Privacy Policy

Last Updated: September 30, 2024

BioAge Labs, Inc. (“BioAge,” “we,” “us,” or “our”) is a clinical-stage biotechnology company that is harnessing the biology of human aging to develop novel targets and therapies for metabolic diseases. This website provides information about our business and these product development activities (this “Site” and our “Product Development Activities” respectively). This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.

As used in this Privacy Policy, “personal information” has the meaning given to it under the law where you live, but typically refers to information that can be use to identify you as an individual; meanwhile our activities taken with respect to your personal information are referred to as “processing.” For residents of California and other U.S. states with special privacy rights, additional disclosures are available here.

1. Scope and updates to this privacy policy
- This Privacy Policy applies to all personal information processed by BioAge. By visiting or accessing this Site, you acknowledge and agree that you have read and understood this Privacy Policy.
- BioAge may provide additional privacy notices to individuals at the time we collect their personal information. For example, we may provide a specific privacy notice to participants that describes our privacy practices in connection with conducting clinical trials or when you submit your information for recruitment to one of our clinical trials. These additional privacy notices may supplement this Privacy Policy or may apply in lieu of this Privacy Policy.
- Changes to our 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. If you continue to access the Site after the new Privacy Policy takes effect, we will assume you have read and acknowledged the new policy.
2. Personal information we collect
- The categories of personal information we collect depend on how you interact with us, the Site, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Site, and information from other sources such as third-party services and organizations, as described below.
A. Personal Information Provided to Us Directly We may collect personal information provided to us in various ways.
1. Account Creation. We may collect personal information when you create an account, such as, name, email address, and username. For example, you may choose to provide your health, insurance and/or financial information in connection with a promotion or a patient assistance or support program.
2. 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.
3. Clinical Trial Participants. If you participate in clinical trials that we sponsor, our clinical trial sites may collect personal information relevant to your participation in clinical trials. Please note that the clinical trial site may be a separate “controller” or “business” of 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.
4. Reporting Adverse Experiences. If you contact us to report a potential issue, concern, or complaint related to an adverse experience potentially related to a clinical trial we sponsor (an “Adverse Experience”), we are required to collect certain information, including potentially sensitive personal information about the health and habits of the person with whom the Adverse Experience is associated.
5. Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address if you request information about our company or our Product Development Activities or to otherwise communicate with us.
6. Conferences, Trade Shows, and Other Events. To the extent we attend or host conferences, trade shows, and other events, we may collect personal information from you and other event registrants.
7. Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
8. Job Applications. We may post job openings and opportunities on the Site. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us. Please note that if you are hired by us, your personal information will be governed by a separate worker privacy notice.
B. Personal Information Collected Automatically We may collect personal information automatically when you use our Site.
1. Automatic Collection of Personal Information. We may collect certain information automatically when you use our Site, such as your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Site, such as pages that you visit before, during and after using our Site, 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 Site.
2. Cookie Policy (and Other Technologies). We, as well as third parties that provide content, or other functionality on our Site, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Site.
3. Social Media Platforms. Our Site may contain social media buttons, such as, Twitter, LinkedIn, Apple Podcasts, and Spotify, 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 Site and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it; and
C. Personal Information Collected from Other Sources
1. Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations or individuals.
3. How we use your personal information
We use your personal information for a variety of business purposes, including to provide our Site, for administrative purposes, and to communicate with you about our Product Development Activities, and for other legitimate business purposes as permitted by law.
A. Support our Product Development Activities and Site We may use your personal information to provide information about our Product Development Activities and Site, such as:
1. Managing your information;
2. Providing access to certain areas, functionalities, and features of our Site;
3. Answering requests for support;
4. Communicating with you;
5. Undertaking activities to verify or maintain the quality or safety of our Site;
6. Processing applications if you apply for a job we post on our Site; and
7. Allowing you to register for events.
B. Administrative Purposes We may use your personal information for various administrative purposes, such as:
1. Pursuing the legitimate interests of our business or a third party, (e.g., research and development (including pharmaceutical clinical trials and studies), network and information security, and fraud prevention, etc.);
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
3. Measuring interest and engagement in our Site;
4. Improving, upgrading, or enhancing our Site;
5. Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
6. Providing information required to meet our compliance obligations or commitments, such as collecting information from individuals who may have experienced potentially Adverse Experiences in conjunction with clinical trials we sponsor or are associated with;
7. Debugging to identify and repair errors with our Site;
8. Auditing relating to interactions, transactions, and other compliance activities;
9. Sharing personal information with third parties as needed to provide our Site, and
10. Enforcing our agreements and policies.
C. 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.
D. 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. Please note if we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.
4. 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. To Provide our Site and Product Development Activities The categories of third parties with whom we may share your personal information are described below.
1. 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 all personal information we receive from CROs about clinical trial participants is de-identified or pseudonymized unless an exception applies.
2. Service Providers. We may share your personal information with our third-party service providers including vendors that assist us with the provision of our Site and Product Development Activities. For example, service providers and vendors may provide us with IT support, hosting, research and development, payment processing, customer service, and related services.
3. Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
4. Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Site may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Site and the general public).
B. To Protect Us or Others
We may access, preserve, and disclose any personal 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 will also disclose personal information in conjunction with our duty to report Adverse Experiences that are reported to, or discovered by us, to relevant oversight authorities.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be disclosed, sold, or transferred as part of such a transaction, as permitted by law and/or contract.
5. Your privacy choices and rights
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
1. 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 you may not be able to opt out of non-promotional communications (e.g., communications regarding our Site or updates to our legal terms or this Privacy Policy).
2. “Do Not Track” / “Global Privacy Control.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. Please note that to fully exercise your rights, you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law and if we engage in relevant processing activities, you may have the right to:
1. 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; 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”);
2. 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;
3. Request Deletion of your personal information;
4. 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; and
5. Be Free of Discriminatory Treatment for exercising your rights to the extent that are conferred by applicable law.
Exercising Your Rights:
1. 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 as set forth in “Contact Us” above for additional instructions.
2. 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 Site.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below 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.
6. Security of your information
- 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 Site 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 Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Site, 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, one of the safeguards we may use to support such transfer is 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 Site, or as necessary to fulfill the purpose(s) for which it was collected, provide our Site, 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. Information of minors

Our Site is not directed to persons 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 believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. 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 (such as to protect our rights).
10. Third-party websites/applications

The Site may contain links to other websites/applications and other websites/applications may reference or link to our Site. 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

BioAge 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:

US residents please contact us at: privacy@bioagelabs.com
Residents of the European Union and United Kingdom, please contact us at: dpo@bioagelabs.com.
12. Notice at collection & supplemental notice for residents of certain U.S. States
- This Notice at Collection and Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and that apply to our Site and Product Development Activities (collectively, “Applicable State Laws”).
- We may have collected the following categories of personal information from you in the last 12 months: personal identifiers (e.g., name, postal address, unique personal identifiers, or other similar identifiers), protected classification characteristics under California or federal law, financial information, employment information, and internet or other electronic network activity information.
- Sensitive Personal Information. We may have also collected sensitive personal information from you, including details of health and disability, including medical information, health insurance information, and mental health in conjunction with your employment or if you reported an Adverse Event. Any processing of sensitive personal information is carried out exclusively for the purposes outlined above, to the extent permitted under law.
- Collection: 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 Site (for example, through cookies and other Technologies) from third parties (for example, from third-party referrals).
- Use: We use personal information we collect about you for the business purposes described above in the section titled, “How We Use Your Personal Information.”
- Disclosure: We may disclose your personal information to the parties described above in the section titled, “How We Disclose Your Personal Information.”
- Sale and Sharing: Your personal information is not (i) “sold” or (ii) “shared” (for purposes of targeted advertising) by us, nor do we have actual knowledge of any such activity involving the personal information of minors 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.