercially reasonable efforts to delete that information. If you believe that we might have any such information from or about a child under 13, please contact us.

II. Information We Collect

Information that identifies (whether directly or indirectly) a particular individual, referred to in this Privacy Policy as “Personal Information”.

When you register to use the Application, you will provide your authorization code and fill out a profile which includes certain Personal Information which may include: user ID, age, country of residence, username, password, ethnicity/race.

When you use the Application, categories of Personal Information you will be asked to provide on the Mobile Application may include demographic information, health-related data and behavioral data.

We also collect Personal Information from our Supported Providers, including business name and contact information. Supported Providers may also provide treatment details for a user (including dosages and appointment times) on the Application.

We will not use any information provided in the Application for the purposes of diagnosing any medical conditions or illnesses and will not be reviewed by a medical professional for the purpose of detecting, diagnosing, or staging pathology of any kind.

IF YOU EXPERIENCE A MEDICAL EVENT OR BELIEVE THAT YOU MAY HAVE A MEDICAL EMERGENCY, YOU SHOULD CALL 911 IMMEDIATELY.

A. Cookies

To help us serve your needs better, we use “cookies” to store user information, such as your IP address.

A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. A website can use cookies to recognize repeat users or track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. Users of the Application should be aware that data about you may be automatically collected by virtue of the standard operation of our computer servers or through the use of cookies, including certain Personal Information. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. There may, however, be some features of the Application which require the use of cookies in order to customize the delivery of information to you.

Users should be aware that we cannot control the use of cookies (or the resulting information) by third parties. The use of third party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies.

We do not track users across third party websites, and therefore do not use or respond to “do not track” signals in your web browser.

III. How We Use Your Information

A. To Provide the Application

We use the information that we collect from you to provide you with access to the Application, support and enhance your use of the Application, including to improve and develop the Application and our business, train our AI/ML algorithms and for other internal operations purposes. This allows us to monitor which features of the Application are used most and to determine which features we need to focus on improving. We may also use your Personal Information to communicate with you, including about the Study, future opportunities to participate in studies that we are conducting or other opportunities that we believe may be of interest to you.

We also use Personal Information collected from users and/or from Supported Providers to create anonymized and aggregated data sets that may be used for a variety of functions, including research, internal analysis, analytics, and other business and administrative purposes.

We may also use Personal Information to comply with legal and regulatory obligations and assert and defend our legal rights, to cooperate with regulators and law enforcement bodies, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend our business, our rights, the rights of our users, or others.

B. For Purposes of the Study in Accordance with the Informed Consent

We use information about you collected through the Application for purposes of the Study and in accordance with the Informed Consent Form you have been provided.

C. Diagnose Website Problems

We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer the Website. Your IP address is also used to gather broad demographic data. It is not stored or linked to your personal profile information, such as name or contact information.

D. Service-related Announcements

We will use your contact information to send you service-related announcements when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email or a notification within the Application.

Generally, you may not opt-out of these communications, which are not promotional in nature. By using the Application, you agree to receive these communications.

IV. Our Disclosure of Your Information

We share your Personal Information as described below, and in accordance with the Informed Consent Form and our Terms of Use. We do not share Personal Information with third parties for them to use for their own marketing purposes.

A. Aggregated Data

We may de-identify Personal Information and use and disclose such de-identified data for any purpose. We may also share aggregated data collected from users of the Application and/or Supported Providers with third parties for industry analysis and demographic profiling, but such aggregated data will not include any Personal Information.

B. Supported Providers / Third Party Service Providers

We may provide third-party companies, including our Supported Providers, and individuals with access to your information to the extent that it is needed by them to facilitate the Application, to provide the Application on our behalf, provide customer support, perform Application-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Application’s features) or to assist us in analyzing how the Application are used. These third parties have access to your Personal Information only to perform these tasks on our behalf, and we will contractually require them to protect and safeguard your Personal Information to at least the same extent that we do.

C. Law Enforcement

We cooperate with government and law enforcement officials, agencies and private parties to facilitate enforcement and compliance with the law. We will disclose information about you to government or law enforcement officials, agencies or private parties to the extent that we, in our sole discretion, believe such disclosure is necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of Atai or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.

D. Business Transfers

In the event that all or a substantial portion of the assets, business or stock of atai are acquired by, merged with or transferred to another party, or in the event that atai goes out of business or enters bankruptcy, your Personal Information may be one of the assets that is transferred to or acquired by the third party. You acknowledge that such transfers may occur, and that any acquirer of atai or its assets may continue to use your Personal Information as set forth in this Privacy Policy.

V. Accessing and Updating Your Personal Information and Preferences

If (i) your Personal Information changes, (ii) you no longer desire to use the Application, or (iii) you wish to update your preferences to receive SMS messaging or other communications from us, you may correct, delete inaccuracies, or amend your Personal Information and preferences by making the change to their profile or by emailing us at [email protected].

VI. Linked Sites

In addition to the third-party entities referenced above, we may provide links to other third-party websites or content through the Application solely as a convenience to you. However, such linking does not mean, and should not be interpreted to mean, that atai endorses, is affiliated with or makes any representations concerning such third-party websites. atai neither reviews, nor controls, nor is responsible for these third-party sites or any content therein. By using such links, you will leave the Application. If you decide to access any of the third-party sites linked to the Application, you do so entirely at your own risk. atai shall not be liable for any consequences arising from use of any third-party websites to which the Application link.

VII. Security

We strive to maintain the security of your information by using appropriate measures designed to protect our systems. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet, and any information you transmit to us you do at your own risk. Consequently, we do not insure or warrant the security of any information you transmit, and you do so at your own risk.

VIII. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes to how we use or disclose information we collect through this Privacy Policy, we will use reasonable efforts to notify you (such as by emailing you at the the email address specified in your account, by posting notice of such changes on the Website or the Application, or by other means consistent with applicable law) and follow such other steps as required by law. We encourage you to periodically review this Privacy Policy, which may be found at https://atai.life/introspect-privacy-policy/ for the latest information on our privacy practices.

IX. Data Retention

Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use your Personal Information for as long as it is needed to provide you with access to the Application, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

X. Contact Us

If you have questions or concerns regarding this Privacy Policy, you should contact us at [email protected] or (332) 910-8980 or at the following address:
atai Therapeutics, Inc.
c/o atai Life Sciences
c/o Industrious NYC
250 West 34th Street
New York, NY 10119 Attn: Legal Department