Last Revision Date: April 29, 2009

Introduction

Below is the website privacy policy (“Privacy Policy”) of Acura Pharmaceuticals, Inc. (“Acura”, “we”, or “us”). It applies only to our website. It is the Privacy Policy referred to in the terms and Conditions.   It does not apply to activities that occur offline or to information we collect outside of our website. Except as set forth in the paragraph under the heading “Use and Disclosure of Information” below and under the heading “Confidentiality and Privacy” in the Terms and Conditions it also does not apply to e-mails that you send us, including emails that you send by clicking a link on the “Company Contacts” page or other pages of our website.

Use of Personal Data

Our website does not collect any personal information from the viewer. This allows you to visit without telling us who you are. We will not sell, share with, or otherwise distribute personally identifiable information to third parties. To the extent a directly linked website provides us information it collects we will also not sell, share, or otherwise distribute that personally identifiable Information to third parties.

Use of Cookies and Other Tracking Systems

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you’ve visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other websites. Acura  does directly use cookies to track user traffic patterns, this website does utilize third-party software to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information.  If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. Acura also may use pixel tags which is a type of graphic that often appears invisible due to its small size. It may be used to track number of users at our website and the navigation through our website.  We do not use this data to track personally identifiable information.  We may also collect IP addresses of persons visiting our website. We may use IP address to aggregate information about the number of visitors to our website, website usage and the general locations from where our website is accessed.  We do not generally use IP addresses to track personally identifiable information.  We reserve the right to use IP addresses to identify persons who abuse or threaten our site, directors, employees, or customers.  We may also use other tracking technologies, but do not intend to use such technologies to collect personally identifiable information.  Notwithstanding any of our policies, we may be required to disclose any data we collect, including IP addresses, by a court order, subpoena or other legal process. In addition, we cannot be held responsible for, and our Privacy Policy does not apply to, the tracking systems of other websites to which we link.

Use and Disclosure of Information

As provided in the Terms and Conditions and except as otherwise noted in this Privacy Policy or the Terms and Conditions, we may use any information you provide to improve the content of our website, customize the website, communicate information to you (if you have requested it), for our marketing and research and development purposes, and for other purposes specified in this Privacy Policy or the Terms and Conditions or at the time such information is requested from you.

Links to Other Sites

This Privacy Policy applies only to our website. We may provide links to other websites that we believe may be of interest to our visitors or advertisers may have links on our website.  Their websites may collect personally identifiable information from you.   For instance, we provide links to websites that display webcasts of some of our investor presentations. These websites may ask for your name, relationship to Acura, profession, company email address, and other information.  You should review the privacy policy of these websites before providing such information, as these websites are not covered by our Privacy Policy.  Due to the nature of the World Wide Web, we cannot guarantee the standards of websites to which we link or advertiser’s website or be responsible for the contents, or privacy practices and policies, of these and other third-party sites.  We encourage you to read the privacy policy of every website you visit.

Changes to this Privacy Policy

This policy may be revised by us from time to time.  By using this site you agree that we have a right to change our policy without prior notification.  The revised policy will appear on our website with the date of last revision.

Privacy of Children

Our website is not intended for use by children under age 13.  We will not knowingly collect personally identifiable information on our website from children under 13.

Use of Our Website

Use of our website is subject to the Terms and Conditions.