Aton Holdings, Inc.
Privacy Notice
Aton Holdings, Inc. (“Aton Health,” “we,” or “us”) is committed to protecting the privacy of your personal information. This Aton Holdings, Inc. Privacy Policy (“Privacy Policy”) outlines how we collect, protect, use, and disclose information through: our website, https://www.atonhealth.com/; clinical trials; social media pages that we control; HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and other offline interactions you have with us. Collectively, we refer to the website, social media pages, emails, and offline business interactions as the “Services.”
Aton Health does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means your personal information to another business or a third party for monetary or other valuable consideration.
Personal and Other Information We Collect and How We Collect It
Texting Privacy
We will only use the information you provide through the Services when opting into receiving text messages to transmit your mobile messages and respond to you, if necessary. We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or customer information collected through the Services to any third party.
Personal Information
As used in this Privacy Policy, “Personal Information” means any information that can be used to identify you as an individual or can be reasonably linked, directly or indirectly, to a specific natural person. The Services collect the following kinds of Personal Information: name, address, telephone number, email address, other contact information, health-related information and IP address.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We collect Personal Information in a variety of ways, including through the Services generally, and from other sources. We collect Personal Information through the Services, for example, when you register interest in or sign up for a clinical trial, attend one of our events, sign up for a newsletter, or call or email us.
If you enroll in an Aton Health clinical trial, you will receive detailed information about data processing – including the collection of Personal Information – during the initiation of the clinical trial process.
Other Information
“Other Information” refers to any information that does not reveal your specific identify or does not directly relate to an identifiable individual, and includes information such as the type of Internet browser and operating system used; domain name of the website from which you came; number of visits; average time spent on the site; and pages viewed. We may use Other Information, for example, to monitor the relevancy of our website and improve its performance or content.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
From Your Browser or Device
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Cookies (Information Stored Automatically on Your Computer)
We use cookies on our website. Cookies are small files that are stored on your computer by your web browser. A cookie allows our website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of our website during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the website, and the link you used to leave our website. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the website may not operate correctly.
Analytics
We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the website uses Google Analytics to help collect and analyze certain information for the purposes discussed above.
Third-Party Plugins
Our website may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.
How We Use and Process Your Information
We use the Personal Information that we collect for the following purposes. We engage in these activities based on our legitimate business interests in providing Services, to manage our relationship with you, and with your consent to the extent required by applicable law.
• Providing the functionality of the Services and fulfilling your requests.
o To provide the Services; conducting clinical trials; responding to your questions or requests concerning the Services; or to provide customer service.
o To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, about our Services.
o To send administrative information to you, such as changes to our terms, conditions, and policies, and to fulfill the terms of any agreement you have with us.
o To deliver confirmations, account information, notifications, and similar operational communications.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
o To send you marketing-related emails, with information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including emails.
o To facilitate social sharing functionality that you choose to use.
• Analyzing Personal Information for business reporting and providing personalized services.
o To analyze or predict our users’ preferences in order to prepare reports on how our digital content is used, so we can improve our Services.
o To improve the user experience and quality of our products and Services generally, including by improving the website and enhancing users’ experiences with the website.
o To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and content that we believe will be relevant and interesting to you.
• Accomplishing our business purposes.
o For data analysis to improve the efficiency of our Services.
o For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
o For fraud prevention and fraud security monitoring purposes, such as prevention of cyberattacks or identity theft.
o For developing new products and services or improving our existing Services.
o For identifying usage trends for our Services.
o To comply with legal and/or regulatory requirements.
o To manage our business.
Disclosure of Your Information
We disclose Personal Information to third parties who support our clinical trials; other third-party service providers; and via other means. You also may disclose your Personal Information yourself.
We may disclose Personal Information that we collect or that you provide to us to third parties we use to support our clinical trials or other services as described in the Privacy Policy. Any such third party is bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, including:
• To comply with a court order, law, or legal process, including to respond to a government or regulatory request, which could include laws outside of your country of residence.
• To cooperate with public and government authorities, including to respond to a request or to provide information we believe is necessary or appropriate (these can include authorities outside of your country of residence).
• To cooperate with law enforcement, including, for example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons, including to enforce our terms and conditions or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Your Own Disclosures
By using the Services, you may elect to disclose Personal Information. This includes disclosure via message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. This also includes disclosure through your social sharing activity.
Transfer and Storage of Your Information
Aton Health is headquartered in Kansas City, Missouri, in the United States. Your Personal Information is saved and processed in the United States. As a result, depending on where you live, your personal information may be processed outside of your country of residence where the data protection rules are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you have any privacy-related questions about the transfer or storage of your Personal Information please contact us at info@atonhealth.com.
Data Retention
We retain your personal information for the length of time needed or permitted in light of the purpose(s) for which it was obtained, as outlined in this Privacy Policy, and/or in accordance with applicable law.
The criteria used to determine our retention periods include:
• The length of time we have an ongoing relationship with you and provide the Services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Security
Aton Health is committed to protecting the Personal Information you share with us.
We seek to utilize a combination of reasonable security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
Sensitive Information
Except where we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
Children
Aton Health’s Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18 without seeking and acquiring consent from the minor’s parental or legal guardian, if required by applicable law.
Your Choices Regarding Direct Marketing
We give you choices regarding our use and disclosure of your Personal Information, including for marking purposes. If you do not want to receive emails from us in the future, you may unsubscribe at any time by clicking on the “unsubscribe” link or contacting info@atonhealthcom.
Aton Health does not share Personal Information with third parties for their direct marketing purposes without your consent.
Aton Health will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Your Rights
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, please contact us using the contact information at the end of this Privacy Policy. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
If you withdraw or are withdrawn from a clinical trial, we will not collect or receive any new information from the Services. However, information already collected, processed, and stored up to the time that your withdrawal request is received may not be deleted, and may continue to be used for the clinical trial’s purpose, including compliance with regulatory requirements, unless applicable law requires otherwise.
External or Third-Party Links
This website may contain links to third-party websites. If you use these links, you will leave the website. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
Changes to the Privacy Policy
We may make changes to the website in the future and, as a consequence, we will need to revise this Privacy Policy to reflect those changes. We will post all such changes on the website, so you should review this page periodically. Any changes will become effective when we post the revised Privacy Policy on the Services.
How to Contact Us
If you have any questions or comments about the Aton Health Privacy Policy, please contact us at:
Aton Holdings, Inc.
Attn: Legal Department, Privacy
1740 W. 92nd St.
Kansas City, MO 64114
Email: info@atonhealth.com
Additional Information Regarding the EEA and UK
Aton Health is located in the United States. Aton Health abides by and uses EEA and UK approved standard contractual clauses and other approved mechanisms for transfers of Personal Information from the EEA and UK to the US.
If you have a question or complaint you may:
• Contact our Data Protection Officer (DPO) at info@atonhealth.com
• File a complaint directly with any relevant supervisory authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.
Additional Information Regarding California
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. As Stated in the Privacy Policy, we may collect Personal Information such as name, contact
information, online identifiers, Internet or network activity information, such as browsing history, search history and interactions with our website.
We do not “sell” Personal Information as defined by the CCPA which is the disclosure of Personal Information to a third party for purposes of cross-context behavioral advertising.
We collect this Personal Information as described above, including from you when you contact us through the Services. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, as described above.
Aton Health does not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. Aton Health retains personal information we collect only as reasonably necessary for the purposes described in this policy or otherwise disclosed to you at the time of collection, or as authorized by you, or as required by law.
Subject to certain limitations and exceptions, California residents may make requests pursuant to the CCPA by contacting us at the address or email in “How to Contact Us” section of this policy. You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
Last updated: January 2026
Aton Holdings, Inc. (“Aton Health,” “we,” or “us”) is committed to protecting the privacy of your personal information. This Aton Holdings, Inc. Privacy Policy (“Privacy Policy”) outlines how we collect, protect, use, and disclose information through: our website, https://www.atonhealth.com/; clinical trials; social media pages that we control; HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and other offline interactions you have with us. Collectively, we refer to the website, social media pages, emails, and offline business interactions as the “Services.”
Aton Health does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means your personal information to another business or a third party for monetary or other valuable consideration.
Personal and Other Information We Collect and How We Collect It
Texting Privacy
We will only use the information you provide through the Services when opting into receiving text messages to transmit your mobile messages and respond to you, if necessary. We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or customer information collected through the Services to any third party.
Personal Information
As used in this Privacy Policy, “Personal Information” means any information that can be used to identify you as an individual or can be reasonably linked, directly or indirectly, to a specific natural person. The Services collect the following kinds of Personal Information: name, address, telephone number, email address, other contact information, health-related information and IP address.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We collect Personal Information in a variety of ways, including through the Services generally, and from other sources. We collect Personal Information through the Services, for example, when you register interest in or sign up for a clinical trial, attend one of our events, sign up for a newsletter, or call or email us.
If you enroll in an Aton Health clinical trial, you will receive detailed information about data processing – including the collection of Personal Information – during the initiation of the clinical trial process.
Other Information
“Other Information” refers to any information that does not reveal your specific identify or does not directly relate to an identifiable individual, and includes information such as the type of Internet browser and operating system used; domain name of the website from which you came; number of visits; average time spent on the site; and pages viewed. We may use Other Information, for example, to monitor the relevancy of our website and improve its performance or content.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
From Your Browser or Device
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Cookies (Information Stored Automatically on Your Computer)
We use cookies on our website. Cookies are small files that are stored on your computer by your web browser. A cookie allows our website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of our website during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the website, and the link you used to leave our website. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the website may not operate correctly.
Analytics
We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the website uses Google Analytics to help collect and analyze certain information for the purposes discussed above.
Third-Party Plugins
Our website may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.
How We Use and Process Your Information
We use the Personal Information that we collect for the following purposes. We engage in these activities based on our legitimate business interests in providing Services, to manage our relationship with you, and with your consent to the extent required by applicable law.
• Providing the functionality of the Services and fulfilling your requests.
o To provide the Services; conducting clinical trials; responding to your questions or requests concerning the Services; or to provide customer service.
o To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, about our Services.
o To send administrative information to you, such as changes to our terms, conditions, and policies, and to fulfill the terms of any agreement you have with us.
o To deliver confirmations, account information, notifications, and similar operational communications.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
o To send you marketing-related emails, with information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including emails.
o To facilitate social sharing functionality that you choose to use.
• Analyzing Personal Information for business reporting and providing personalized services.
o To analyze or predict our users’ preferences in order to prepare reports on how our digital content is used, so we can improve our Services.
o To improve the user experience and quality of our products and Services generally, including by improving the website and enhancing users’ experiences with the website.
o To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and content that we believe will be relevant and interesting to you.
• Accomplishing our business purposes.
o For data analysis to improve the efficiency of our Services.
o For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
o For fraud prevention and fraud security monitoring purposes, such as prevention of cyberattacks or identity theft.
o For developing new products and services or improving our existing Services.
o For identifying usage trends for our Services.
o To comply with legal and/or regulatory requirements.
o To manage our business.
Disclosure of Your Information
We disclose Personal Information to third parties who support our clinical trials; other third-party service providers; and via other means. You also may disclose your Personal Information yourself.
We may disclose Personal Information that we collect or that you provide to us to third parties we use to support our clinical trials or other services as described in the Privacy Policy. Any such third party is bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, including:
• To comply with a court order, law, or legal process, including to respond to a government or regulatory request, which could include laws outside of your country of residence.
• To cooperate with public and government authorities, including to respond to a request or to provide information we believe is necessary or appropriate (these can include authorities outside of your country of residence).
• To cooperate with law enforcement, including, for example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons, including to enforce our terms and conditions or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Your Own Disclosures
By using the Services, you may elect to disclose Personal Information. This includes disclosure via message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. This also includes disclosure through your social sharing activity.
Transfer and Storage of Your Information
Aton Health is headquartered in Kansas City, Missouri, in the United States. Your Personal Information is saved and processed in the United States. As a result, depending on where you live, your personal information may be processed outside of your country of residence where the data protection rules are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you have any privacy-related questions about the transfer or storage of your Personal Information please contact us at info@atonhealth.com.
Data Retention
We retain your personal information for the length of time needed or permitted in light of the purpose(s) for which it was obtained, as outlined in this Privacy Policy, and/or in accordance with applicable law.
The criteria used to determine our retention periods include:
• The length of time we have an ongoing relationship with you and provide the Services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Security
Aton Health is committed to protecting the Personal Information you share with us.
We seek to utilize a combination of reasonable security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
Sensitive Information
Except where we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
Children
Aton Health’s Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18 without seeking and acquiring consent from the minor’s parental or legal guardian, if required by applicable law.
Your Choices Regarding Direct Marketing
We give you choices regarding our use and disclosure of your Personal Information, including for marking purposes. If you do not want to receive emails from us in the future, you may unsubscribe at any time by clicking on the “unsubscribe” link or contacting info@atonhealthcom.
Aton Health does not share Personal Information with third parties for their direct marketing purposes without your consent.
Aton Health will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Your Rights
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, please contact us using the contact information at the end of this Privacy Policy. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
If you withdraw or are withdrawn from a clinical trial, we will not collect or receive any new information from the Services. However, information already collected, processed, and stored up to the time that your withdrawal request is received may not be deleted, and may continue to be used for the clinical trial’s purpose, including compliance with regulatory requirements, unless applicable law requires otherwise.
External or Third-Party Links
This website may contain links to third-party websites. If you use these links, you will leave the website. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
Changes to the Privacy Policy
We may make changes to the website in the future and, as a consequence, we will need to revise this Privacy Policy to reflect those changes. We will post all such changes on the website, so you should review this page periodically. Any changes will become effective when we post the revised Privacy Policy on the Services.
How to Contact Us
If you have any questions or comments about the Aton Health Privacy Policy, please contact us at:
Aton Holdings, Inc.
Attn: Legal Department, Privacy
1740 W. 92nd St.
Kansas City, MO 64114
Email: info@atonhealth.com
Additional Information Regarding the EEA and UK
Aton Health is located in the United States. Aton Health abides by and uses EEA and UK approved standard contractual clauses and other approved mechanisms for transfers of Personal Information from the EEA and UK to the US.
If you have a question or complaint you may:
• Contact our Data Protection Officer (DPO) at info@atonhealth.com
• File a complaint directly with any relevant supervisory authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.
Additional Information Regarding California
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. As Stated in the Privacy Policy, we may collect Personal Information such as name, contact
information, online identifiers, Internet or network activity information, such as browsing history, search history and interactions with our website.
We do not “sell” Personal Information as defined by the CCPA which is the disclosure of Personal Information to a third party for purposes of cross-context behavioral advertising.
We collect this Personal Information as described above, including from you when you contact us through the Services. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, as described above.
Aton Health does not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. Aton Health retains personal information we collect only as reasonably necessary for the purposes described in this policy or otherwise disclosed to you at the time of collection, or as authorized by you, or as required by law.
Subject to certain limitations and exceptions, California residents may make requests pursuant to the CCPA by contacting us at the address or email in “How to Contact Us” section of this policy. You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
Last updated: January 2026
Aton Holdings, Inc. (“Aton Health,” “we,” or “us”) is committed to protecting the privacy of your personal information. This Aton Holdings, Inc. Privacy Policy (“Privacy Policy”) outlines how we collect, protect, use, and disclose information through: our website, https://www.atonhealth.com/; clinical trials; social media pages that we control; HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and other offline interactions you have with us. Collectively, we refer to the website, social media pages, emails, and offline business interactions as the “Services.”
Aton Health does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means your personal information to another business or a third party for monetary or other valuable consideration.
Personal and Other Information We Collect and How We Collect It
Texting Privacy
We will only use the information you provide through the Services when opting into receiving text messages to transmit your mobile messages and respond to you, if necessary. We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or customer information collected through the Services to any third party.
Personal Information
As used in this Privacy Policy, “Personal Information” means any information that can be used to identify you as an individual or can be reasonably linked, directly or indirectly, to a specific natural person. The Services collect the following kinds of Personal Information: name, address, telephone number, email address, other contact information, health-related information and IP address.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We collect Personal Information in a variety of ways, including through the Services generally, and from other sources. We collect Personal Information through the Services, for example, when you register interest in or sign up for a clinical trial, attend one of our events, sign up for a newsletter, or call or email us.
If you enroll in an Aton Health clinical trial, you will receive detailed information about data processing – including the collection of Personal Information – during the initiation of the clinical trial process.
Other Information
“Other Information” refers to any information that does not reveal your specific identify or does not directly relate to an identifiable individual, and includes information such as the type of Internet browser and operating system used; domain name of the website from which you came; number of visits; average time spent on the site; and pages viewed. We may use Other Information, for example, to monitor the relevancy of our website and improve its performance or content.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
From Your Browser or Device
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Cookies (Information Stored Automatically on Your Computer)
We use cookies on our website. Cookies are small files that are stored on your computer by your web browser. A cookie allows our website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of our website during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the website, and the link you used to leave our website. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the website may not operate correctly.
Analytics
We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the website uses Google Analytics to help collect and analyze certain information for the purposes discussed above.
Third-Party Plugins
Our website may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.
How We Use and Process Your Information
We use the Personal Information that we collect for the following purposes. We engage in these activities based on our legitimate business interests in providing Services, to manage our relationship with you, and with your consent to the extent required by applicable law.
• Providing the functionality of the Services and fulfilling your requests.
o To provide the Services; conducting clinical trials; responding to your questions or requests concerning the Services; or to provide customer service.
o To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, about our Services.
o To send administrative information to you, such as changes to our terms, conditions, and policies, and to fulfill the terms of any agreement you have with us.
o To deliver confirmations, account information, notifications, and similar operational communications.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
o To send you marketing-related emails, with information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including emails.
o To facilitate social sharing functionality that you choose to use.
• Analyzing Personal Information for business reporting and providing personalized services.
o To analyze or predict our users’ preferences in order to prepare reports on how our digital content is used, so we can improve our Services.
o To improve the user experience and quality of our products and Services generally, including by improving the website and enhancing users’ experiences with the website.
o To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and content that we believe will be relevant and interesting to you.
• Accomplishing our business purposes.
o For data analysis to improve the efficiency of our Services.
o For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
o For fraud prevention and fraud security monitoring purposes, such as prevention of cyberattacks or identity theft.
o For developing new products and services or improving our existing Services.
o For identifying usage trends for our Services.
o To comply with legal and/or regulatory requirements.
o To manage our business.
Disclosure of Your Information
We disclose Personal Information to third parties who support our clinical trials; other third-party service providers; and via other means. You also may disclose your Personal Information yourself.
We may disclose Personal Information that we collect or that you provide to us to third parties we use to support our clinical trials or other services as described in the Privacy Policy. Any such third party is bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, including:
• To comply with a court order, law, or legal process, including to respond to a government or regulatory request, which could include laws outside of your country of residence.
• To cooperate with public and government authorities, including to respond to a request or to provide information we believe is necessary or appropriate (these can include authorities outside of your country of residence).
• To cooperate with law enforcement, including, for example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons, including to enforce our terms and conditions or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Your Own Disclosures
By using the Services, you may elect to disclose Personal Information. This includes disclosure via message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. This also includes disclosure through your social sharing activity.
Transfer and Storage of Your Information
Aton Health is headquartered in Kansas City, Missouri, in the United States. Your Personal Information is saved and processed in the United States. As a result, depending on where you live, your personal information may be processed outside of your country of residence where the data protection rules are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you have any privacy-related questions about the transfer or storage of your Personal Information please contact us at info@atonhealth.com.
Data Retention
We retain your personal information for the length of time needed or permitted in light of the purpose(s) for which it was obtained, as outlined in this Privacy Policy, and/or in accordance with applicable law.
The criteria used to determine our retention periods include:
• The length of time we have an ongoing relationship with you and provide the Services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Security
Aton Health is committed to protecting the Personal Information you share with us.
We seek to utilize a combination of reasonable security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
Sensitive Information
Except where we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
Children
Aton Health’s Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18 without seeking and acquiring consent from the minor’s parental or legal guardian, if required by applicable law.
Your Choices Regarding Direct Marketing
We give you choices regarding our use and disclosure of your Personal Information, including for marking purposes. If you do not want to receive emails from us in the future, you may unsubscribe at any time by clicking on the “unsubscribe” link or contacting info@atonhealthcom.
Aton Health does not share Personal Information with third parties for their direct marketing purposes without your consent.
Aton Health will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Your Rights
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, please contact us using the contact information at the end of this Privacy Policy. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
If you withdraw or are withdrawn from a clinical trial, we will not collect or receive any new information from the Services. However, information already collected, processed, and stored up to the time that your withdrawal request is received may not be deleted, and may continue to be used for the clinical trial’s purpose, including compliance with regulatory requirements, unless applicable law requires otherwise.
External or Third-Party Links
This website may contain links to third-party websites. If you use these links, you will leave the website. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
Changes to the Privacy Policy
We may make changes to the website in the future and, as a consequence, we will need to revise this Privacy Policy to reflect those changes. We will post all such changes on the website, so you should review this page periodically. Any changes will become effective when we post the revised Privacy Policy on the Services.
How to Contact Us
If you have any questions or comments about the Aton Health Privacy Policy, please contact us at:
Aton Holdings, Inc.
Attn: Legal Department, Privacy
1740 W. 92nd St.
Kansas City, MO 64114
Email: info@atonhealth.com
Additional Information Regarding the EEA and UK
Aton Health is located in the United States. Aton Health abides by and uses EEA and UK approved standard contractual clauses and other approved mechanisms for transfers of Personal Information from the EEA and UK to the US.
If you have a question or complaint you may:
• Contact our Data Protection Officer (DPO) at info@atonhealth.com
• File a complaint directly with any relevant supervisory authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.
Additional Information Regarding California
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. As Stated in the Privacy Policy, we may collect Personal Information such as name, contact
information, online identifiers, Internet or network activity information, such as browsing history, search history and interactions with our website.
We do not “sell” Personal Information as defined by the CCPA which is the disclosure of Personal Information to a third party for purposes of cross-context behavioral advertising.
We collect this Personal Information as described above, including from you when you contact us through the Services. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, as described above.
Aton Health does not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. Aton Health retains personal information we collect only as reasonably necessary for the purposes described in this policy or otherwise disclosed to you at the time of collection, or as authorized by you, or as required by law.
Subject to certain limitations and exceptions, California residents may make requests pursuant to the CCPA by contacting us at the address or email in “How to Contact Us” section of this policy. You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
Last updated: January 2026