Last Updated February 10, 2026

This Privacy Policy describes the practices of ADARx Pharmaceuticals, Inc. and its subsidiaries (“ADARx,” “we“, “us” or “our“), regarding the collection, use, and disclosure of your personal information, including when you visit https://www.adarx.com (the “Site”), interact with our social media pages, and engage in other activities described in this Privacy Policy.

ADARx may provide additional or supplemental privacy policies to individuals at the time we collect personal information. In particular, this Privacy Policy does not apply to personal information of clinical trial participants or clinical site staff (including investigators) that we handle in connection with clinical trials. Our privacy practices in connection with clinical trials are governed by applicable clinical trial protocols and additional privacy notices that may be specific for each clinical trial.

If you have applied for employment with or are an employee of ADARx, please refer to our Privacy Notice for Applicants and Employees for information on our collection, use, and disclosure of your personal information.

Index

Personal Information We Collect

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses (including city, state, country of residence and postal code), phone number, and professional title and company name.
  • Communications data based on our exchanges with you, including when you contact us through the Site, social media, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Device/browser information, such as IP addresses, device type, browser information, and operating system.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Do not provide us with any health-related information (including any information regarding your past, present or future physical or mental health status).

How We Collect or Receive Your Personal Information

  • Information you provide to us when you use our Site, such as when you contact us.
  • From public sources, such as government agencies, public records, and other publicly available sources.
  • From partners, such as business partners.
  • From service providers that provide it on our behalf or help us operate the Site, our social media pages,or our business.
  • From transactional partners, in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

How We Use Your Personal Information

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

Operations. We may use your personal information to:

  • provide the Site;
  • enable security features of the Site;
  • communicate with you about the Site and our business, including by sending Site- or business-related announcements, updates, security alerts, and support and administrative messages; and
  • provide support for the Site and our business, and respond to your requests, questions and feedback.

Marketing. We, our service providers and our marketing partners may collect and use your personal information for marketing purposes. We may send you direct marketing communications based on interests or inquiries you provide to us. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce our terms and conditions; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We will not attempt to reidentify such de-identified and/or anonymized data. We may use this aggregated, de-identified and/or anonymized data and disclose it to third parties for our lawful business purposes, including analyzing and improving the Site and promoting our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which the information was collected.

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 process personal information to engage in transactions with customers, suppliers, and business partners.
  • Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to maintain the security of the Site and prevent fraud. 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, for example if you subscribe to an email newsletter.

How We Disclose Your Personal Information

We may disclose your personal information, including the categories of personal information described above, with the parties set out below and as otherwise described in this Privacy Policy, 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 the Site or our business (such as hosting, information technology, email delivery, marketing, consumer research and website analytics).

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 and Choices

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

Opt-out of communications. You may opt-out of marketing-related emails by following any opt-out or unsubscribe instructions at the bottom of any such email you have received from us, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive business-related and other non-marketing emails.

Blocking images/clear gifs.  Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We may need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services to you.

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 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.

Other Sites

The Site or our social media pages may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. It is your responsibility to read the privacy policies of the other websites and online services you use.

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 for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal information for a longer period if a complaint has been made or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 Transfer

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.

Our website may contain social media buttons or links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities that take place on those social media platforms or third-party websites.

Children

The Site and our social media pages are not intended for use by anyone under 18 years of age. We do not knowingly process personal information from individuals under 18 years old. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Site or our social media pages from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Site after the effective date of any modified Privacy Policy indicates your acknowledgement that the modified Privacy Policy applies to your interactions with the Site and our business.

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