Privacy Policy

Last Updated: October 14, 2025

Effective Date: October 14, 2025

This Privacy Policy (“Policy”) describes the policies of Phagenesis Inc. (”Phagenesis”) on the collection, use, and disclosure of personal information that we collect when you use our website(s) where this Policy is posted (the “Site”) and our services that link to or reference this Policy (the “Services”). We conduct business within the United States (“U.S.”), United Kingdom (“UK”), European Union (“EU”), and the European Economic Area (“EEA”). We are committed to protecting and respecting your privacy.

This Policy does not apply to third-party platforms or to other Phagenesis Inc.-operated websites or other Phagenesis-operated platforms on which it is not posted. It also does not apply to information collected through other channels where this Policy is not linked to or referenced, such as through a clinical study. By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service. Where applicable, you may make a request to withdraw your consent to the collection, use, disclosure, and transfer of your information as described in this Policy (including any Privacy Notices that apply to you) by contacting us directly.

Some of the information we collect through this Site and our Services may be “Personal Information” as defined below, collected when you visit or use the Site or the Services.

This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those particular pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.

If you have a disability, you may request access to this Policy in an alternative format by contacting [email protected].

Among other things, this Policy describes:

What information we collect about you
How and on what basis we use the information we collect
How we collect your Personal Information
How long we keep your Personal Information
How we share the information we collect
How we protect your information
How you can access and control your information
How you can contact us

Regional provisions:

Consumer Health Data (U.S.)
California Residents
Nevada Residents

Complete Agreement

This Policy is part of the Terms of Use that govern your use of the Site and the Services. Except as written in any other disclaimers, policies, or other notices in connection with the Services, this Policy and the Terms of Use are the complete agreement between you and Phagenesis with respect to your use of this Site and the Services. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials on or sections of this Site and the Services.

Changes to this Policy

Phagenesis reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site.

Your use of the Site or the Services following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of the public areas of this Site. We recommend periodically reviewing this Policy for updates.

This Policy was last updated on October 14th, 2025. The update included a complete revision of the Policy, including more details about how we collect and use Personal Information and your privacy rights.

What is Personal Information?

Personal Information means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1. How do we collect your Personal Information?

How we collect Personal Information will depend upon the nature of your dealings with us. We collect and use non-Personal Information differently from Personal Information. Whenever it is reasonable and practical to do so, we will collect your Personal Information directly from you. We may also collect Personal Information from third parties, including in the course of providing products to you such as from our distributors, your healthcare practitioners, your caregiver/family member, guardian, publicly available information and databases supplied by third parties.

If you are one of our suppliers, distributors or a healthcare professional that uses our products, your Personal Information may be collected from you, your employer, other employees, or third parties. Similarly, if you are a prospective employee, we may collect information through third parties such as recruiters.
If you choose not to provide some Personal Information to us, this may affect our ability to provide products or services to you.

2. Information We Collect:

Generally, Personal Data we collect may include but is not limited to:

Name and contact details
Details of your company, industry, role and accreditations
Information from your visits to our websites, including the IP address, type of browser, device (including unique device identifiers) and operating system you use, network information, access times, pages viewed, links clicked on, cookie information;
Details of products you have inquired about or that we have supplied to you, including any additional information necessary to deliver those products and to respond to your inquiries;
Credit information, payment, credit card and debit card or bank account information for product deposits, purchases or refunds;
Information that you provide to us directly through one of our websites, apps or that you email to use; and
Information you provide in customer surveys, interviews or case studies.

Product User Data

If you are a someone who uses our products, including clinical trial participants: we may collect additional specific information about your use of our products and you, such as your gender, date of birth, your medical history and conditions, treatment, device information, family and social history, medical inquiries you or your physician make, and adverse events you report. We may receive some of this information from third parties, such as our distributors or your health care professional. Some of this information may be, but is not always, anonymized, or de-identified. If you are a clinical trial participant, this Policy is not applicable to your clinical trial. Trial information will be used in accordance with the informed consent, any applicable trial privacy notices, and applicable law.

Suppliers, Customers or Other External Stakeholder Data

If you are a supplier, customer, distributor, or a healthcare professional that implants our products: we may collect additional specific information including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and your dealings with us.

If you are an employee, contractor or applicant: we may collect additional specific information including your gender, date of birth, contact details, information collected in our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or history. We may receive some of this information from third parties such as recruiters or from reference checks.

Personal Data You Manually Provide through this Site

Phagenesis collects the information you manually provide (e.g., using your keyboard, mouse, or touchscreen) when you use this Site. For example, we collect the information you provide if you choose to complete a pre-screening questionnaire entitled, “Am I a Candidate?” or similar questionnaire, contact us with questions, or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Data including but not limited to:

Contact data: such as name, title, address, phone number, mailing address, and email.
Other identifiers: such as device ID or serial number, various types of personal health information (e.g., health insurance information, medical information, and the like), online identifiers, and other similar identifiers.
Communication data submitted by you: such as questions and feedback.
Demographic data: such as language, age, and gender.
Marketing preferences: such as e-mail subscription and frequency preferences.

Information Automatically Collected through this Site

Phagenesis collects information through this Site that is sent to us automatically by your web browser or mobile device. This information may include but is not limited to:

Product use and application data (including date and time of your visit)
IP address
The browser you are using (including name and version)
Your location and other geographic data
The website you came from and the website you visit after leaving
Pages viewed on the Site
Links clicked on the Sit
Time spent on a particular page of the Site or the Site as a whole
Site data used to facilitate the use of the Site such as login and technical data

The information we receive may depend on your browser or device settings as well as your cookie settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information that either does, or may, identify you.

Information Collected by Cookies and Other Technologies through this Site

We use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

Collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
Support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits
Personalize your experience when you use this Site; and
Improve our marketing efforts, including through use of targeted advertising.

The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Data that you provide. If you do not wish to receive cookies, you may choose to reject cookies in your cookie settings when you visit our Site. You may also set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if you or your browser rejects cookies.

Information Collected by Third-Party Cookies through this Site

In addition to the cookies Phagenesis delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Sites.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on our Sites. You may use the cookie pop-up banner on the Site to decline non-essential cookies. Additionally, you may download an Opt-out Browser Add-on to opt-out of Google Analytics by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.

You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

3. How We Use Your Information:

We may use the information we collect through this Site for various purposes, including but not limited to:

When needed for our legitimate interests:
- To provide you with access to this Site.
- To respond to your requests.
- To personalize your access to our Site.
- To develop records (including records of your Personal Data) such as to enable you to create an account (such as a physician e-learning account) or request information from us.
- To oversee and appropriately manage, maintain, and secure this Site and our Services.
When you give your consent:
- To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others.
For analytical purposes and to research, develop, and improve programs, products, services, and content.
To remove your personal identifiers. Once we have de-identified information, it may be considered non-Personal Data and if so we may treat it like other non-Personal Data.
To enforce this Policy and other rules about your use of this Site.
To protect someone’s health, safety, or welfare.
To protect our rights or property.
To comply with a law or regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

Collected through our Services

Generally, the purpose for which we collect Personal Data will be apparent from the way in which we collect it or will be disclosed before or at the time of collection. We may use your information, including Personal Data to:

Provide patients and health care professionals with product support.
Respond to and fulfill queries and requests from patients, healthcare professionals, and our distributors and suppliers.
Administer, improve and promote our products.
To personalize your access to our Services, for example, by telling you about new features that may be of interest to you, or to the extent you set up an account, to allow you to properly use that account, as well as administer any Services.
Analyze the performance of our products.
Improve our services and services of our third-party suppliers and distributors.
Monitor the safety of our products and record, analyze and respond to and act on medical queries, complaints and safety reports and to report as required to regulatory bodies and other relevant companies which market and sell our products.
Notify you of matters concerning the safety of our products which we consider you should be notified of or to notify you as may be required by law or regulation.
Generate and maintain customer lists for the purposes of our own market research and to enable us or our distributors to undertake marketing to you and others.
Perform clinical trials and other research organized by us which you have agreed to be involved in.
Administer patient support, health awareness/management programs or other similar programs organized by us.
Organize and administer conferences, symposia, seminars or other events and meetings.
Generate and maintain our investor information to comply with legal requirements and to enable reporting to investors.
Provide you with information such as our press releases.
To maintain our register of shareholders and investor communication lists and to make offers and communicate with our shareholders and investors.
Comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements and ethical requirements including to comply with demands or requests made by regulators, governments, courts and law enforcement authorities.

4. Our Legal Basis for Processing Personal Data (EU/EEA/UK Residents Only)

We may process the Personal Data we collect/receive under the following legal bases:

Legitimate interest. We can process your Personal Data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. We will use your personal data in order to help us provide you with our services and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
Consent. In some cases we will only process your information where you have given your consent. For example, if you sign up for email communications, provide your phone number for phone communication, or where you may be providing special categories of personal data (or “sensitive data”). Please note that we may have a different legal basis for processing (e.g., legitimate interest) so that consent is not needed. When our use and sharing is not readily apparent when you provide your information, we will provide additional information at the time we collect the information regarding our purposes and use of the information.
To fulfill our obligations to you under a contract. If you purchase a product from us, we may process your personal data in order to fulfill our contract with you.
As required by law. Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud.

Examples of the legal basis we may rely on when processing your Personal Data and how they apply are contained in the chart below:

Lawful Basis	Purpose of Processing	Types of Personal Data
Legitimate Interest We process Personal Data when we have a genuine and legitimate reason and are not harming any of your rights and interests	To respond to your requests, provide services (including providing and managing our physician e-learning platform) and appropriate information, and improve our products and services	– First and last name – Internet identifiers such as IP address, type of browser and other identifiers or details -Contact information including e-mail addressInformation you provide us directly through our websites, apps or e-mails – Responses to surveys, interviews, case studies – Information you provide to create accounts with us
Consent Process information where you have given your consent	Sign up for e-mail or phone communications	– First and last name – Internet identifiers – Contact information including name and e-mail address
	To provide patient education services or patient support	– First and last name – Contact information including e-mail address – Health-related information you provide including diagnoses and symptoms
Contract We process Personal Data to fulfill our contract with you.	To fulfill our contractual obligations for product purchase agreements or other agreements with you	– First and last name – Payment information such as credit, debit, or bank account information – Contact information including e-mail address and postal address – Other details as specified by or relevant to the applicable contract
Legal Obligation We process Personal Data as reasonable and necessary to fulfill our legal obligations.	To support fraud prevention, prevent and detect crimes, and establish and defend legal rights	– First and last name – Contact information – Internet identifiers such as IP address – Account information such as user ID, password, usage information or other details
	Support product safety	– First and last name – Contact information including e-mail address – Details about potential adverse events including medical information as needed
	To respond to requests from you under applicable privacy laws	– Contact information – Verification details as needed

5. How We Share Your Information:

Phagenesis will not share Personal Information about you collected from this website with an unrelated third party except as provided in this Policy. We may share for the following purposes.

With Third–Party Vendors

Phagenesis shares information collected through this Site and the Services with third-party vendors who act for us or on our behalf. For example, we may use third-party vendors to design and operate this Site and the Services; to conduct surveys and clinical studies; and to help us with our promotional efforts (such as to operate our Mobile Messaging Program as described below). These third-party vendors may need information about you to perform their functions on our behalf. In general, we require our third-party service providers and vendors to restrict their use of any personally identifiable information received through our Site or the Services to the intended purposes.

With Third-Party Social Media Platforms

We may also use third-party social media platforms to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by platform vendors with a user on their platform. Although we do not provide any directly identifiable Personal Information to these platform vendors, they may gain insights about individuals who respond to the ads we serve.

In Aggregate or De-Identified Form

We use information collected through this Site and Services to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties for various purposes including so they can better understand our user base. We may also share with third parties information about how particular individuals use this Site and the Services, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site or Services user, as opposed to Site or Services users collectively. For clarity, we may use and share aggregated or de-identified data without restriction.

As Part of a Business Transfer

Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site or the Services to another organization or if we merge with another organization or liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply with Laws and Protect Our Rights and the Rights of Others

We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site or the Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As Described in a Privacy Notice or Click-Through Agreement

We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site or provided in connection with the Services where you provide that information. By providing your information on that page you will be agreeing to or consenting to the use and disclosure of your information as described in that privacy notice. We also reserve the right to disclose your information as described in any click–through agreement to which you have agreed.

If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

6. Retention Of Your Information:

We will always keep Personal Information for the period required to comply with or demonstrate compliance with: applicable laws, legal orders, requirements having the authority of law, regulations, guidance, codes of conduct, product approvals, license requirements, ethical and safety requirements. We may also maintain your information as required to comply with any contract of which we are a party.

Otherwise, we keep your Personal Data:

For as long as needed to provide you with access to product and longer to assist us in best addressing any safety matters that may arise with respect to our products.
Where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request, plus up to two (2) years for our record-keeping purposes.

7. Children’s Privacy

This Site is not targeted to children under the age of 18 and we do not knowingly collect or solicit Personal Information about such children. If we discover that a child has provided us with Personal Information online through this Website, we will take steps to delete this information as quickly as possible. If you believe we may have received Personal Information from a child under the age of 18, please contact us immediately.

8. Marketing E-mail Opt-out

We may contact you to provide information about products, services and content that may be of interest to you. You may revoke your consent for the receipt of marketing communications that we send to you at any time by using the “unsubscribe” functionality included in our emails to you or by contacting us directly.

You should note that this will not affect all communications from us, for example, we are legally required to provide notices such as notification of a data breach in which case you should expect to receive a notification via email. We may also communicate with you for business purposes including to respond to communications from you, such as if you submit an online form on our Site or through our Services.

9. Data Subject Rights

Your rights will vary depending on which laws apply, and different laws may apply depending on where or your data is located. You may make a request to exercise any rights that you may have, and we will comply with any laws that apply. You may have the following rights:

Know. You may have the right to know about and confirm the existence of Personal Information about you, how we use or share it, what categories of Personal Information we process, our purposes of processing, and categories of parties we disclosed Personal Information to.
Access and portability. You may have the right to access your Personal Information, specific pieces of information, and know of third parties Personal Information was disclosed. You may have a right to obtain a copy of your data, including in a machine-readable format or have it transferred to someone else.
Correction. You may have the right to correct or amend your data if it is incomplete, inaccurate, or outdated.
Deletion or elimination. You may have the right to request your Personal Information be deleted or eliminated. Subject to applicable law, we may de-identify this data in certain circumstances.
Restriction. You may have a right to restrict processing of your data in some circumstances, such as if processing is excessive or unlawful, the accuracy of the data is contested, the controller no longer needs the data for its primary processing purposes but is needed for legal or compliance purposes, or if the data is sensitive Personal Information (e.g., health information) and it is being used for purposes beyond those reasonably necessary to perform services or provide goods requested.
Objection and opt–out. You may have the right to object to or opt-out of processing of Personal Information about you in certain circumstances. This can include cases where that data is used for direct marketing (including email or telephonic marketing), shared with third parties for their own marketing or for retargeting or cross-contextual marketing, sold to third parties, used to make certain automated or artificially-generated decisions or profiles about you, used for historical or scientific research, or used to contact you with automated/prerecorded voice telephonic messages in some cases.
Consent and cancelation of consent. You may have the right to consent, and to withhold or cancel that consent, for some practices, including processing of sensitive Personal Information (such as health information) or data on children, or where we use consent as our lawful basis for processing or transfer. If you cancel your consent, we will not further collect or process the Personal Information on the basis of that consent unless allowed or required by applicable law.
Non–discrimination. We will not discriminate against you for exercising your rights. This does not necessarily include, where permitted by applicable law in your jurisdiction, cases where a difference in price or services offered is reasonably related to the value provided by Personal Information you provide, or where you consent to participate in a voluntary program offering incentives (such as a loyalty program).
Appeal. You may have the right to appeal decisions we make about the exercise of your rights. To submit an appeal to a decision we made about the exercise of your rights, you may send an email to [email protected]. Please enclose a copy, or otherwise specifically reference our decision on your data subject request, to allow us to address your appeal. We will strive to comply with applicable law when we respond to your appeal.
Make a complaint. You may have the right to complain to regulators, such as your state attorney general, local data protection agency or authority, or other public bodies responsible for data protection and privacy enforcement, if you are not satisfied with our response to your request or if you have concerns about our data practices. For more information, if you are in the EU, EEA, or UK, you can also contact your local Supervisory Authority.

Submitting a Request or Inquiry

If you want to submit a request or inquiry to us regarding privacy rights you may have, you or your authorized agent (someone acting on your behalf) can contact us using our contact information below. You do not have to create an account with us to submit a request.
Your request will be confirmed within ten days of receipt and we will respond within 45 days, unless shorter periods are required by law. If we need more than 45 days, we will notify you that your request is being delayed.
We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. In the process of verifying your request, we may contact you to ask for additional information that will help us do so, including government-issued IDs containing your name and address, utility bills containing that same information, and/or unique identifiers like usernames. We will only use that additional information in the verification process, and not for any other purpose. Once we have received and verified the requested information from you, we will contact you with our response to your request, including any data, if applicable. If we do not hear from you or are unable to verify your identity for the request, we will contact you to inform you that we cannot process your request because we cannot verify your identity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.
There may be times where we cannot comply with your request. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide an explanation for our refusal to grant access.
Residents of WA, CA, NV, CT, please also see the respective Addendums for further details.

10. How We Protect Your Information

Phagenesis takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.

11. Transfer and Storage of Your Personal Information

We may store, collect, transfer, and process your Personal Information in the United States, European Union, or United Kingdom. Some relevant privacy and data protection laws may be different than your country. By submitting your Personal Information, you agree to and acknowledge such transfers, storage, and processing, including onward transfers.

The European Commission and the UK Information Commissioner’s Office (ICO), have the power to determine, based on the General Data Protection Regulation (“GDPR”) or UK GDPR respectively, whether a country offers an adequate level of data protection by making an ‘adequacy decision’. With respect to any transfers of information to the United States, we will implement appropriate measures to protect and secure your Personal Data when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws, including in the case of EU residents, with your consent, through adequacy frameworks, or through the use of approved model standard contractual clauses along with supplementary measures, where determined appropriate. The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses along with supplementary measures provides for an adequate level of protection of your Personal Data. Similarly, the UK has adopted International Data Transfer Agreements. Under these standardized agreements, you have similar rights as if your Personal Data was not transferred.

You may request more information about our data transfer practices by contacting us.

12. Third Party Links & Use Of Your Information:

This Policy applies only to the Phagenesis-operated websites on which it is posted and the Services to which it is linked or where it is referenced. Phagenesis and its affiliates may operate different websites for different purposes and in different countries, where different laws may apply. If you visit another website, including a Phagenesis website, please take a moment to review the privacy policy posted on that site to learn what information may be collected through that site and how it is processed. This Site may also contain links to websites that are not operated by or on behalf of Phagenesis or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. Phagenesis does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.

13. Contact Us / Privacy Inquiries:

If you have any requests, queries, or concerns about the processing of your information that is available with us, you may contact us using the information below. We will address your concerns in accordance with applicable law.

Data Protection Officer/Privacy Inquiries

Postal address: Data Protection Officer

Phagenesis Inc., Unit 18 Enterprise House, Manchester Science Park, Manchester M15 6SE, United Kingdom

E-mail: [email protected]

Addendum: California Residents

“Do Not Track” Policy for California Online Privacy Protection Act (CalOPPA)

Our Site does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California’s Shine the Light law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes. We do not share Personal Information for third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Policy.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided in this Policy and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Addendum: Nevada Opt-Out Rights

Your Nevada Opt-Out Rights

We do not sell your Personal Information, but nevertheless we offer an opt out to sales of consumer data in an overabundance of caution as required by, and to ensure compliance with, Nevada law. Verified requests under Nevada law (NRS 603A) to not make any sale of any covered information we have collected or will collect regarding a consumer, as defined in that law, may be sent to [email protected]. Please include in any such request email “Request for Nevada Opt-Out” in the subject line and in the body of the message.

Addendum: Consumer Health Data Policy

(including Washington, Nevada, Connecticut)

Various U.S. state laws provide protections for “consumer health data”. This addendum applies to such information by applicable law. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

“Consumer Health Data” is used in this addendum as it is defined in the Washington My Health My Data Act (MHMDA) and other laws applicable to the same or similar data. It generally includes any information that is linked or reasonably linkable to an individual and that identifies that individual’s past, present, or future physical or mental health status. Excluded from Consumer Health Data are certain types of health information, such as when we must collect, use, and disclose health information to meet our regulatory obligations or as part of a clinical trial. We do not collect, share, or sell Consumer Health Data except as described in this Privacy Policy and this Addendum or with your consent.

Categories of Consumer Health Data We Collect and Share

We process limited Consumer Health Data and may collect Consumer Health Data from various categories including, individual health conditions, treatment, diseases, or diagnosis; dynamics interventions, health-related surgeries or procedures; use or purchase of prescribed medication; bodily functions, vital signs and symptoms; diagnoses or diagnostic testing, treatment, or medication; genetic data; precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies (i.e., geofencing); and data that identifies a consumer seeking health care services.

Sources of Consumer Health Data

We collect Consumer Health Data directly from you, including when you submit information through our website, or other services or platforms we operate.

How Phagenesis Uses Consumer Health Data

We use consumer health data to provide consumers information and education about Phagenesis’s products and help connect them to a provider that can provide them diagnosis and treatment options.

How Phagenesis May Share Consumer Health Data

We may share Consumer Health Data, including the categories of Consumer Health Data, with Phagenesis-affiliated companies, service providers acting on our behalf, and others, including health care providers that you select, as necessary to provide you with the products or services you request or your authorized representatives request on your behalf.

Exercising Your Rights

Based on applicable laws in your state, you may have the right to:

Confirm whether Phagenesis is collecting, sharing, or selling Consumer Health Data concerning you and to access this data, including:
- A list of all third parties and affiliates with or to whom Phagenesis has shared or sold the Consumer Health Data
- Access an active email address or other online mechanism that you may use to contact these third parties
Withdraw consent from Phagenesis to collect and share your consumer health data
Request to have Consumer Health Data concerning you deleted and exercise that right by informing Phagenesis of your request for deletion
Appeal if Phagenesis does not address an attempt to exercise one or more of these rights to your satisfaction

You may request that Phagenesis take the actions outlined in the paragraphs above to exercise rights you may have by submitting a request, at any time, to Phagenesis. Phagenesis will seek to respond within forty-five (45) days.

P005I Revision 1