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PRIVACY POLICY 

 

Effective Date: May 15, 2026 

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Progentos Therapeutics, Inc. ("Company", "we", "us", or "our") operates the website progentos.com (the "Site"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy governs our data collection, processing, and usage practices. 

We may update or modify this Privacy Policy at any time by posting the amended version including the effective date of the updated version. 

 

1. Information We Collect 

We collect personal information that you voluntarily provide to us when you interact with the Site, contact us via email, sign up for corporate updates, or inquire about our clinical pipelines. 

  • Information You Provide: We collect personal information you provide us. Information you provide to us may include but is not necessarily limited to the following: name, email address, phone number, physical address, and communication history. 

  • Automatically Collected Data: In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store personal information and related data when you visit or interact with our website, open or click on emails we send you, or interact with our advertisements through cookies, pixels, tracking technologies, and similar tracking or analytics technologies. Information we collect online may include but is not necessarily limited to: Internet Protocol (IP) addresses, URL address, device and/or browser settings, browser type, operating system, usage data, and tracking data collected through cookies. 

 

2. How We Use Your Information 

We process your personal information for legitimate business interests, including, but not limited to: 

  • To respond to user inquiries and provide informational updates. 

  • To administer and improve Progentos’ services and our Site. 

  • To monitor and optimize the performance and security of our Site. 

  • To seek advice on our legal rights and obligations and to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other customers or business partners, visitors to Progentos, or anyone else who could be harmed by such activities 

  • To comply with legal obligations relevant to biotech and clinical operations. 

 

We may use aggregated information that is collected to understand general information and trends related to our services. This information cannot be used to identify an individual and does not include specific personally identifiable information. 

 

3. Data Sharing and Third-Party Disclosures 

We do not sell your personal information. We may share your information with: 

  • Service Providers: Third-party vendors executing IT hosting, website analytics, or communications infrastructure on our behalf. 

  • Site Monitoring: Web analytics providers who monitor and analyze the use of our services.  

  • Business Transactions: We may also disclose your personal information in connection with a sale, merger, consolidation, financing, change in control, transfer of substantial assets, reorganization, restructure, or liquidation of Progentos. If we are subject to a merger or acquisition with/by another company, we may share information with the other company in connection with the transaction, and your personal information may be transferred to such company upon completion of the transaction. 

  • Legal Obligations: Public and governmental authorities if required under applicable international, federal, or state laws or to comply with a subpoena, court order or other formal governmental requests, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials. 

  • Consent: We share your personal information if you have asked or intend for us to do so or we have received your consent. 

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4. Legal Bases and Purposes for Processing Personal Information 

We may process personal information on the basis of: 

  • Providing Services, such as to fulfill our agreement with you, including processing necessary to provide you with Services or to manage our relationship with you, and delivering customer support.  

  • Managing our business relationships, including working with retailers, dealers, and business partners.  

  • Communicating with you, including responding to inquiries, providing updates, and sending service-related or marketing communications.  

  • Operating and managing our business, including internal administration, accounting, finance, marketing, technology, cybersecurity, privacy, vendor and service provider management, and other operational activities.  

  • Operating and improving our Site and Services, including analytics, research, product development, and enhancing our website and user experience.  

  • Maintaining security and preventing fraud, including protecting our systems, customers, and business operations.  

  • Complying with legal obligations and protecting our rights, including meeting regulatory requirements and handling claims or disputes. 

 

Where required under applicable data privacy laws, we rely on one or more of the following legal bases to process personal information: 

  • Consent, where you have given us permission to disclose and process your personal information for specific purposes, including providing Services.  

  • Performance of a contract, where processing is necessary to provide you with Services or to manage our relationship with you, or our business partners.  

  • Legitimate interests, where processing is necessary for our business operations, such as improving our Services, maintaining security, and operating our business, and where those interests are not overridden by your rights and freedoms.  

  • Legal obligations, where processing is required to comply with applicable laws, regulations, or legal processes.  

 

Where we rely on legitimate interests, we take steps to ensure that our interests are balanced against your rights and freedoms. 

 

5. International Data Transfers 

Progentos Therapeutics, Inc. is headquartered in the United States.  If and to the extent Progentos transfers personal information from another country into the United States, Progentos does so in compliance with the data privacy laws of the originating country and for purposes outlined in this privacy policy. This includes transfers to third-party service providers acting as data processors on our behalf, such as cloud infrastructure providers, who are bound by appropriate contractual obligations. Where we transfer personal information of individuals in the EU, Switzerland, or the UK to the United States, we rely on appropriate transfer mechanisms, which may include: (i) an adequacy decision issued by the relevant authority; (ii) the EU standard contractual clauses approved by the European Commission, the equivalent clauses recognized by Swiss authorities, and/or the UK Addendum approved by the UK information commissioner's office; or (iii) the EU-U.S. data privacy framework where our service providers are certified participants. We assess the laws and practices of the recipient country where required and implement supplementary technical and organizational measures as appropriate to ensure an equivalent level of protection. 

 

6. Your Global Privacy Rights 

Depending on your geographic location, you may possess the following data protection rights: 

  • GDPR (EU Residents):  

    • The right to access - You have the right to request us for copies of your personal information. We may charge you a small fee for this service. 

    • The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.  

    • The right to erasure - You have the right to request that we erase your personal information, under certain conditions. 

    • The right to restrict processing - You have the right to request that we restrict the processing of your personal information, under certain conditions. 

    • The right to object to processing - You have the right to object to our processing of your personal information, under certain conditions. 

    • The right to data portability - You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. 

    • You have the right to lodge a complaint with a competent data protection authority in your country of residence, place of work, or where an alleged infringement has occurred. 

    • For more information, you may contact, as applicable to you, the following authorities: 

  • Residents of Certain US States, where an applicable US state privacy law applies, your rights may include: The right to know what personal information is collected, receive a copy, request its deletion, correct any inaccuracies, limit the use and disclosure, opt out of profiling and targeted advertising, and opt out of data sale. 

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To execute these rights, submit a formal request to our contact details outlined below. 

Please note, if you are not a resident of a US state where one or more of these rights are granted to you under applicable law or not a European resident, then we have no obligations to take action on a request to exercise these rights. 

 

7. Cookies and Tracking Technology 

Our Site utilizes basic cookies to enhance performance and analyze user traffic. You retain the authority to configure your browser parameters to refuse or alert you about cookies. 

 

Progentos may collect and generate information about you when you interact with our Site, which may include name and contact information (as described above), information about the device you use to interact with our Site, and information about your interaction with our Site (such as content you view, features you access, sites you view immediately before and after you access our Site, content you view on our Site, search terms you use on our Site, and content in which you have indicated interest). 

 

We may place cookies on your browser or, if you use the Services, on your Device, in order to identify you when you return to our Site or log into our Services, for website functionality and, usage analytics. Using cookies, we may also collect other information about your use of the Site, including your Internet Protocol or IP address, username, session, browser, web pages you view and referring web pages, when you access the Site, and general online behavior for performance and marketing purposes. For further information on cookies, visit allaboutcookies.org. 

 

Progentos may use web beacons or pixels. Web beacons are a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages. We or third-party partners may use invisible pixels or beacons on our Site to count how many users access or use certain pages, features, or content. This information is collected and reported in the aggregate. We may use this information to improve our current service offerings, develop new services, and target information to you that may be helpful and useful to you based upon your use of our services. 

 

Progentos may use third-party analytics tracking technologies and tools to collect information about how you use our Site, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device information, discussed above. These tools examine website activities to prepare usage reports, and this information helps us improve our Site and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for Progentos to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you. 

 

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all features of our Site. For more information, please visit https://www.aboutcookies.org/. 

 

8. Security and Retention of Your Information 

We deploy industry-standard technical and organizational safety measures designed to guard your data against unauthorized access, destruction, or disclosure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. 

 

We will retain your personal information for as long as is necessary to fulfill the purpose for which we collected your personal information and any other permitted linked purpose and in compliance with our data retention policies. For example, we will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

Factors that may be relevant to determining how long we keep personal information include: 

  • The purposes for which we collected it; 

  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise; 

  • Your preferences and how you engage with our Site and services; 

  • Any applicable legal or regulatory requirements; and 

  • Whether we need the information for our business purposes, or to protect our rights (for example, in actual or potential litigation). 

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9. Policy On Children’s Information 

We do not knowingly collect personally identifiable information from anyone under the age of 13 without the consent of the child’s parent or guardian, and we do not target the services to children under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent, please contact us though one of the methods listed under “Contact Information,” below. If we become aware that we have collected personal information from children without verification of parental consent, we take reasonable steps to remove that information from our servers. 

 

10. Links To Other Sites 

Our services and/or Site may contain links to third-party websites. If you click on one of those links, you will be taken to websites we do not control. This Privacy Policy does not apply to the information practices of those third-party websites. You should read the privacy policies of third-party websites carefully. We are not responsible for the content, privacy policies, actions, or security of third-party websites. 

 

11. Contact Information 

For any legal inquiries regarding this Privacy Policy or our operational data handling, reach out to us at: 

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