XALUD GLOBAL PRIVACY AND DATA PROTECTION NOTICE
THE XALUD PRIVACY COMMITMENT
Xalud is committed to protecting the privacy of your personal information. This Global Privacy and Data Protection Notice (“Notice”) describes how Xalud and its affiliates (collectively “we,” “us,” or “our”) may process your personal information, along with how we protect it. Xalud, as the Controller of your personal information, adheres to applicable privacy laws and regulations, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and the European Union’s General Data Protection Regulation (GDPR). This Notice describes our general practices, but where local laws or regulations require that we process your personal information differently, we will comply with those local laws.
WHAT TYPE OF PERSONAL INFORMATION DOES XALUD COLLECT?
The types of personal information Xalud collects depends on how you interact with us. Personal information we may collect and process from you may include contact information, educational information, and professional experience.
HOW MAY XALUD USE MY PERSONAL INFORMATION?
Xalud may collect and use your personal information for reasons including, but not limited to, those listed below.
1) Healthcare Professionals and Scientists
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To provide, collect, review and communicate information on the proper use of drugs in development (“Xalud Products”);
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To provide, collect, review, and communicate information on quality, safety, or clinical trial data of Xalud Products;
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To coordinate the logistics of your participation at a Xalud event;
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To disclose, notify, or report research and financial relationships as required by law and regulations.
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2) Media and the Investment Community
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To distribute news and information on Xalud;
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To analyze our stakeholders’ needs and plan accordingly;
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To contact media representatives, securities analysts, and investors.
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If we decide to use your personal information for a purpose other than originally intended when we first collected your data, we will provide you with new Notice.
WHY IS XALUD ALLOWED TO COLLECT PERSONAL INFORMATION?
Xalud can collect and use your personal information when any of the following apply:
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You give us your explicit consent to use your data. You can withdraw this consent at any time.
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We need your personal information in order to enter into or perform a contract.
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We need your personal information to comply with legal requirements.
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We have a legitimate interest in using your personal information for the purposes above.
WITH WHOM MAY XALUD SHARE YOUR PERSONAL INFORMATION?
Xalud may share your personal information in accordance with data privacy legislation with authorized third parties for legitimate business purposes, including, but not limited to:
• Xalud affiliates;
• Healthcare professionals and organizations, distributors, and other members of the healthcare and pharmaceutical industry including those involved in clinical trial activities;
• Selected suppliers, vendors, and service providers, including event planners, and technology suppliers;
• Legal or administrative authorities;
• Potential stakeholders, including in the event of a merger, legal restructuring operation such as an acquisition, joint venture, or divestiture;
• Professional service providers such as accountants and auditors.
In any case, Xalud will require that such third parties:
• Comply with applicable data protection laws and the principles of this Notice;
• Only process the personal information for the purposes permitted in this Notice; and
• Implement appropriate technical and organizational security measures designed to protect the integrity and confidentiality of your personal information.
To facilitate our global operations, Xalud may transfer, store, or process your personal information within our corporate locations or with service providers based around the world, including in the United States and the European Union (EU), where laws may differ from your country of residence. Xalud takes appropriate steps to ensure personal information is processed and transferred according to applicable laws including through the use of written agreements, such as Standard Contractual Clauses adopted by the EU. Please contact Xalud at privacy@xaludthera.com for more information regarding these safeguards.
HOW LONG WILL XALUD RETAIN YOUR PERSONAL INFORMATION?
Xalud will maintain your personal information only as long as is reasonably deemed required for legal, contractual, or business purposes.
YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL INFORMATION
You have certain rights with respect to your personal information, although some exceptions may apply depending on our basis for processing your personal information and the law in your jurisdiction. Depending on these, you may have the right to access your personal information, request corrections or deletions, restrict or object to processing, or withdraw consent to processing. You have the right to complain to your local data protection authority, although we ask that you contact us first.
To exercise any of these rights, please Email us at privacy@xaludthera.com.
CHANGES TO THIS NOTICE
This Notice may be modified from time to time, particularly in the event of changes in the law or Xalud’s practices. The date on which this Notice was last updated is shown at the end of this document. Please email info@xaludthera.com for the current version.
CONTACT INFORMATION
If you have any questions pertaining to Xalud’s privacy practices, use of your personal information, or your rights described above, you may contact us at privacy@xaludthera.com.
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Effective: 12/8/22