ADARx Clinical Trial-Related Website Privacy Notice

Last Updated March 30, 2026

ADARx Pharmaceuticals, Inc. (“ADARx,” “we”, “us” or “our”) sponsors clinical trials. This Privacy Notice describes our practices regarding the collection, use, and disclosure of your personal information when you visit a site that includes or links to this Privacy Notice (collectively, the “Site”) or engage in other activities described in this Privacy Notice.

ADARx, its service providers, or business partners may provide additional or supplemental privacy policies to individuals at the time we or they collect personal information, including in relation to active participation in any clinical trials.

Table of Contents

Personal Information We Collect
How We Collect or Receive Your Personal Information
How We Use Your Personal Information
How We Disclose Your Personal Information
Your Rights and Choices
Other Sites
Security and Data Retention
International Data Transfer
Children
Changes to this Privacy Notice
How to Contact Us

Personal Information We Collect

We may collect the following categories of personal information depending on how you interact with the Site, your jurisdiction, and as permitted or required by applicable law:

  • Contact data, such as your first and last name, email address, postal address, zip code, phone number, professional title and company name, password, username, or other information you provide when creating a clinical trial portal account or otherwise registering for the Site.
  • Communications data, such as information about, and the contents of, your exchanges with us, including when you complete a form on the Site or otherwise contact us through the Site.
  • Screening data,such as health data, insurance data, government-issued identification information (e.g., driver’s license), citizenship, citizenship status or immigration status, age, race, ancestry, marital status, medical diagnoses, medical conditions, prescriptions, treatments, surgeries, procedures or medications, physical or mental disability, sex, pregnancy or childbirth history/status or sexual orientation, and other information collected to assess the eligibility or qualification for a clinical trial (including frequency of clinical trial participation and contact).
  • Training records, such as certifications of completion for trainings.
  • Device/browser information/analytics data, such as IP addresses, device type, browser information, operating system, and analytics data, such as browsing actions and patterns, the time of the visit and the page(s) visited, information regarding your search queries on the Site, traffic on the Site, metadata, and other user actions and details.
  • Other data not specifically listed here, which we will collect and use as described in this Privacy Notice, as otherwise disclosed at the time of collection, or as otherwise required or permitted by law.

How We Collect or Receive Your Personal Information

We may collect personal information from the following sources:

  • Directly from you, when you use our Site, such as when you contact us, or when you otherwise provide information to us.
  • From service providers and business partners, such as entities that help support the patient recruitment process or that help us operate the Site or conduct a clinical trial, or marketing or analytics partners that provide statistics or analysis about how people are using the Site.
  • From tracking technologies that may automatically collect information about you when you visit the Site. Further information about how we use cookies and how you can exercise your choices related to cookies can be found in the cookie management tool, which you can navigate to by clicking on the cookie notice in the footer of the site or “Customize” from the cookie banner, or otherwise made available on the Site.
  • 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, 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:
    • inform and educate you about a clinical trial, and provide you with information about how to pre-qualify and/or contact a study site, or to otherwise market or promote a clinical trial to you;
    • find potential participants for a clinical trial, which may include processing potential participant personal information for qualification, pre-screening, and enrollment (including assignment to a research site);
    • communicate or facilitate communication between research sites, including research site staff and principal investigators, or other parties involved in trial activities on behalf of clinical trial sponsor(s) regarding the potential participant’s eligibility and/or enrollment;
    • communicate with you, including responding to your questions or registering you, with your consent, to receive emails or other information or materials;
    • support recruitment, participation in, and running of a clinical trial, including receiving feedback on the Site or a clinical trial;
    • plan, organize, and review the research we perform; and
    • provide the Site and monitor Site usage analytics.
  • 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, including regulatory (including medical and safety), tax, accounting or reporting requirements;
    • 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 from personal information we collect from other individuals. We make personal information into aggregate, de-identified and/or anonymized data by removing information that makes the data identifiable to you. We will not attempt to re-identify such aggregate, de-identified and/or anonymized data. We may use this aggregated, de-identified and/or anonymized data and disclose it to third parties for lawful business purposes, including analyzing and improving the Site.
  • 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 such uses 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. Depending on your relationship with us, we rely on one or more of the following legal bases:

  • Contracts: We process personal information to fulfill our contracts with you, such as to provide you with the Site or to engage in transactions with our business partners to allow you to learn about or participate in the clinical trial.
  • 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 to which we are subject.
  • 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, to the parties set out below and for the purposes described in this Privacy Notice, and as otherwise described 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, and ADARx does not have knowledge that we “sell” or “share” the personal information of users under 16 years of age.

  • Service providers and other business partners. We may disclose your personal information to third parties that provide services on our behalf or that help us operate the Site or our business (such as conducting or operating our clinical trials, or providing us hosting, information technology, email delivery, marketing, consumer research and website analytics services). This includes entities such as Contract Research Organizations, Contract Commercial Organizations, and IT service suppliers.
  • Third parties designated by you. We may disclose your personal information to third parties where you have instructed us or provided your consent to do so.
  • Regulatory Authorities. We may disclose your personal information to regulatory authorities, such as the U.S. Food and Drug Administration, as necessary or appropriate for the purposes described above in “How We Use Your Personal Information ”, including in relation to medical regulation and safety reporting, or as disclosed at the time of collection.
  • Business transactions. We may disclose your 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 to 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.
  • Affiliates. We may disclose your personal information to our affiliates or otherwise within our corporate group.

Your Rights and Choices

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 carry out certain activities. If you do not provide the information we identify as required or mandatory, we may not be able to carry out certain activities and/or provide the Site, and you may not be able to participate in the clinical trial.

Privacy Rights. If you reside in certain states within the United States or certain locations outside of the United States, in particular the UK/EU, you may have certain additional rights in relation to your personal information, subject to certain exceptions. Subject to applicable laws in your jurisdiction, you may have the right to:

  • Access/Know your personal information (commonly known as a data subject access request). You have a right to access the categories and specific pieces of personal information we have collected about you, the categories of sources from which personal information was collected, the purposes for processing your personal information, and the categories of third parties to whom we have disclosed your personal information.
  • Data portability, a right to obtain a copy of the personal information that you provided to us in a portable and, to the extent technically feasible, readily usable format.
  • 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, request that we transfer a copy of your personal information to another party, or otherwise exercise any privacy rights you may have, 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). Please see the list of the EU data protection authorities at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

We will not discriminate or retaliate 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 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 outlined in this Privacy Notice or otherwise disclosed to you at the time of collection, which includes satisfying any legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal information for a longer period if required or permitted by law, including if a complaint has been made or if we reasonably believe there is a prospect of litigation with 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 and business partners 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 for further information about the safeguards we use when transferring personal information and where applicable, to obtain a copy of the relevant transfer mechanisms.

Children

The Site and our social media pages are not intended for use by anyone under 18 years of age (or the age required by the applicable jurisdiction to create an account or otherwise use the Site or participate in the clinical trials, or we need to have obtained verifiable consent from your parent or legal guardian). 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 Notice

We reserve the right to modify this Privacy Notice at any time. If we make changes to this Privacy Notice, we will notify you by updating the “Last Updated” date of this Privacy Notice and posting the updated Privacy Notice on the Site. If we make material changes to how we treat your personal information or changes that otherwise require your consent, we will notify you through a manner appropriate to the changes. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting or notice). In all cases, your use of the Site after the effective date of any modified Privacy Notice indicates your acknowledgement that the modified Privacy Notice applies to your interactions with the Site and our business.

How to Contact Us

  • Email: legalnotices@adarx.com
  • Mail: 5871 Oberlin Drive, Suite 200, San Diego, CA 92121
  • Phone: (877) 232-7974
  • UK representative: ADARx.dpr.UK@mydata-trust.info
  • EU representative: ADARx.dpr.EU@mydata-trust.info