US Privacy Notice

Last Updated: April 24, 2024

1. INTRODUCTION AND SCOPE

   This privacy notice (this "Privacy Notice") describes how Anokion US, Inc., 50 Hampshire Street, Suite 402, 4th floor, Cambridge, MA 02139, USA, Anokion SA, Kanyos Bio, Inc., and each of their respective affiliates (“Anokion,” "us", "we", or "our") collect, handle, share and use the personal data of users of www.anokion.com (the “Website”), and the personal data of individuals in relation to other interactions, transaction, sites or applications that reference this Privacy Notice (the "Services"), such users and individuals being “Data Subjects”.

   This Privacy Notice applies only to the personal data of Data Subjects who are resident in the United States. Please note that this notice does not apply to our collection of personal data in respect of clinical trials, which shall be subject to a separate privacy notice issued to participants in such trials.

   We shall act as a controller of Data Subjects’ personal data that is collected or received in accordance with this Privacy Notice. If we process personal data as a data processor, we will process such personal data in accordance with the terms of the contract we have with the third party for whom we act as data processor, and this Privacy Notice shall not apply to the processing of such personal data.

   To receive this notice in another format (for example, audio, large print, braille) please contact us using the contact details in section 12 below.

2. ACCEPTANCE OF PRIVACY NOTICE

   By using the Website, you signify your acceptance of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not use the Website. Your continued use of the Website following the posting of changes to these terms will mean that you accept those changes.

3. WHAT PERSONAL DATA DO WE PROCESS AND HOW IS IT COLLECTED

   Data Subject Provided Personal Data

   Data Subjects may provide to us (whether by uploading, email, telephone, post or otherwise) the following types of personal data in relation to the Services, which we may then collect, use, store and/or transfer in accordance with this Privacy Notice:

   Type of personal data	Personal data includes:
   Contact Data	Physical address (billing and delivery) Email address Telephone numbers
   Identity Data	First name Last name Position / Title
   Marketing and Communications Data	Preferences in receiving marketing from us and third parties Communication preferences

   Automatically Collected Personal Data

   The following types of personal data may be automatically collected or logged when Data Subjects access and use the Services, which we may then collect, use, store and/or transfer in accordance with this Privacy Notice:

   Type of personal data	Personal data includes:
   Technical Data	Internet protocol (IP) address Browser type and version Time zone setting and location Browser plug-in types and versions Operating system and platform Other technology on the devices used to access the Services
   Usage Data	Information about how the Services are used

   Third Party Provided Personal Data

   We may also obtain Data Subjects’ personal data from the following third parties:

   Third Party	Type of personal data	Source of Data
   Investors	Contact Data Identity Data	General correspondence (including emails) Tax forms Financial/bank transfer information Share register
   Collaboration Partners	Contact Data Identity Data	General correspondence (including emails) Contracts Purchase orders Tax forms Financial/bank transfer information
   Consultants	Contact Data Identity Data	Contracts Purchase orders Tax forms Financial/bank transfer information
   Service Providers	Contact Data Identity Data	Contracts Purchase orders Financial/bank transfer information Tax/regulatory documents

   Special Categories of Personal Data

   We do not collect any special categories of personal data about Data Subjects (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Data Subjects’ health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

   Children

   Under Age 13. The features, programs, promotions and other aspects of our Services requiring the submission of personal data are not intended for children. We do not knowingly collect personal data from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe they have disclosed personal to us, please contact us using the contact details at section 13 below.

   Under Age 18. Minors under 18 years of age may have the personal data that they have provide to Anokion deleted by contacting us using the contact details in section 12 below requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

4. HOW WE USE PERSONAL DATA

   Purpose	Type of personal data	Lawful basis for processing	Details
   To monitor the use of the Services	Technical Data	Legitimate interests	To improve the functionality and content of the Services.
   To provide our products and services	Identity Data Contact Data	Legitimate interests	To enable us to provide our products and services to Data Subjects.
   To contact Data Subjects who request such contact	Identity Data Contact Data	Consent	To respond to Data Subjects’ contact requests.
   To manage and protect our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Data Contact Data Technical Data	Legitimate interests	To manage our business and ensure the effective provision of the Services. To prevent fraud.
   To undertake identification verification	Identity Data Contact Data	Legitimate interests	To protect our business and to prevent fraud.
   To send personal marketing and promotional materials to Data Subjects	Identity Data Contact Data Marketing and Communications Data	Consent	To promote our products and services.

   If a Data Subject has provided consent to processing and subsequently withdraws that consent, we may still process that Data Subject's personal data where we have another lawful basis for doing so.

   Where we need to collect personal data by law or under the terms of a contract that we have with a Data Subject and the Data Subject fails to provide that personal data when requested, we may not be able to perform the contract we have with the Data Subject (for example, to provide access to the Services).

5. SHARING OF PERSONAL DATA

   We may share Data Subjects' information with the following categories of third parties:

   Third Party	Description
   Service Providers	Our service providers include third parties that provide us with services such as IT services, hosting services, administration services, and other business process services, and marketing services. Such third parties will act as our processors.
   Professional advisors	We may need to provide Data Subjects' personal data to our professional advisers that provide services to us. Our professional advisors include lawyers, accountants, bankers, auditors and insurers. Such third parties may act as our processors or independent controllers.
   Authorities	We may disclose personal data where required in order to respond to requests from regulatory or governmental authorities, court orders, legal process, or to establish or exercise our legal rights or defend against legal claims. It may also be necessary for use to share personal data in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law. In such circumstances, we will take appropriate measures to ensure that the recipient understands the sensitive nature of the personal data that they may receive.
   Other Third Parties	We may share Data Subjects' personal data with third parties to whom we may choose to transact business with. We may share Data Subjects’ personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (including in relation to restructuring/insolvency situations). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use Data Subjects’ personal data in the same way as set out in this Privacy Notice. Data Subjects’ personal data may be a transferred asset in any sale of all or part of our business.
   Affiliates	Data Subjects’ personal data might also be transmitted within the group of which we are members for internal administrative purposes.

   We require all our data processors and any other third party that we provide Data Subjects' personal data to respect the security of Data Subjects' personal data and to treat it in accordance with applicable law.

   We do not allow our data processors to use Data Subjects' personal data for their own purposes and only permits them to process Data Subjects' personal data for specified purposes and in accordance with our instructions.

6. MARKETING

   We may send Data Subjects marketing communications (including newsletters) if they have requested such communications from us or if we are otherwise allowed to do so under applicable law.

   Opt-Out

   If a Data Subject does not wish to receive marketing information from us, the Data Subject can opt-out by contacting us using the contact details at section 13 below or by clicking the opt-out link in our electronic marketing communications.

7. SECURITY

   The security of your data is very important to Anokion. We have implemented appropriate security measures preventing your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, you should know that no website operator, including Anokion, can fully eliminate security risks associated with personal data. While Anokion has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Website or via e-mail cannot be guaranteed.

8. AUTOMATED DECISION MAKING

   We do not make any decisions regarding Data Subjects solely using automated decision making (including profiling) based on Data Subjects’ personal data.

9. RETENTION OF PERSONAL DATA

   We will only retain Data Subjects' personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

   Details of retention periods for personal data are available from us on request using the contact details at section 13 below.

10. RESPONSE TO DO-NOT-TRACK SIGNALS

    Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Anokion does not process or respond to “Do Not Track” signals.

11. LINKS TO OTHER WEBSITES

    Our Website may contain links to other websites. These websites may have separate privacy and data collection practices, independent of our practices, and Data Subjects’ use and access to such sites is subject to those terms and policies. We have no responsibility or liability for these independent policies or actions and we are not responsible for the privacy practice or the content of such websites.

12. HOW TO CONTACT US

    To ask any questions regarding this Privacy Notice or to exercise any rights, please contact us using the following contact details:

    Address: Anokion US, Inc., 50 Hampshire Street, Suite 402, 4th floor, Cambridge, MA 02139, USA

    Email: info@anokion.com.

13. AMENDMENTS TO THIS PRIVACY NOTICE

    This Privacy Notice may be revised from time to time, including where we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display a “Last Updated” date in at the top of this Privacy Notice so it is clear when there has been a change. If we make any change to this Privacy Notice regarding use or disclosure of personal data, we will provide notice on the Website and as otherwise required. Small changes or changes that do not significantly affect Data Subjects’ privacy interests may be made at any time and without prior notice.