For Washington residents, please visit our Consumer Health Data Privacy Policy to review our privacy practices related to your health data.

Trevi Therapeutics, Inc. (“Trevi,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with any interaction you have with us, including through our websites, mobile applications, social media pages, emails and other communications, offline activities, and other products and services (collectively, the “Services”), as well as in the course of our business, professional, research, and commercial relationships.

This Privacy Policy applies to personal information we collect from or about individuals who interact with us in any capacity in the ordinary course of business including patients, caregivers, healthcare professionals, research participants (outside of formal clinical trials), website visitors (at https://www.trevitherapeutics.com/ (the “Site”)), business contacts, consultants, vendors, contractors, investigators and other partners.

This Privacy Policy does not apply where another privacy notice is provided to you for a specific processing activity such as personal information collected as part of a clinical trial or other research study where a separate informed consent or privacy notice is provided, or to information governed by the Health Information Portability and Accountability Act and its implementing regulations (“HIPAA”) or other laws that may override the requirements of this Privacy Policy. Personal information collected under this Privacy Policy is not combined with data collected under clinical trial protocols, patient registries, or other IRB-approved research activities, which are governed by separate informed consent documents and applicable regulatory requirements. Trevi is not a HIPAA Covered Entity with respect to personal information collected under this Privacy Policy unless expressly stated otherwise.

By using the Services or otherwise interacting with us, you agree with our website’s Terms of Use and this Privacy Policy.

IF YOU DO NOT AGREE PLEASE DO NOT USE THE SERVICES OR PROVIDE US WITH YOUR INFORMATION.

Where permitted by law, this Privacy Policy may be incorporated by reference into agreements, statements of work, engagement letters, or other documentation between you and Trevi, and will govern our handling of personal information described in those documents unless expressly stated otherwise.

​1. Information We Collect. We collect personal information in a variety of ways, including when you use our Services, communicate or interact with us (online or offline), participate in our programs or research activities, enter into agreements with us, or otherwise engage with our business.

Information You Provide. You may provide personal information through registrations, applications, Site contact forms, surveys, contracts, onboarding processes, social media interactions, inquiries, purchases or participation in programs or clinical trials. This may include contact information, professional information, health-related information, insurance or financial information, or information related to patient support or assistance programs.

Cookies. We use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site 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 the Site 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 visiting the Site, and the link you used to leave the Site.  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 Site may not operate correctly.

Other Information Collected Automatically. We and our third-party partners (such as social media providers) may automatically collect information when you use the Services (such as our websites or other online services) through beacons, pixels, or similar technologies. This may include device identifiers, IP address, browser type, pages viewed, time spent, referring URLs, and interactions with content. Third parties may collect information across our websites and Services over time.

Information From Other Sources. We may supplement the personal information we have about you with information from public sources, professional directories, social media platforms, business partners, and service providers to verify credentials, confirm contact details, or support business operations. If you provide information about other people to us, you represent that you have the authority to do so.

Sensitive Personal Information. Certain information we collect may be considered sensitive personal information under applicable law, including health-related or safety-related information. We use and disclose such information only as permitted by law and for the purposes described in this Privacy Policy or as otherwise disclosed at the time of collection. Certain health-related information may be subject to additional protections under applicable law, even when not governed by HIPAA.

2. How We Use Your Information

We may use personal information:

• Based on our legitimate business interests, to:
  • Operate, maintain, and improve our Services and business;
  • Deliver our products and Services;
  • Process, complete and fulfill your requested transactions;
  • Support patient assistance, support, and engagement programs;
  • Communicate with you and respond to inquiries;
  • Conduct analytics, research, and quality improvement;
  • Protect our rights, safety and property.

• As necessary for the performance of (or steps prior to entering into) a contract, to:
  • Fulfill our contractual and transactional obligations;
  • Manage recruitment and employment-related processes.

If you do not provide us with your information in this context, we may not be able to comply with contract content or conclude a contract (e.g. employment contract following a recruitment process).

• As necessary to comply with legal, regulatory, and safety obligations. In particular, we can process your personal information to meet pharmacovigilance, product safety, and regulatory reporting obligations including adverse event reporting and product complaints.

• In connection with your authorization for such use, including:
  • providing you with newsletters, articles, alerts, announcements, invitations, and other information about products, brands, health topics and disease states (for educational purposes only and not as medical advice or promotion of unapproved uses.)
  • the use of cookies on the Site. For more information about cookies, please visit our cookie notice and the “Advertising” and “Analytics” sections below.

International Transfers. The information that we collect through or in connection with the Services may be transferred to and processed in the United States for the purposes described herein. We may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence.

The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By providing any personal or other information to us, you expressly consent (where permitted under applicable law) to such transfer and processing. Where applicable law does not permit us to rely on your consent to transfer your information abroad, and the recipient is not located in a country providing sufficient protection for your information, we will implement other appropriate safeguards to protect your data (such as Standard Contractual Clauses). If you are located in European Union or United Kingdom and would like more information about the transfer mechanism implemented, please contact our DPO (contact details below).

Pharmacovigilance and Regulatory Reporting. We process personal information to meet pharmacovigilance, product safety, and regulatory reporting obligations including adverse event reporting and product complaints. Information submitted for these purposes will be retained and reported as required by law and cannot be deleted upon request. Such information may be reported to regulatory authorities worldwide without further notice where required by law and certain privacy rights may not apply where processing is necessary for pharmacovigilance, patient safety, or regulatory compliance.

Advertising. The Site also enables third-party tracking mechanisms (e.g. cookies, web logs, web beacons) to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our Site to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Site to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Where these cookies are placed through the Site, you may also reject non-essential cookies via the Site cookie banner. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Our Site does not currently respond to “do not track” browser headers, except Global Privacy Control signals (see the “Your Privacy Rights” section below for additional details).

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 Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may reject non-essential cookies (such as analytics ones) via the Site cookie banner. You may also opt out of the use of cookies by Google Analytics here.

Aggregated or De-identified Information. We may aggregate or de-identify information about individuals who use the Services and use it for any lawful purpose. We do not attempt to re-identify de-identified data.

3. How We Share Information

We may share personal information with:

• Service providers and vendors;
• Affiliates;
• Third-party providers (e.g., social medias, third-party cookies providers);
• Research partners and clinical collaborators (where applicable);
• Regulators and government authorities;
• Professional advisors;
• Successors in corporate transactions;
• Law enforcement or courts where required or permitted by law.

We do not sell personal information for monetary consideration.

4. Updating Your Information

We want to be sure that we keep only the most accurate and up-to-date information about you in our records. Therefore, whenever you believe that your information needs to be updated, you can contact us to correct or update it. You may choose at any time to remove your name, telephone number and postal and e-mail addresses from the list we use to send notices or updates and elect not to receive correspondence from us by contacting us.

5. Your Privacy Rights

You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at Privacy@TreviTx.com.

If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:

• The right to access your personal information;
• The right to correct or amend any personal information we have on file about you;
• The right to delete your personal information;
• The right to limit the use of your “sensitive” personal information;
• The right to opt-out of the sale or “sharing” of your personal information;
• The right to opt-out of the use of your personal information for targeted advertising purposes;
• The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
• The right to restrict or opt-out of the use of your personal information for certain automated decision-making (including profiling in furtherance of decisions that produce legal or similarly significant effects);
• The right to revoke your consent (to the extent applicable);
• The right to confirm whether personal information about you is being processed;
• The right to request the receipt or the transfer to another organization, in a machine-readable form, of your personal information (right to portability);
• The right to obtain a list of specific third parties (or categories of third parties) to which we have disclosed your personal information or any personal information.

To exercise any of these rights, please contact us via email at Privacy@TreviTx.com. We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. We will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to Privacy@TreviTx.com with the subject line “Appeal of Decision Related to Privacy Rights Request.”

Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you.

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

If you are located in specific jurisdictions (such as the European Union or United Kingdom), you may also have the right to lodge a complaint with the competent Supervisory Authority, if you consider that your personal data is not processed in accordance with data protection law and this Privacy Policy.

If you have implemented a Global Privacy Control (GPC) signal on your browser or device, we will treat that GPC signal as a valid request to exercise the opt-out rights available to you under your jurisdiction’s privacy law(s). Once we recognize the opt-out preference signal on our Services, we will automatically apply your right to opt-out to the browser or device through which we recognize the signal. The Services respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized). To learn more about opt-out preference signals, please visit https://globalprivacycontrol.org/.

6. Social Media

​Responsibility for Your Content

You are responsible for any content that you post on our social channels or in the comments. Only post content that is original and that you have the right to post. Trevi is not responsible for any content posted by you and has no duty or obligation to monitor the content. Using information provided by other users is at your own risk. We reserve the right to monitor, review, edit, remove, and delete user content, as well as disable, refuse, restrict, or terminate access to our social media channels at our sole discretion, with or without notice.

Social media is a public forum – do not share any sensitive or personal information in the comments or posts on our pages. Content posted on our social media channels may be reviewed for pharmacovigilance purposes, including identification and reporting of adverse events as required by law.

We Will Remove Any Content That:

• Mentions us or our products in a manner which is defamatory, non-compliant with regulatory approvals, or mentions products of other companies;
• Infringes on our, or any third party’s, intellectual property rights;
• Violates a third party’s right to privacy;
• Is inappropriate, vulgar, degrading, abusive, harassing, profane, or violent;
• Constitutes spam;
• Violates any applicable law or advocates illegal activity; or
• Violates the terms of use of any social media platform.

Health Issues

Social media and websites are not an appropriate place to resolve issues, complaints, suggestions, or experiences with your healthcare. If you have any questions or concerns about your health, you should consult your physician, pharmacist, or other healthcare professional.

Information shared on our social media channels that relates to adverse events, product complaints, or patient safety may be retained and reported to regulatory authorities as required by law, even if the content is later removed or deleted.

7. Data Integrity and Security

We take reasonable steps to protect your personally identifiable information as you transmit your information to us  and to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. We implement reasonable administrative, technical, and physical safeguards designed to protect personal information. You should keep in mind, however, that no Internet transmission is ever 100% secure or error free. In particular, e-mail may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. Regulatory, safety, and audit records may be retained for longer periods than other personal information due to our legal obligations.

9. Children

Our website and the Services are not directed at children under 18 and we do not knowingly collect personal information from children under 18.

10. Future Updates

We may update this Privacy Policy from time to time. Changes will be posted on this page.

11. Contact Us

You may contact us by emailing us at Privacy@TreviTx.com or by mailing us at:

Trevi Therapeutics, Inc.

195 Church Street, Floor 16

New Haven, CT 06510

Under EU Data Protection Laws, Trevi is considered as the Controller for the processing of your information, as described in this Privacy Policy.

Contact details of Trevi’s Data Protection Officer (“DPO”) are trevi.dpo@mydata-trust.info.

Contact details of Trevi’s Data Protection Representative (“DPR”) are:

In the United Kingdom: MyData-TRUST LTD, Belmont Building, Belmont Road – Uxbridge, UB8 1HE, United Kingdom; trevi.dpr@mydata-trust.info

In European Union: MyData-TRUST SA, Avenue Lavoisier 18B, 1300 Wavre, Belgium; trevi.dpr@mydata-trust.info