Sanavia Oncology Privacy Policy

Effective Date:  December 1, 2025

Sanavia Oncology (“Sanavia”) is committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you when you use the websites and online services that we operate and that link to this Privacy Policy (the “Services”). 

I.      CATEGORIES OF INFORMATION

We may collect or process the following categories of information when you used our Services:

Information you provide directly to us.

o   Identifiers, including your name, email address, telephone or mobile phone number, and postal address;

o   Demographic and Profile Information, including your interests, educational information, professional affiliations, details about your medical specialty, preferences, feedback, date of birth, age, gender, race, color, national origin, and sex; and

o   Other Information and Correspondence you send to us.

Some of the Personal Information in these categories may be considered sensitive Personal Information in some jurisdictions.

II.    SOURCES OF PERSONAL INFORMATION

·       Information we collect automatically. 

o   Online and Technical Information, including internet, electronic activity, and other information automatically from the devices and browsers that you use, including information regarding your interactions with our websites, applications, or advertisements, including IP address, device identifiers, settings, characteristics, standard server log information, and other information collected using cookies and similar technologies.

o   Inferred and Derived Information, including inferences used to create a profile about preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes;

o   Audio and Visual Information, including audio, electronic, visual, or similar information relating to your interactions with us, including photographs, video images, CCTV recordings, call center recordings, call monitoring records, and voicemails.

·       Information we collect from other sources.  We also may receive the categories of information described above from other sources, including from other users of our Services, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.  For example, if you access any social media or similar services through the Services to login or to share information about your experience on our Services with others, we may collect information from these third-party services.

Without this information, we may not be able to provide you with all the requested Services, and any differences in services are related to your information.  

We may aggregate or de-identify the information described above.  Aggregated or de-identified data is not subject to this Privacy Policy.

III.   USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above to provide and maintain our products and services and as otherwise permitted by law, including:

·       To provide you with information you request from us and to provide you with features including to allow you to participate in interactive features of our Services.

·       To manage our relationship with you, including providing you with the information that you request from us, notifying you about changes to our terms or Privacy Policy, and for account management.

·       To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates and trusted business partners.

·       To administer and improve our products and services, including to ensure that content is presented in the most relevant and effective manner for you and for your device and to train and enhance software-based features and tools that support our Services and for troubleshooting, data analytics, testing, research, statistical and survey purposes.

·       For research and development of our products and services, including scientific, business, and market research.

·       For legal and compliance purposes, including to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims. This includes using your information to comply with regulatory requirements relating to the safety and efficacy of our products.

·       To support our everyday business purposes, such as for quality control, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance, analytics and research, enforcement of contracts and other contract management.

Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

IV.  DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may disclose the categories of information we collect.

•       Authorized third-party vendors and service providers. We may disclose your personal information to third-party vendors and service providers that provide services to us for a variety of business purposes, such as customer service, email deployment, advertising and marketing, security and performance monitoring, data hosting, auditing, and data processing.

•       Corporate affiliates.  We may disclose your personal information with our corporate affiliates.

•       Business transfers. We may disclose your personal information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.

•       Advertising Partners. We may disclose your personal information to certain third-party business partners for advertising and marketing purposes, including so that they can provide individuals with special offers, promotions, and other materials that may be of interest to them. We may also use third-party advertising services to serve advertisements on the Services and on third-party platforms. These third parties may set their own cookies or similar technologies to collect information about users’ online activities over time and across apps and websites. Please see the Your Rights and Choices section for additional information on the rights to opt out of these disclosures of personal data.

•       Legal purposes. We may disclose your personal information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Sanavia Oncology, our affiliates, users, or the public.

•       Other recipients, with notice and your consent. We may disclose your personal information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.  

If you access third-party services, such as social media services, or third-party single-sign on tools, through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.

If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas.  You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

V.    ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES

When you use our Services, we and our third party advertising partners use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. By using the Services, you consent to our use of cookies and similar technologies.

The following types of cookies are used on our Services:

·       Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.

·       Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you've previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.

·       Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.

·       Content / advertising cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising on our Services and elsewhere online and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you've visited our Services and help us understand usage of our Services. Some of these cookies are from third parties that collect information about your use of our Services in order to provide advertising (on our Services and elsewhere, across your different devices) based on your online activities (so-called "interest-based advertising") on our Services and elsewhere online, across your different devices. We do not control the privacy practices of these third parties, and their practices are not covered by this Privacy Policy.

Cookie Preferences. You may be able to refuse or disable cookies by adjusting your web browser settings.  Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.

Network Advertising Initiative. Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here.  Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest-based advertising for mobile applications.  Please check your device settings and mobile app permissions for additional information on how to opt out.

Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit "do-not-track" signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

VI.           YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable law, to certain rights over the information we collect and process about you. In particular, you may have the right to:

·       Request to access, correct, or delete of your personal information;

·       Object to or request restriction of processing of your personal information;

·       Know more information about our privacy practices, including in some cases, more information about when we disclose your personal information to third parties.

·       Withdraw your consent at any time by contacting us, where we process your personal information based on your consent. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.

How to Submit a Request. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.

Authorized Agents. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent or to appeal a refusal to take action on your request. To designate an authorized agent to exercise your rights and choices on your behalf, they will be required to provide proof that they are authorized to represent you and verify your identity. 

Appeal. If you disagree with a decision made in response to a request to exercise your rights, you may be entitled, in accordance with applicable law, to appeal the decision. To appeal a decision, please contact us at the address below.

Additional Information. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.  Any difference in the Services are related to the value provided. You also may be able to control our collection and use of your location information through your mobile device or app settings. You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.

VII.          INTERNATIONAL TRANSFERS

By using the Services and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction.  To the extent you are a resident of a country other than the United States, you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

VIII.        CHILDREN

We do not knowingly collect, sell, or share cross-context behavioral advertising, any information from known children who are less than thirteen years of age or such other age defined by applicable law, without parental consent or as otherwise permitted by applicable law.

IX.            DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary and proportionate for the purposes set out above and consistent with our retention policies, considering criteria such as the duration of our relationship with you, the sensitivity of the relevant information, any applicable rules on statute of limitations, and any legal requirements to retain your personal information.

We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current.  Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

X.             LINKS TO OTHER WEBSITES

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under our control or maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

XI.            ADDITIONAL JURISDICTION-SPECIFIC DISCLOSURES

For additional information regarding our processing of personal data, please see the following jurisdiction-specific details:

Collection, Use, Disclosure of Personal Information. In the twelve months since this Privacy Policy took effect, we may have collected, used, or disclosed the personal information described above in Sections I through V.

Collection and Use of Sensitive Personal Information. While some of the personal information we collect may be considered sensitive, we do not use or share sensitive information except to provide you with products and services you request and as otherwise required or permitted by law.

Additional Rights. We also provide you additional rights depending on where you live. In particular:

·       Opt-Out of Sale or Sharing. You may have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes. You may exercise this right by clicking the [“Do Not Sell or Share My Personal Information”] or [“Your Privacy Choices”] link in the footer of applicable websites.

Our websites also support the Global Privacy Control (“GPC”), which is a browser-based opt-out preference signal that can communicate your privacy preferences to the websites you visit. You can learn more about the Global Privacy Control to here. Please note that because the Global Privacy Control is a browser-based mechanism, your opt-out preference will apply only to the browser and device from which you exercised that choice.

·       Request a list of specific third parties to which we have disclosed your personal information;

·       Shine the Light Request, you may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

XII.          CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy.  We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

XIII.         CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices or would like to exercise a right under applicable law, please contact us via contact@sanavia.bio