Privacy and Data Protection Policy and Notice

Leal Health Inc. (“Leal Health”, “we”, “us”, “our” or the “Company”) is a patient-first digital health company with a mission to democratize access to advanced cancer treatment. We provide an AI-based clinical trial matching and decision support web application that serves as a gateway between cancer patients, their healthcare providers and biopharma (the “Platform” or “Services”).

We offer our Platform-registered cancer patients (“Patients”) and their authorized caregivers and health care providers trial matching services, drug treatment directory services and support directory services, as detailed in our Terms of Use (together: “Patient Services”). Our Platform also provides biopharmaceutical companies (“Clients”) with patient trial matching and drug treatment optimization services (together: “Pharma Services”).

Leal Health respects the privacy of Patients, Clients, caregivers, health care providers, partners, vendors, service providers, employment candidates and website visitors, and is committed to protecting the personal information that is shared with us (these and any others with respect to whom we collect Personal Data, shall collectively be referred to as “you” or “Data Subjects”).

This policy and notice (the “Privacy Policy”) explains the types of Personal Data we collect from you, that we receive about you or that you may provide in the course of your interest in our Services, during your usage of our Platform, during business transactions, conferences or when you visit our website. We are transparent about our practices regarding the information we collect, use, maintain and process and describe our practices in this policy and notice. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

For the purposes of the EU General Data Protection Regulation and the UK Data Protection Law 2018 (together the “GDPR”), as well as other applicable privacy laws, Leal Health is a data controller (“Controller”) in relation to the Personal Data of Patients who seek our Services, the representatives of our Clients and prospective clients, health care providers, caregivers, employees, partners, vendors and website visitors.

BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES.

1. WHICH INFORMATION MAY WE COLLECT?

Summary: we collect various categories of Personal Data in order to meet our contractual obligations, provide you with our Services, and also to meet various legitimate interests, such as fraud prevention and marketing.

Personal Data (also known as ‘personal information’) means information which identifies or is reasonably capable of being associated with a particular natural person. Personal Data does not include information that has been deidentified, aggregated or anonymized.

You do not have any legal obligation to provide any Personal Data to Leal Health. However, we require certain information in order to perform contracts, for internal audit purposes or to provide any Services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the Services.

We collect several categories of Personal Data from a variety of sources while providing our Services and conducting our business, including those listed below.

(a) Platform User Account Data

Whether you are a Patient, a legally authorized caregiver, a health care provider or an authorized user on behalf of our client (“Platform Users”), we collect basic account information when you create a Platform user account (“User Account”). This consists of your name, email address, phone number and login credentials. As part of creating an account for our Patient Services, you will also be asked to provide certain Patient Data, as described below.

(b) Patient data

If you, your legally authorized caregiver or healthcare provider register to and use our Patient Services, we collect your Personal Data as necessary in order to provide our Services (“Patient Data”). This data is provided voluntarily in a variety of ways, including: when you fill out our online questionnaire during your creation of a User Account; during your ongoing use of our Platform; when you contact us in order to provide us with your data, and; in the framework of our clinical team’s ongoing communications with you by phone or email throughout your trial enrollment process.

Patient Data may consist of any/all of the following information, to the extent you provide it to us:

Name (first and last) – collected only directly from patients;
Contact information (e.g. email, phone number)Date of birth (by month and year);
Demographics (gender, age, race);
Location (general location stored in a geo-hashed form, i.e. not exact address). This data helps us offer you clinical trials and support organizations that are closest to the patient;
Medical data: Type of cancer, cancer diagnosis date, disease characteristics (e.g. status, size, stage, location), biopsy genetic testing biomarkers, whether patient is pregnant and/breastfeeding, treatment history, general health information (e.g. ECOG/karnofsky, labs, other medications and health problems), medical documentation which may contain any of the above and any other medical data you may choose to provide to us;
Financial support related information: whether you received financial help in the past for cancer treatment, whether you have a social security number, range of how many people live in your household, range of annual household income and type of health insurance.

If you are an unregistered patient who wishes to make use of our Services, but the cancer type you selected in our online questionnaire is not yet supported by our Platform, we offer you to provide us with your Personal Data (“Unregistered Patient Data”), such as your email, details regarding your cancer condition (type, stage and location). We will use this data in order for us to notify you when our Platform is prepared to support you with our Services and to send you clinical trial related patient resources that you may find useful.

(d) Healthcare provider and caregiver data:

If you are a cancer patient’s healthcare provider or caregiver Platform User, as mentioned above, we will require your personal data in order to create a User Account. We will also collect your Personal Data when you contact us in other ways, such as by email, phone, meetings or conferences. If you are a health care provider, we may also process your email address when a Platform User Patient shares a matched trial with you via the Platform. In this case, we may use your email address to communicate with you regarding our Services.

(e) Client representative data, clinical trial coordinator and vendor data:

If you are a Client representative, a vendor, distributor or other business partner, we collect Personal Data when you or the organization you are associated with send it to us; we also collect Personal Data through our website and through our interactions with you.

We collect Personal Data required to provide our Client Services when you register interest, or when you provide us such information in meetings or conferences, or in the course of preparing a contract, or when contacting us or submitting requests for information or support, through your use of our website and Platform, by email, phone, or other ways in which you communicate and interact with us. This Personal Data generally includes your name (first and last), email address, phone number, job title, company name, country, and other information you may choose to provide to Leal Health.

If you are a coordinator of a clinical trial sponsored by our client, we may receive your contact details from our Client and may use these details in order to connect our Patients with your trial.

(f) Technical and behavioral information we collect through your use of our website and Platform:

When you are using our website and Platform, we are aware of it and gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This includes technical information and behavioral information such as the user’s Internet protocol (IP) address used to connect your device to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting.

We likewise place functional cookies on your browsing devices (see "Cookies" section below).

(g) Social media network information:

If you log in to our Platform through social media networks, such as Facebook, we will receive information about you from those networks, such as your public profile information, email address and other information you permit those networks to share with third parties.

(h) Employment candidates:

We collect Personal Data and other information relating to employment candidates, including name, address, email address, telephone number, and information on resumes. We may also collect information through notes on meetings, standardized tests, reports, references, interviewer impressions and such industry standard data, as well as data made publicly available or available to us on social networks.

2. HOW DO WE USE PATIENT DATA?

Summary: we process Patient Data in order to provide our Patient Services. We also anonymize data in order to improve our Patient Services and provide our Clients with clinical trial and drug insights

(a) Providing our Patient Services

Patient Data will be used by our Platform, including through use of AI (Artificial Intelligence), in order to provide you with our Patient Services. This includes:

Trial Matching Services: we provide real-time personalized list of matched clinical trials suitable to patients’ condition; facilitate their communication with trial coordinators; and support them throughout their trial enrollment process.
Drug and Treatment Directory Services: we provide data regarding available FDA approved drugs for diagnosis treatments Support Directory Services: we provide information regarding third parties that may support patients’ cancer-related needs, such as financial, medical or mental health support, legal assistance, support groups, lodging, transportation and child care support.

These services are customized to your/your patient’s medical profile, location, financial situation (as relevant for our Support Directory Services) and other data you provide us.

If your are a Patient User, your data will also be used by our clinical staff in order to support you throughout your clinical trial journey. After your creation of a User Account, you will receive automatic updates regarding new trial matches, and if you are matched with any of our Clients’ clinical trials, our clinical staff will reach out to you by phone or email in order to offer guidance and assistance throughout the enrollment process. We will also follow up with you regarding your usage of drugs presented to you by us and any experienced side effects, in order to ensure our Patient Services are updated to your cancer journey and needs. If you wish, you may choose to opt out of receiving such communications. If you express interest in enrolling in a clinical trial sponsored by one of our Clients, we will, under your express instructions, share your data with the relevant clinical trial site coordinator.

If you choose to do so, you may also share your matched clinical trial/s and relevant health and drug treatment data with your healthcare provider through the Platform, or by downloading such data in PDF form and emailing it independently.

Your data may also be shared with us by your healthcare provider or caregiver, using the Platform on your behalf. In such cases, we won’t collect any of your directly identifying data, such as name or contact information, and will only collect your relevant medical and general location data. We further require whoever shares such data on your behalf to receive your authorization prior to sharing your data and to redact directly identifying data before uploading any medical files.

(b) Improving our Patient Services

Patient Data will be fully anonymized and aggregated in order to optimize the Platform’s trial-matching and drug-matching AI capabilities. You will not be identifiable in any way from such data. You are entitled to object to using your data for this purpose by contacting us using the contact details below, and we shall assess such requests in accordance with applicable laws.

Your data will be fully anonymized and aggregated in order to present statistical information to our Clients through our Pharma Services, which enables them to and analyze the barriers keeping cancer patients from enrolling into their clinical trials, in order to improve and diversify patient enrollment, and/or to monitor, track and analyze cancer patients’ drug usage and treatments, in order to improve their drug development efforts. Our Clients will not be able to identify you in any way from this information. You are entitled to object to using your data for each of these purposes by contacting us using the contact details below, and we shall assess such requests in accordance with applicable laws.

3. WHAT IS THE LEGAL BASIS OF THE PERSONAL DATA WE COLLECT?

Summary: we process Personal Data to provide our Services, operate our website and Platform, meet our obligations, protect our rights and manage our business.

We will use Personal Data to provide and improve our Services to our Clients, Patients, health care providers and others, operate our website and Platform and meet our contractual, ethical and legal obligations.

All Personal Data will remain accurate, complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:

carrying out our obligations arising from any contracts entered into between you and Leal Health and/or any contracts entered into with Leal Health and to provide you with the information, support and Services that you request from Leal Health;
verifying and carrying out financial transactions in relation to payments you make in connection with the Services;
providing Platform Users with secure access to the Platform.

Processing which is necessary for the providing our Patient Services as described in our Terms of Service (performance of contract) and necessary for advancing scientific research:

collection of Patient Data in order to provide Patients and their health care providers and caregivers with a real-time list of relevant clinical trials, approved drugs for treatments and support directories, including sending them automatic notifications and updates regarding such information;
maintaining ongoing communications between our clinical team and Patients in order to provide assistance and guidance throughout the trial matching and drug treatment process;
processing of health care provider data in order to assist Patients with sharing matched trials and health and drug treatment data with them and vise-versa;
sharing Patient Data with matched clinical trial coordinators (under the Patient’s explicit instructions);
collection of Unregistered Patient Data in order to notify patients when our Platform is prepared to support their type of cancer and to send them clinical trial related patient resources.

Processing which is necessary for the purposes of the legitimate interests pursued by Leal Health or by a third party of providing an efficient and wide-ranging service to Clients, health care providers and Patients, in conjunction with processing that is necessary for advancing scientific research (when applicable – such as regarding health data):

notifying you about changes to our Platform and Services;
contacting you to give you educational or promotional information about clinical-trial related content and webinars, or additional Services offered by Leal Health which may be of interest to you (after you provide consent, when required under applicable law). You can unsubscribe from these communications at any point;
soliciting feedback in connection with the Services;
tracking use of our website and Platform to enable us to optimize them;
contacting you to ask if you wish to provide a Patient testimonial on our website;
enabling your health care provider or caregiver to share your health data with us for trial matching purposes;
If you are a potential client or health care provider - contacting you in order to interest you in our Services;
anonymizing Patient Data in order to provide Clients with statistical aggregated data;
anonymizing Patient Data in order to use such data for optimization of the Platform’s AI capabilities;
for security purposes and to identify and authenticate your access to the login zone.

Processing which is necessary for compliance with a legal obligation to which Leal Health is subject or for exercising and defending legal claims:

compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, anti-money laundering, tax related obligations, and for crime prevention and prosecution in so far as it relates to our staff, clients, service providers, facilities etc;
if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding.

4. SHARING DATA WITH THIRD PARTIES

Summary: we share Personal Data with our service providers, partners, and group companies, and authorities where required.

We transfer Personal Data to:

Members of our Group: If in the future we have affiliates - which means affiliate companies - whether wholly or partially owned by Leal Health, and co-owned companies – we will transfer Personal Data to them.

Clinical Trial Administrators: We share Patient Data with matched clinical trial coordinators, after Patients agree to sharing their data. Our Clients are fully responsible, as independent Controllers, with regards to all data processing activities in the framework of the clinical trial/s you choose to enroll in.

Third Parties We transfer Personal Data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties also include analytics and search engine providers that assist us in the improvement and optimization of our website, Platform and marketing.

We periodically add and remove third party providers. At present services provided by third-party providers to whom we transfer Personal Data include also the following:

Website analytics;
Document management and sharing services;
Client and Patient ticketing and support;
On-site and cloud-based database services;
Authentication and pseudonymization services;
CRM software;
Data security, data backup, and data access control systems;
Our lawyers, accountants, and other standard business software and partners.

In addition, we will disclose Personal Data to third parties if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case Personal Data will be one of the transferred assets. Likewise, we transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Leal Health, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For avoidance of doubt, Leal Health may transfer and disclose non-Personal Data to third parties at its own discretion.

5. WHERE DO WE STORE YOUR DATA?

Summary: we store your Personal Data across multiple locations globally

We store your Personal Data on servers owned or controlled by Leal Health, or processed by third parties on behalf of Leal Health, by reputable service providers (see the following section regarding international transfers).

6. INTERNATIONAL DATA TRANSFERS

Summary: we transfer Personal Data within and to the EEA, UK, USA, Israel and elsewhere, with appropriate safeguards in place.

Personal Data collected in the EU and UK is transferred to, and stored and processed at, a destination outside the European Economic Area (EEA) and the UK. This includes transfers to Israel, a jurisdiction deemed adequate by the EU Commission and the UK, and to the USA, not currently deemed adequate.

Where your Data is transferred outside of the EEA or UK, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, including entering into contracts that require the recipients to adhere to data protection standards that are considered satisfactory under EU law and other applicable, and that it is treated securely and in accordance with this Privacy Policy. Transfers from the EEA to Israel are made based on an adequacy ruling by the EU Commission. Transfers from the EEA to the USA are made based on the Standard Contractual Clauses published by the EU Commission. Transfers from the UK to the EEA and to Israel and made based on UK’s adequacy regulations. Transfers from the UK to the USA are made based on the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses. For more information about these safeguards, please contact us as detailed below.

We transfer Personal Data to locations outside of the EEA and UK, including in particular USA and Israel, in order to:

store or backup the information;
enable us to provide you with the Services and fulfill our contract with you;
fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
to serve our clients across multiple jurisdictions; and
to operate our affiliates in an efficient and optimal manner.

7. DATA RETENTION

Summary: we retain Personal Data according to our data retention policy, as required to provide our Services, meet our obligations, protect our rights, and manage our business.

Leal Health will retain Personal Data it processes only for as long as required in our view, to provide the Services, and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.

If you would like the Personal Data associated with your Platform User Account deleted, please contact us at Privacy@leal.health. Your account data will be deleted up to 90 days after your account deletion request, or 3 years following inactivity (after sending you a notice in advance). Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten. Leal Health will take reasonable steps to protect against unauthorized access to or use of any personal information contained in records that are deleted from our system

Data that is no longer retained will be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our website, Platform and Services are not subject to the deletion procedures in this policy and will be retained by Leal Health. We will not be able to identify you from this data.

8. COOKIES

Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our websites, or through your device and browser.

Leal Health uses cookies, pixel tags and other forms of identification and local storage (together referred to below as “cookies”) to distinguish you from other users of the website and of websites of our network. This helps us to provide you with a good user-experience when you browse the website and websites of our network and also allows us to improve our website and our Services.

In many cases, these cookies lead to the use of your device’s processing or storage capabilities. Some of these cookies are set by us, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.

These cookies can fall into several categories: (i) those that are necessary to enable the basic features of a website, such as providing secure log-in or adjusting your consent preferences (necessary cookies); (ii) those that are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors (performance cookies); (iiO) those that we use to carry out website performance and audience metrics, such as number of visitors, bounce rate, traffic source, etc. (analytics cookies) and (iv) those used to provide visitors with customized advertisements passed on the pages you visited previously and to analyze the effectiveness of ad campaigns (marketing cookies).

Necessary cookies do not require your consent. For other cookies, however, we request your consent before placing them on your device. You can customize and manage your cookie consent choices by clicking “Customize” on our cookie consent banner, which will lead you to our “Customize Consent Preferences” tool.

Internet browsers allow you to change your cookie settings, for example to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/how-to-delete-cookies/

To consult the list of cookies which we use on our website, please check your browser's settings. Instructions: https://www.wikihow.com/View-Cookies

9. SECURITY AND STORAGE OF INFORMATION

Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. Leal Health implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, such as regarding Patient Data, we pseudonymize and encrypt data in transit and at rest. Likewise, we take industry standard steps to ensure our website, Platform and Services are safe and to prevent unauthorized access to our data bases. Other security safeguards include, but are not limited to, firewalls, WAF, anti-virus, audit logs, strict access controls, breach detection systems and physical access controls to buildings, systems and files.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within Leal Health, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for Leal Health to provide its Services and fulfill its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.

Leal Health acts in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by Leal Health is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Leal Health promptly takes reasonable remedial measures.

10. DATA SUBJECT RIGHTS

Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.

Data Subjects in certain jurisdictions, such as in the EU, the UK, have rights granted pursuant to local laws under certain circumstances and with certain exceptions, including:

Access– the right to receive confirmation whether your Personal Data is being processed by us, what types of Personal Data, for what purposes, with whom is it or will it be shared (if at all) and for how long will it be stored.
Rectification – the right to correct your Personal Data held by us that may be inaccurate or incomplete. Please note that you may correct your data through your account settings.
Erasure– the right to have your Personal Data held by us deleted.
Restriction of Processing – the right to require us to cease processing your Personal Data.
Portability – the right to receive a copy of any of your Personal Data held by us in a convenient format and to have any of your Personal Data held by us transferred to a third party.
Objection – the right to object to the processing of your Personal Data by us.
Objection to Direct Marketing– the right to object to the processing of your Personal Data by us for the purposes of direct marketing, this can be achieved by opting out using the unsubscribe/opt-out feature displayed in our communications with you.
Objection to Processing based on our Legitimate Interests – the right to refuse to have your Personal Data processed in connection with activities that are based on our legitimate interests. This includes your right to object to anonymization of your data for our Clients’ trial and drug optimization purposes, as well as for optimization of the Platform’s AI capabilities. In such cases, Leal Health will assess whether its legitimate interests override your rights and freedoms.
Withdrawal of Consent– where we rely upon your consent in order to process your Personal Data, you have the right to withdraw such consent at any time.

A data subject who wishes to modify, delete or retrieve their Personal Data, or to otherwise exercise their data subject rights, may do so by contacting Leal Health (privacy@leal.health).

Note that Leal Health may have to undertake a process to identify a data subject exercising their rights. Leal Health may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Leal Health.

It is clarified that where Personal Data is provided by a client being the data subject's employer, such data subject rights will have to be effected through that client, the data subject’s employer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Leal Health employees and staff, with Leal Health proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent.

Data subjects in the EU, UK and other locations have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.

11. MINORS

We do not knowingly collect or solicit information or data from or about children under the age of 16 without parental consent, or knowingly allow children under the age of 16 to register to our Platform. If you are under 16, do not register or attempt to register for any of the Leal Health Services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16 without appropriate permissions, we will delete that Personal Data as soon as reasonably practicable without any liability to Leal Health. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: privacy@leal.health, as soon as possible.

12. THIRD PARTY LINKS

In the future, we may include third party links on our website. Please note that this privacy policy only applies to the Personal Data that we (or third parties on our behalf) collect from or about you and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.

13. CHANGES TO THIS PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the website, and any information collected in connection with Leal Health’s contractual obligations, Services and Platform. Leal Health may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://trialjectory.com/privacy-policy/. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our Services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

14. CONTACT US

Leal Health aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Leal Health only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.

Leal Health’s data protection officer (DPO), and its appointed GDPR Article 27 representative, MyEDPO Ltd., may both be contacted at: privacy@leal.health.

Last Revised: June 26,2024, Version: 3.0