AirNexis Therapeutics, Inc., Global Privacy Notice 

Effective date: September 1, 2026

AirNexis Therapeutics, Inc., understands your concerns regarding your privacy when it comes to your Personal Information (PI). As we operate globally you can be confident that we have aligned our organization wide privacy practices with the highest standard expected regarding:

  • clinical trial subjects,
  • website visitors,
  • employees, consultants, contractors, collaborators, and healthcare professionals
  • service providers
  • our social media pages,
  • through other interactions by email

This is to ensure that you can be confident in how we securely manage the information we process.

In order to be transparent about the practices we have adopted, we have compiled the following to provide you with key information.

This Privacy Notice aims to inform you how we collect, use, maintain and disclose PI that could identify you.

Please be sure to read this notice before submitting information to us so that you can make a fully informed decision prior to sharing your PI with us.

What Is Personal Information?

Personal Information (PI), or Personal Data, is information that can be used to identify you as an individual. It can include obvious things such as your first and last names, home address, email address, telephone number, and job title. However, it can also include information that can indirectly identify you; examples may include your user ID, login and password, qualifications, organization name, industry sectors, or any other information which might reasonably be used in combination to identify you.

It does not include information to which the public has access if the disclosure is provided by law, such as official documents.

Sensitive personal information is a subset of PI. As this can be defined differently depending on the jurisdiction, AirNexis has brought together all of the relevant elements to give the broadest definition. We therefore treat an individual’s:

  • Racial or ethnic origin,
  • Political, religious or philosophical beliefs and union membership,
  • Data concerning health,
  • Genetic data,
  • Biometric data for the purpose of uniquely identifying someone,
  • Identification numbers such as Social Security, driver’s license, state identification card or passport number,
  • Account details such as login, financial account information, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account,
  • Precise geolocation,
  • Citizenship and immigration status,
  • Mail, e-mail and text messages (unless from our employees within their role with us)

as sensitive information. We do not collect all these categories of information and carefully consider what we will collect in the first place, whom we share it with and how we secure it.

How and What Information Is Collected, and for What Purposes

In general terms we collect PI:

  • Directly from you, such as when you contact us, are enrolled in a clinical trial or apply for a position within our organization
  • Through our website
  • From health care organizations (e.g., physician practices, hospitals, clinics, pharmacies)
  • From contract research organizations and clinical trial investigators
  • From government agencies or public records
  • From third-party service providers, or business partners such as recruiters and employment websites
  • From web research, social media and public sources
  • The organizations with which you are employed or affiliated
  • When you visit or interact with our clinical trial software or mobile apps or those services outside of a clinical research trial, we may collect information that identifies or is capable of being associated with you directly or indirectly from your operating system and platforms.
  • From service providers, consultants/contractors for procurement of services
  • From clinical sites for regulatory and clinical compliance

Personal and Business Contact Information

We collect this information which you provide voluntarily via the website. This may be when you submit a query for general inquiries or business development/partnerships, or when pursuing employment opportunities.

We may use this information:

  • To communicate with you,
  • To provide you with information you request related to AirNexis, or
  • For employment purposes such as processing a job application.

In some areas, the provision of PI is identified as necessary to complete the task you have requested, for example, requesting your contact details in order to respond to a query. However, the decision to submit any data is entirely voluntary, and we aim to provide you with both the knowledge and opportunities to determine to what extent you intend to share your data with us and for what purposes.

If you decide to opt-in to AirNexis email notifications on our website, you will receive information that may include company news, updates, events, or financial information.

If, at any time, you would like to unsubscribe from AirNexis email notifications, detailed instructions are included at the bottom of each email.

If you submit a job application via our website, or through other means, we will retain your information in line with AirNexis’ personal data retention policy, and it will be used in line with the sections relevant to you below.

Health Related Data

AirNexis collects health related information, often termed as Personal Health Information (PHI), only when it is voluntarily provided directly from you or someone who has your permission or a responsibility to do so, such as your healthcare professional.

We may use this information to:

  • Conduct clinical trials to develop new medicines and to show that those medicines are safe and effective. Initially, when you first show interest in a clinical trial, we will collect only sufficient data to determine if your medical history would be suitable for the trial in question.

If your eligibility for the trial is confirmed, you will be asked to provide further information to us. Giving your consent to a clinical trial is also a medical ethics issue, and AirNexis ensures that sufficient information will be provided for you to adequately make that determination before giving your consent. This information is provided in the form of an informed consent form or patient information sheet about the clinical trial.

For data protection purposes, we additionally aim to make sure that it is clear that you have agreed to allow us to process your PI, including sensitive information, within these forms. These forms will therefore also say what we will do with the data and why we need it.

Your PI is then processed by one or more organizations acting on our behalf. These organizations may be located in the European Economic Area (EEA), United Kingdom (UK), United States (U.S.), or another country. The data is collected, processed, and stored electronically; in some cases, in paper records which will be kept confidential and secure. For more information on who this information is shared with and why, please see below.

  • For employment purposes we may need to obtain social security numbers, addresses, medical record numbers, insurance plan member IDs, and medical device identifiers and serial numbers. Our HR team may ask employees for supporting documentation for sick leave, wellness programs, health insurance, or workers’ compensation. As a rule, we will not contact your healthcare providers directly for any PHI, as they cannot release an employee’s health records to an employer without prior authorization from the individual (this would be a HIPAA violation), unless other laws require them to do so.

For details regarding our health plan to our employees and how this is affected by HIPAA please see the section below.

Healthcare Professionals, Employees, Consultants, Contractors, and Service Providers

As a healthcare professional, employee, consultant, contractor, and services provider of AirNexis, we may collect some or all of the following PI about you:

  • General information: name, postal address, email address, phone number, date of birth and other information such as photographs, digital imagery and sound recordings, payment-related information, government issued identification (e.g., driving license, passport, tax identification number), agreements made with AirNexis.
  • Professional information: such as a job title, educational information, professional qualifications, prescribing history, work experience, medical/professional licenses, curriculum vitae (CV), networks and affiliates, programs and activities participated in, publications authored or co-authored, awards, board memberships, professional conference, attendance at events and employment status.
  • Assessment information: such as internal assessments, feedback and evaluations, classifications or performance ratings of your professional activities and outcomes.
  • Financial information: such as your bank details so that we can pay you for your expenses, or other compensation, this could also include collecting information to validate or make claims for any required insurances.
  • Other information: we may be required to collect and process other PI as required by law. An example is financial disclosure information to comply with the U.S. Food and Drug Administration regulation, 21 CFR Part 54.

User Information, Cookies and Similar Technologies

Cookies. Our website uses cookies, tags, pixels, web beacons, and similar tracking technologies (“Cookies”) to provide, customize, evaluate, improve, and secure our website and services.

A Cookie is a small piece of text that is placed on your website browser when you visit a website and may be our own first-party Cookies as well as those of third-parties such as our service providers and marketing partners. Some Cookies are only stored temporarily and destroyed each time you close your web browser. Our website also uses persistent Cookies, which do not delete when you close your browser and may collect and store data for a set period of time after you have left our website. You can find out more about Cookies in general and how they work at Cookiepedia.

How We Use Cookies. We use Cookies for the following purposes:

  • Website Operation. Cookies help us run our website securely and enable basic functions like page navigation.
  • Performance and Analytics. Cookies help us analyze how you interact with our website. This enables us to monitor and improve our website performance, services, and your experience.
  • Advertisements. Cookies allow us to deliver advertisements that are meaningful to you. Our third party advertising partners may use the Cookies to build a profile of your interests, deliver relevant advertising on other sites, and measure the efficiency of the advertisements. For instance, we use Google Analytics to analyze Site traffic and to improve our advertising efforts. To disable Google Analytics, please download the Google Analytics Opt-out browser add-on. You also have the option to opt out of Google’s use of cookies by changing your settings via Google’s advertising opt-out page.

How to Manage Cookies. If you wish to prevent Cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, certain features on our website may not work. For more information on how you can customize your browser’s Cookie setting please visit the link to your web browser below:

You may opt-out of interest-based advertising in general by visiting the Digital Advertising Alliance or Network Advertising Initiative websites. You can also turn off ad personalization from Google. We are not responsible for the completeness, effectiveness, or accuracy of any third party opt-out options or programs.

Web log data. When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see above). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.

Laws and Regulations Governing the Processing of Your Personal Information

AirNexis processes your PI as permitted by law. In some areas (for example, the European Union) this means that we must define the legal basis as described below:

  • Some of the PI collected will be processed to meet legal obligations, for example, around safety reporting in relation to the protection of health or for employment purposes. As the processing will involve special category health data, AirNexis provides suitable and specific measures to safeguard your rights.
  • AirNexis may also use the PI collected in the public interest purposes compatible with public health during the clinical trial but not specified within a specific legal obligation. In this instance there is a legitimate interest of AirNexis in processing your PI as there is potential for new knowledge about medical conditions; thereby improving the quality of life for potentially a large number of people. We will consider the reasonable expectations you have in allowing your information to be processed in relation to the clinical trial and ensure that the manner in which we collect and use the PI is proportionate to the aim pursued, respecting the essence of the right to data protection, and provide suitable and specific measures to safeguard the fundamental rights and the interests of you as a data subject.

Throughout the clinical trial, AirNexis will assess the balance of your interests with our own to ensure that we do not override yours. If we do, the reasons will be explained to you. (See the section labelled “Your Rights and Choices About Your Personal Information”).

  • An additional basis for processing your PI would be our legitimate business interests, as AirNexis may obtain financial rewards as a result of the processing. To the extent that we use PI to improve our website or for analyzing statistics, the basis for collection of data is also in our legitimate interest to conduct such improvements and analysis.

As with the preceding points, AirNexis must consider the reasonable expectations you have in allowing your information to be processed (it must be proportionate to the aim pursued, respecting your rights with regard to data protection and providing suitable and specific measures to safeguard them).

  • The processing of information is in anticipation of entering into engagements or a contractual service with you or your institution or company.
  • As we outlined in the section on health information, consent is a legal basis for processing PI under global privacy laws and under the comprehensive privacy legislation that is applicable to some states in the U.S.

AirNexis does not knowingly collect any PI from children under 13 years old through this website. However, if the parent or the guardian of a child under 13 believes that the child has provided us with Personally Identifiable Information, the parent or guardian of that child should contact us at privacy@airnexis.com, or they can utilize the Data Protection Officer email address below to request the deletion of this information from our files if they reside in the EU.

Anyone under 18 years old should seek their parent’s or guardian’s permission prior to using or disclosing any PI on this website.

How We Keep Your Data Safe and Secure

AirNexis takes reasonable steps to protect your personal data as you transmit your information from your computer to our website. We protect it from loss, misuse, unauthorized access and disclosure, and its alteration or destruction.

To accomplish this, AirNexis adopts appropriate data collection and processing practices, as well as employing security measures during data transmission and storage. We consider the nature, scope, context and purposes of processing, within the limits of current security principles and technologies.

You should keep in mind, however, that no internet transmission is ever 100% secure or error free. In particular, email sent to or from our website may not be secure, and you should therefore take special care in deciding what information you send to us via email.

If we become aware that your personal data has been breached, and we believe that this may result in a risk to your rights and freedoms, AirNexis will notify the relevant authority within your jurisdiction without undue delay and in accordance with the applicable laws.

If we are concerned the data breach is likely to result in a high risk to your rights and freedoms, we will take steps to notify you of it.

Additional regional specific information is included within this notice.

Sharing Personal Information

With regards to PI collected for use in clinical trials, we may be legally required to share certain PI if we are involved in legal proceedings or when complying with legal obligations, a court order, or the instructions of a government authority.

In addition, we will share your PI with healthcare regulatory authorities.

We may share your PI with commercial collaborators and authorized third parties (for example, if we sell a medicinal product for which you participated in the clinical trial).

We may sometimes contract with third parties to supply hosted secure database services to us. In some cases, those third parties may require limited access to some of your PI for the purpose of maintaining that information in the database.

In all these cases, your PI will remain ‘pseudonymized’ (i.e., we cannot identify you directly by name, address, or hospital number).

At the end of the clinical trial, your study-coded information will form part of a clinical study report that may eventually be made available to regulatory agencies worldwide in order to approve the medicine for general use.

For healthcare professionals, employees, consultants, contractors and service providers, we disclose individual information only as reasonably required within AirNexis and our worldwide affiliates, to pursue our legitimate business aims and as required by law. Appropriate safeguards will be established, where possible, to protect your information.

As a sponsor of clinical trials, we may also disclose your PI to third parties such as public/regulatory authorities/governmental bodies (including social and benefits departments), third parties that provide services to us (such as conducting audits, IT services, assisting in our clinical trials and studies, or health care compliance activities), business partners, and collaborators (such as external scientists).

In addition, we may disclose PI about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

AirNexis does not and will not sell, trade, or otherwise transfer to third parties your PI for their own direct marketing use unless it provides clear notice regarding this and obtains your explicit consent for your data to be shared in this manner.

With regards to the strictly necessary cookies outlined above, when you use our website you are accepting that your PI can be transmitted to our website hosting and editing partners and other sub-contractors who assist AirNexis in providing this service, so long as those sub-contractors undertake to process the information only according to our instructions and to comply with the applicable law regarding the protection of personal identification information.

With regard to the cookies, you will have voluntarily accepted any sub-contractors that undertake to process the information; they do so only according to our instructions and in compliance with applicable laws.

In addition, AirNexis may transfer PI to third parties in the event of sale or transfer of all or substantially all of its shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing.

AirNexis may also transfer PI to its service providers and subcontractors in order to keep you up to date on any information you may like to hear about either from AirNexis or from its business partners if you have opted for these types of communications.

AirNexis may release PI when it is necessary to comply with valid legal processes such as a warrant, a subpoena, or other court order if, following a review of the request and if it believes it is lawful, that it is reasonably necessary to comply with (for example, it does not ask for too much information).

AirNexis may transfer PI to third parties to investigate or respond to a complaint or security threat and to defend itself against third party claims and assist in fraud prevention or investigation.

Data Retention

AirNexis takes all reasonable measures to ensure that your PI is processed for the minimum period necessary for the purposes set out in this Privacy Notice and consistent with the reason(s) for which it was first collected.

Under international and national regulations governing clinical trials, we are required to keep your PI and study coded information for up to 25 years after the end of the clinical trial or according to our Personal Data Retention Policy.

After this period, your PI will be irreversibly destroyed or retained for a further period if required by law. You may request a copy of our Data Retention Policy.

PI obtained from healthcare professionals that are required to be kept as key documents under international and national regulations applying to clinical research will be retained for a period of 25 years following completion of clinical development.

For employees, consultants, contractors, and service providers, PI will be retained in accordance with our retention policy, which may be for a period of up to 10 years after the discontinuation of our business relationship with you where applicable laws or regulations require or allow us to do so. For further information, please contact us using the information provided below.

In general PI will be retained by AirNexis according to the following criteria:

  • as long as AirNexis maintains an ongoing relationship with you (e.g., where you are in receipt of our services, or you are lawfully included in AirNexis’ mailing list as you have not unsubscribed);
  • as long as your PI is necessary in connection with the purposes set out in this Privacy Notice, and for which AirNexis has a valid legal basis as outlined above;
  • with your prior consent, until the expiry of any additional retention period.

AirNexis undertakes to securely delete PI upon expiry of the retention period as described above.

Data Accuracy and Minimization

We take reasonable measures:

  • to ensure that your PI is accurately kept up to date; and
  • that PI is collected only as needed in connection with the purposes set out in this Privacy Notice.

Your Rights and Choices About Your Personal Information

AirNexis has developed a compliance program designed to enable us to comply with all applicable laws and regulations. We strive to ensure that each person whose PI we process benefits from the following rights. These rights may be limited by other contractual, regulatory or legal obligations that we are bound to uphold:

  • a right to be informed about what PI is being collected relating to you. If you want to know what PI we have about you, you can ask us for details of that PI, and request a copy of it (if any such PI is held). This is known as a “Data Subject Access Request” (DSAR);
  • a right of access to the PI collected about you;
  • a right to modify and correct your PI;
  • a right to oppose or restrict the processing of your PI;
  • the right to erase your PI;
  • and a right to portability of their PI.

For PI processed in relation to clinical trials – your PI is pseudonymized and we have no ability to identify you directly. Therefore, we recommend you contact your study doctor or healthcare institution if you wish to exercise the following rights. Additionally, if you should withdraw your consent to future processing, this would make it impossible for you to continue in the study.

You have the right to withdraw your consent in a clinical trial at any time, but this will not affect the lawfulness of us processing PI that was collected before your withdrawal due to our legal obligations outlined above. Where we process your PI under our legitimate interests, your right to erasure is limited by our legitimate interest to continue the processing, our legal obligations, our public interest (public health – high standards of quality and safety of health care and of medicinal products, or medical devices), scientific research, historical research, for statistical purposes, or for the establishment, exercise or defense of legal claims.

You can request PI be provided to you or directly transmitted to another organization nominated by you. This will be done in a structured, commonly used, and machine-readable format. However, for clinical trial subjects, if we are not able to retrieve your PI because we cannot identify you directly or where it may infringe upon the privacy rights of other clinical trial subjects, we may refuse your request.

All DSAR and other rights requests should be made in writing and sent to: privacy@airnexis.com

You can request a form from us to help make your request.

There is not normally a charge for a DSAR and other rights requests. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive or redundant requests) a fee may be charged to cover our administrative costs in responding or we may refuse your request.

We will provide you with a written response to your request within one month of the receipt of your request after having verified your identity. Should there be any delay due to

  • your request being complex or
  • there are multiple requests

we will inform you within one month of the request. If appropriate, we may extend this period by two further months, but we shall explain our reasons for doing so.

We may refuse to comply with your request to enforce your rights where;

  • the rights of other persons would be violated,
  • where any other legal exemptions may apply,
  • where your request is not legitimate or applicable,
  • or where it is not in our legitimate interests to the extent allowed by the data protection laws.

If we refuse to comply, we will explain to you our reasons for doing so.

We would encourage you to use our complaints processes with any concerns you have about how your PI is being handled privacy@airnexis.com.

However, if you still feel that your PI has not been handled appropriately according to the law, you can contact a Data Protection Authority and file a complaint with them.

These rights are consistent with Californian residents’ privacy rights under the California Consumer Privacy Act and the General Data Protection Regulation (GDPR) in the EU and UK (see below).

How to Contact Us or Our Representatives to Exercise Your Rights and Regional Specific Statements

AirNexis Therapeutics, Inc., (“AirNexis”), a U.S. company with registered office at:

1001 Page Mill Rd, Bldg 4, Suite 200B, Palo Alto, California 94304.

The United States of America and State Comprehensive Data Privacy Laws

If you are a U.S. resident and wish to request for us to provide you with your rights, you may submit a request to us through the following ways:

U.S. State Privacy Rights

Personal Data Breaches

As AirNexis takes their commitment to the security of your personal data seriously we aim to meet the highest level of breach notification laws in the United States as found in California’s state legislation i.e., when there is an unauthorized acquisition of computerized data that compromises the security, confidentiality, or integrity of PI.

PI includes a state resident’s first name (or first initial) and last name in combination with at least one sensitive data element such as:

  • Social Security number
  • Driver’s license or ID number
  • Financial account, credit card, or debit card number combined with a security code, access code, or password that would allow access to the account
  • Medical or health insurance information
  • Biometric data used for authentication, such as fingerprints or retina scans
  • Tax identification numbers
  • Unique identification numbers issued on a government document, such as a passport

If a breach of this nature occurs involving your PI, we will notify you within 30 days of its discovery unless a law enforcement or legal or regulatory delay applies.

If required, AirNexis will notify the appropriate state authority such as the state Attorney General.

California Consumer Privacy Act

AirNexis is not a covered entity under the California Privacy Rights Act of 2020 (“CCPA”).

Washington’s My Health, My Data Act (MHMDA)

Section 12 of Washington’s My Health My Data Act (the “Act” or “HB 1155”) contains statutory exceptions for research activities pursuant to:

  • the good clinical practice guidelines issued by the International Council for Harmonization (“ICH”) or under the FDA’s regulations governing informed consent and Institutional Review Board (IRB) requirements
  • health care information collected, used, or disclosed in accordance with laws that permits health care providers and health care facilities’ disclosure of adverse events and
  • data covered by the Health Insurance Portability and Accountability Act (“HIPAA”)
  • and PI that has been de-identified in accordance with HIPAA.

AirNexis does not knowingly collect any health information with regards to reproductive or sexual health outside of clinical trials. Nevertheless, the rights provided to you outlined above will ensure that your data is protected under this Act, and AirNexis confirms it will not sell or share your health information with law enforcement authorities unless legally compelled to do so.

Health Insurance Portability and Accountability Act (HIPAA)

In response to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the United States Department of Health and Human Services (HHS) issued regulations entitled Standards for Privacy for PHI for covered entities, known as the Privacy Rule.

These covered entities include physicians and other health care professionals that process and share PHI such as information in a patient’s medical chart or a patient’s test results as well as other identifiable health information relating to the relevant clinical research gathered by a covered health care provider when conducting clinical trials.

HIPAA permits a covered entity to use or disclose PHI for research with your written permission and when PHI has been de-identified in accordance with the standards set by the Privacy Rule. AirNexis has put in place policies and procedures to safeguard this type of information from unauthorized disclosures and access.

Canadian Data Protection and Privacy Laws

Canada’s Personal Information and Electronic Documents Act (“PIPEDA”) 2001 regulates privacy in Canada at a federal level and applies to private-sector organizations that carry on activities in Canada and their collection, use, or sharing of personal data of individuals, including employees.

The information in the sections above also apply to PI we process of individuals residing in Canada including why and how we collect your information, who we disclose it to and the safeguards we apply to keep it safe.

PIPEDA gives the right to individuals to access and rectify their data, as well as the right to “data portability” as outlined in the section marked Your Rights and Choices About Your Personal Information.

Domestic and International Data Transfers

PIPEDA allows AirNexis to transfer your PI domestically, i.e., to provinces that have enacted private sector privacy legislation which the federal government has deemed substantially similar to PIPEDA, as well as internationally. However, AirNexis will remain responsible for the PI transferred. AirNexis meets these obligations by ensuring privacy protection clauses are in place with the receiving parties to ensure that they:

  • have appropriate policies and processes in place;
  • have trained its staff to ensure information is properly safeguarded at all times; and
  • has effective security measures in place.

If AirNexis transfers your data in this manner we will inform you to which jurisdiction it will be transferred and whether it has the same level of protection as PIPEDA offers in relation to safeguarding your information; for example, if it may be accessed by the courts, law enforcement, and national security authorities. AirNexis will obtain your informed consent prior to transferring your data.

If your personal data has been processed by AirNexis during their business operations in Canada or its provinces you may submit a request to provide you of your rights by contacting the AirNexis Privacy Officer at:

Personal Data Breaches

In the case of a breach of PI which AirNexis believes creates a real risk of significant harm to you, we will notify the Office of the Privacy Commissioner of Canada (‘OPC’) as soon as feasible after we have determined that the breach has occurred.

Unless otherwise prohibited by law, we will notify you of any breach involving your PI if we believe that there is a real risk of significant harm to you.

If you have a complaint about the manner in which AirNexis has processed your PI, please contact the Privacy Officer and we will endeavor to resolve any concerns that you have. If not resolved, you have the right to file a written complaint via this online complaint form here which makes it easier to submit your complaint to the OPC or to your provincial or territorial privacy authority or to another regulatory body.

European Union and GDPR-like Data Privacy Laws

For residents of the EU and UK, AirNexis has a Data Protection Officer (DPO) that can assist with your DSARs. The DPO and/or the EU Data Protection Representative appointed by AirNexis shall be contacted by using the following information:

DPO: Pharma Data Protection SARL

Address: 1 La Cour, 50210 Belval, France

Email: dpo@pharmadataprotection.com

Additionally, any questions about our Global Privacy Notice may be directed to privacy@airnexis.com.

Further information about your rights in Europe can also be obtained from your national Data Protection Authority or the Supervisory Authority. A list can be found here: https://ec.europa.eu/digital-single-market/en/news/list-personal-data-protection-competent-authorities. In the UK, the Data Protection Authority is the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/).

You also have a right to lodge a complaint with the supervisory authority from your country of residence, or from the country where you are located when the PI is collected.

International Data Transfers

With regards to transfers pertaining to EEA/UK residents, AirNexis does not transfer PI to any third party country nor to any international organization, except as the case may be on the basis of:

  • where there is an adequacy decision in place, i.e., where the European Commission has determined that there is a comparative level of protection for your data as there is within the EU;
  • where there are suitable Standard Contractual Clauses in place, as issued by the European Commission; or
  • other valid transfer mechanisms under GDPR.

AirNexis primarily relies on the first two options.

Personal Data Breaches

In the case of a personal data breach, AirNexis will notify your national Data Protection Authority or a Lead Supervisory Authority of the breach if it is likely to result in a risk to your rights and freedoms. We will do so without undue delay and, where feasible, no later than 72 hours after having become aware of the breach.

AirNexis will also notify you of any data breach if it is likely to result in a high risk to your rights and freedoms.

Changes

Because this policy is subject to change without notice, you should check this Global Privacy Notice regularly for any changes. AirNexis will therefore revise the “last update date” at the bottom of this page. Users acknowledge and agree that it is their responsibility to review this Global Privacy Notice periodically and become aware of modifications.

This Privacy Notice is applicable from September 1, 2026.