Effective Date: September 2024

1. Introduction
Cytospire Therapeutics Limited (“Cytospire Therapeutics”, “us”, or “we”) respects the privacy of our customers, partners, and other website visitors (”you”). This Privacy Policy (“Policy”) describes how we collect, process, share, and safeguard personal information that we collect via our website (https://cytospire.com) (“Website”) or when we otherwise communicate with you. It also tells you about your rights and choices with respect to your personal information, and how you can contact us if you have any questions or concerns.

Cytospire Therapeutics Limited will be the controller of your personal information in accordance with the data protection laws of the European Economic Area and the United Kingdom.

2. Personal information We Collect
We collect personal information from you in the following ways:

Personal Information You Provide to Us

Contact Information and Communications. We may collect your full name, email address, phone number(s), and contact address(es) when you communicate with us via email or by other means. When you contact us, you also provide us with the content of your communications. When you engage with us as a customer representative, we may also collect your job position and company you are associated with.

Automatic Data Collection

We and our service providers may automatically log information about you, your computer, or mobile device, and our communications with you, including through the use of cookies and other similar technologies. This information includes:

Device Information: The manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Website. The information we collect may vary based on your device type and settings. We may also derive a rough estimate of your location from your IP address when you visit the Website.

Usage Information: Information about how you engage with our Website such as the types of content that you view or actions you take on our Website, and the time, frequency, and duration of your activities.

For more information on our use of cookies, please see our Cookie Policy.

Personal Information We Obtain From Third Parties

Social media platforms. We maintain pages on social media platforms, such as Facebook, LinkedIn, X (Twitter). You or the platform providers may provide us with information through the social media platform, and we will treat such information in accordance with this Policy.

3. How We Use Your Personal Information
We will use your personal information for one or more of the purposes set out below.

To operate and deliver our Website and services. We will use your personal information to perform our contractual obligations and when it is in our legitimate business interests, including to:

• Provide, operate, maintain, and secure our services;
• Provide support assistance and troubleshooting;
• To send you updates about administrative matters such as changes to our terms or policies; and
• Provide user support, and respond to your requests, questions and feedback.

To improve, monitor, personalise, and protect our Website. It is in our legitimate business interests to improve and keep our Website safe, which includes:

• Analysing and understanding how you visit our Website, how you interact with us and to enrich your user experience and customise your relationship with us;
• Protecting the security of our Website; and
• Preventing and detecting security threats, fraud or other criminal or malicious activities.

To comply with legal obligations and to defend Cytospire Therapeutics against legal claims or disputes. We may use your personal information to comply with our legal obligations or when it is in our legitimate business interests, which includes to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our compliance with legal and contractual requirements and internal policies; and
• Protect the security of and manage access to our premises and prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft.

To facilitate corporate acquisitions, mergers or transactions. We may use your personal information, when it is in our legitimate business interests, when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

4. How We Share Your Personal Information
We may share personal information with the following categories of third parties:

• Service Providers: To assist us in meeting business operational needs and to perform certain services and functions, we may share personal data with our vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers and email communication software, web analytics services. Pursuant to our instructions, these parties will access, process, or store personal data in the course of performing their duties for us.
• Professional Advisors: We may share personal information with our professional advisors such as lawyers and accountants where doing so is necessary to facilitate the services they render to us.
• Legal Requirements: We do not volunteer your personal information to government authorities or regulators, but we may disclose your personal information where required to do so to comply with laws and regulations applicable to us as described above.
• Business Transaction: If Cytospire Therapeutics is involved in a merger, acquisition or asset sale, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be sold, transferred, or otherwise shared including as part of any due diligence process.

5. Your Rights and Choices
Depending on where you are based, and as provided under applicable law and subject to any limitations in such law, you may have the right to:

• access the personal information we hold about you;
• request we correct any inaccurate personal information we hold about you;
• request we delete any personal information we hold about you;
• restrict the processing of personal information we hold about you;
• object to the processing of personal information we hold about you;
• receive any personal information we hold about you in a structured and commonly used machine readable format or have such personal information transmitted to another company; and
• withdraw any consent you previously provided to us regarding the processing of your personal information at any time. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case. For more information on your rights, please contact us using the details in the “Contact Us” section below.

6. Data Storage
We store your personal information in the United Kingdom.

7. Children’s Privacy
Our Website is not directed at children, and we do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us as set out in the “Contact Us” section below.

8. Retention of Personal Information
We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention procedures, and in accordance with applicable laws.

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

9. Security of Personal Information
We use reasonable organisational, technical and administrative measures designed to protect against unauthorised access, misuse, loss, disclosure, alteration, and destruction of personal information we process. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its security.

10. Do Not Track
Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

11. Links to Other Sites
Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

12. Changes and Updates to this Policy
We will update this Policy from time to time. Please review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

13. Complaints
If you wish to lodge a complaint about how we process your personal information, please contact us at info@cytospiretx.com . We will endeavor to respond to your complaint as soon as possible. If you are based in certain jurisdictions, you may also lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. For example, if you are based in the UK, you may choose to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ .

14. Contact Us
Cytospire Therapeutics is the entity responsible for the processing of your personal information, and is the controller in respect of such processing as provided under applicable law. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at info@cytospiretx.com.