ADARx Pharmaceuticals – Privacy Notice for Applicants, Employees, and Contractors

Last Updated February 10, 2026

This Privacy Notice describes the practices of ADARx Pharmaceuticals, Inc. and its subsidiaries (“ADARx,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information relating to job applicants, current and former employees (including full-time staff, part-time staff, and interns), and contractors. This Privacy Notice does not apply to personal information of clinical trial participants or clinical site staff (including investigators), which is governed by separate privacy notices and clinical trial documentation. ADARx may also provide additional or supplemental privacy policies to individuals at the time we collect personal information.

Personal Information We Collect

Depending on your relationship with us and applicable law, we may receive and use the following categories of your personal information:

  • Contact information such as name, title, address, telephone number, and email address.
  • Biographical information such as date of birth, gender, marital status, dependents, and emergency contact information.
  • Financial information required for payroll and administrative purposes including insurance information, bank account details, payroll records, tax information, and wage garnishment records (such as for child support obligations).
  • Social security number or taxpayer ID information.
  • Compensation, reimbursement, annual leave, attendance, leave of absence information, pension, and benefits information.
  • Start date.
  • Termination information.
  • Proof of identity, including drivers’ license, passport, or other government-issued ID.
  • Classifications protected under state or federal laws (such as race or national origin), medical information, and veteran status (for mandatory reporting purposes only).
  • Employment records (including job titles, work history, working hours, holidays, training records, work authorization, and professional memberships).
  • Performance information.
  • Disciplinary and grievance information.
  • Information about your use of our information and communications systems, including the contents of communications sent using our systems.
  • Recruitment information, including copies of right to work documentation, references, other information included in a resume, CV or cover letter or as part of the application process, or results of a background or employment status check.
  • Sign-in and device Information, including username and password, account name or number, and other online or device identifiers, Internet or other electronic network activity information such as browsing and search history and information regarding interactions with websites and applications, our systems, and networks.
  • Location information.
  • Biometric Information, including fingerprint scans.

Where permitted by law, we may process limited special category data, such as information relating to health, disability, or diversity and equal opportunities monitoring. Such data is processed only where necessary, lawful, and subject to appropriate safeguards.

How We Collect or Receive Personal Information

We collect personal information about employees, contractors and job applicants through the application and recruitment process, directly from applicants and/or through a third party (such as a recruiter or a background check provider). We may sometimes collect additional information from third parties, including former employers and credit reference agencies. By applying for employment with us, you agree that we may collect personal information from third parties (for example, from recruiters, employment references, or from websites where you may have provided information about your work experience or interests).

We also collect personal information in the course of job-related activities during your employment with us.

How We Use Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

  • Recruitment and hiring. We may use personal information to assess candidate qualifications and suitability for roles; communicate with applicants; conduct interviews, assessments, and background checks; and make hiring decisions.
  • Employment administration. We may use personal information to manage the employment relationship; for payroll, benefits, equity, and expense administration; for performance management, training, and development; for record-keeping related to hiring and employment; and for workforce planning and internal reporting.
  • Compliance, security, and protection. We may use personal information to comply with legal and regulatory obligations; maintain workplace safety and security; protect our rights, property, and confidential information; and prevent fraud, misconduct, and unauthorized access.
  • Systems and operations. We may use personal information to provide and maintain recruitment and employment systems; troubleshoot audit, and improve internal processes; and create aggregated or de-identified analytics.
  • Timekeeping.  For hourly employees only, we use personal information, including biometric information (i.e., fingerprint scans), to verify your time entries.  Biometric information is not used for any other purpose.

Legal Bases. In the United Kingdom and European Union (“UK/EU”), the law requires us to have a legal basis for collecting and using your personal information. We rely on one or more of the following legal bases:

  • Contracts: We may process personal information to take steps in relation to your employment contract.
  • Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests. Before relying on this basis, we assess and balance the potential impact (both positive and negative) of the processing on you. We do not use your personal information for activities where our interests are outweighed by any adverse effect on you, unless we have your consent or are otherwise legally permitted to do so.
  • Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to.
  • Consent: We rely on consent where we have obtained your active agreement to collect and/or use your personal information for a specified purpose.

How We Disclose Personal Information

We may disclose personal information, including the categories of personal information described above, with the parties set out below and as otherwise described in this Privacy Notice, in other applicable notices, or at the time of collection. In the preceding 12 months, ADARx has not “sold” or “shared” personal information, as those terms are defined under applicable law.

  • Service providers. Third parties that provide services on our behalf or help us operate our business (such as IT, payroll, benefits, recruitment, and background check providers).
  • Third parties designated by you. We may disclose your personal information with third parties where you have instructed us or provided your consent to do so.
  • Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
  • Business transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in ADARx, financing of ADARx, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to disclose certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of ADARx as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your Rights

In this section, we describe the rights and choices available to all users.

Declining to provide information. We may need to collect personal information to assess your application or for employment purposes.  

Access, correction, or deletion requests. Subject to applicable laws in your jurisdiction, you may have the right to:

  • Access your personal information (commonly known as a data subject access request). You may request a copy of the personal information we hold about you, which third parties have received your personal information, and confirm that we are processing it lawfully.
  • Correct any incomplete or inaccurate personal information that we hold about you.
  • Erase or delete your personal information. You may ask us to delete or remove your personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).  We may retain some personal information to the extent permitted or required by applicable law.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) or where we are processing your personal information for direct marketing purposes.
  • Restrict the processing of your personal information. You may ask us to suspend the processing of personal information about you.
  • Transfer your personal information to another party. You may request that we transfer your personal information to you or to another organization, where it is technically feasible.
  • Appeal decisions made in response to a rights request.
  • Withdraw consent to processing, subject to any legal or contractual restrictions and reasonable notice.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact us at legalnotices@adarx.com. When contacting us, please provide your full name and email address and identify the right(s) you wish to exercise. Where permitted by applicable law, authorized agents may also make a request on your behalf by emailing us at legalnotices@adarx.com and providing both your full name and email address and the name and email address of the agent, evidence of the authority granted to the agent, and the specific rights being exercised.

We may not be able to fulfill your request in all instances. If we cannot fulfill a request, we will notify you and provide an explanation.

We may ask you for identifying information and attempt to match it to information that we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.

If you reside in the UK or EU, you also have the right to make a complaint at any time to your local UK/EU regulator, as applicable. In the UK, you may reach out to the Information Commissioner’s Office (ICO) with respect to data protection issues (see www.ico.org.uk).

We will not discriminate against you for exercising any of your applicable rights. We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects.

Security and Data Retention

We take reasonable steps, consistent with generally accepted industry standards, including technical, organizational and physical safeguards designed to protect the personal information we collect. However, as no system is fully secure against illegal tampering or “hacking”, security risks are inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, including:

  • Recruitment records in accordance with applicable limitation periods;
  • Employment records for the duration of employment and thereafter as required by law; and
  • Compliance records as required for legal or regulatory purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

International Data Transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Where we transfer your personal information internationally, we do so in accordance with applicable legal requirements and ensure that appropriate safeguards are in place to protect your personal information. You may contact us (see below) for further information about the safeguards we use when transferring personal information and where applicable, to obtain a copy of the relevant transfer mechanisms.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Material changes will be communicated through appropriate channels.

How to Contact Us