LEADIANT BIOSCIENCES, INC.
PRIVACY POLICY FOR WEBSITE TARGETED TO CANADIAN AUDIENCES

At Leadiant Biosciences, Inc. (“Leadiant”, “we” or “us”), we recognize the importance of the privacy of Personal Information of individuals who visit our company and product websites (“you” or “your”).

This Privacy Policy (“Policy”) applies to www.canada.leadiant.com (the “Website”) and is directed at Website visitors based in Canada. The Policy addresses how we collect and process Personal Information about individuals and is designed to assist you in making informed decisions when visiting the Website. “Personal Information” is defined as information, in any format, about an identifiable individual.

By voluntarily providing us with Personal Information and accessing the Website, you are consenting to its collection, use and disclosure in accordance with this Privacy Policy. If you do not agree to have your information used in any of the ways described in the Privacy Policy, you must discontinue use of the Website and not provide us with any personal information. This Policy will be assessed and updated by Leadiant from time-to-time to reflect new technologies, business practices and our users’ needs. You should consult this Policy when you visit our Website to stay current on our policy, including any updates. If we revise this Policy, we will indicate at the bottom of this page the date this Policy was last revised. We may also notify you, either through the Website, in an email notification or through other reasonable means.

If you provide Personal Information, you acknowledge and agree that such Personal Information (i) may be transferred from your current location to the offices and servers of Leadiant and the authorized third parties referred to herein located in the United States, Switzerland, Italy, the United Kingdom, Germany and France; (ii) may be accessed by the national security or law enforcement agencies of those countries. Without limiting the foregoing, we have the right to cooperate fully with any law enforcement authorities or court order requesting or directing us to disclose the identity or other information of anyone posting any materials on or through the Website. When Personal Information is transferred to such parties, we use contractual or other means to ensure that a comparable level of protection as set out in this Privacy Policy is provided.

1. Scope of this Privacy Policy
Please read this Policy before using our Website. By visiting our Website, you agree and consent to the collection, use and disclosure of your Personal Information as outlined in this Policy.

2. What Personal Information Do We Collect?
We may collect and process the following Personal Information about you including but not limited to:
(a) General information, such as name, postal and/or email address, phone number, date of birth, and other information such as agreements, your communications preferences, and queries you make to Leadiant;
(b) Professional information, such as your job title, educational information, professional qualifications, work experience, professional networks, programs and activities in which you participated; and
(c) Digital information, generated from your use of the Website, such as your Internet Protocol (“IP”) address, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other data transmitted via cookies. Information about use of cookies by Leadiant can be found below under the section titled ‘Use of Cookies’.

No personal health information or sensitive personal information: We do not knowingly or intentionally collect any personal health information or sensitive personal information through the Website, unless provided by you through the Website. ‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

Unless provided solely through the Website and only as necessary to use the same, please do not submit any personal health information or sensitive personal information to us through the Website. If, however, you inadvertently or intentionally submit or transmit sensitive personal information to us, other than personal health information submitted through the Website, you will be considered to have explicitly consented to us processing that sensitive personal information. In such case, we will use and process personal health information and sensitive personal information solely for the purposes of deleting it, if and when we become aware of the same.

3. How We Obtain Your Personal Information
Leadiant may collect Personal Information that you submit directly through the Website. We also collect Personal Information from your computer or any other devices you use when visiting the Website such as IP address, domain name, Internet Service Provider, information about the date and time of your request and other information provided by tracking technologies. Please see the section below titled ‘Use of Cookies’.

4. How We Use Your Personal Information
We may use your Personal Information in a number of ways and the below are some examples.
(a) Managing our business and providing you goods and services — to administer our business and to evaluate and improve our products and services based on your preferences.
(b) Managing our relationships/communications with individuals — for example, responding to questions, comments or inquiries about applications, trials or services, inviting individuals to Leadiant events, and making proposals for future service needs.
(c) For collaboration and research purposes – to enable Leadiant to make more informed and objective decisions when identifying or engaging with healthcare professionals and key opinion leaders and managing the collaboration relationship with healthcare professionals and for scientific and statistical research purposes.
(d) Recruitment — processing professional information to assess the individual suitability for job openings at Leadiant through a link to Leadiant’s job portal (“Job Portal”). Please note that the Job Portal will be accessible through a link on the Website and use of the Job Portal will be subject to the Terms of Use and Privacy Policy of Leadiant Biosciences, Inc.
(e) To ensure our Website functions — to ensure that content from our Website is presented in the most effective manner for you and for your device.
(f) Legal or regulatory matters — to comply with our legal or regulatory requirements (such as reporting for risk management and drug safety obligations, product quality complaints or to fulfill transparency requirements with respect to transfers of value to you by us).
(g) Protection — to protect individuals (such as our employees, contractors, and patients); to protect our information and other assets; to prevent crime (such as fraud, financial crime and theft of intellectual and industry property).

5. To Whom We Disclose Your Personal Information
We may share your Personal Information in a number of ways, including for the following purposes:
(a) if we have your consent;
(b) within Leadiant and/or with our service providers (such as but not limited to a cloud service provider in Canada or the United States for data storage and other services providers conducting audits, providing IT services, assisting in or managing our clinical trials and studies), business partners and collaborators (such as external scientists);
(c) with any member of the Leadiant group of companies, which include our international affiliates, specifically Leadiant Biosciences, SA (Switzerland), Exelead, Inc. (Delaware, US), ESSETIFIN S.p.A (Italy), Leadiant Biosciences, S.p.A (Italy), Leadiant Biosciences Ltd. (UK), Sigma-Tau Arzneimittel, G.m.b.H (Germany), Leadiant, G.m.b.H (Germany), Leadiant Biosciences, SAS (France), and any other affiliate that may be subsequently formed or re-organized;
(d) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
(e) with our third parties such as public/regulatory authorities/governmental bodies (government, including social and benefits departments), and third parties who may conduct reviews and assist Leadiant with health care compliance activities, or if we are under a duty to disclose or share individuals’ Personal Information to comply with any legal or regulatory obligation or request;
(f) to respond to a subpoena, order, legal process or government request or to protect, establish or exercise our legal rights or defend against legal claims;
(g) to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud and situations involving potential threats to the reputation or physical safety of any person;
(h) in the event that we are (i) subject to negotiations for the sale of our business or part thereof to a third party, (ii) are sold to a third party or (iii) undergo a re-organization, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process or for the purpose of analyzing any proposed sale or re-organization. In addition, we may transfer your Personal Information to a third party, such as a re-organized entity or third party purchaser, or an acquirer or licensee of an existing marketed product or investigational unapproved compound or asset, to be used for the same purposes as set forth in this Policy; and
(i) to enforce any agreements we have with individuals; or to protect the rights, property or safety of employees, patients or others (e.g. visitors to Leadiant premises).

6. Use of Cookies
Cookies are small text files created when you visit a website. They are stored on the user’s computer or mobile device and are sent back to the Website or to another website that recognizes the cookie and uses the information to develop a record of the user’s online activity. We may deliver cookies (and similar internet technologies) for our own use as explained below.

In addition, we may include third party links on our Website, such as links to patient organization websites and social media platforms, and those third parties may set a cookie on your device when you activate their link. For example, we may include links to websites of various patient organizations that may be of interest to you. Those services and websites may use their own cookies to collect information on user behavior, demographics, or for personalized advertising. We do not have control over the cookies set by other websites and services, even if you access them from our Website.

Cookies may be used for Website functioning purposes and to provide access to secure areas of the Website. We do not use these cookies to track your Internet browsing activity beyond our Website.

We use analytics programs to gather aggregate data about how visitors use our Website, to identify new and repeat visitors, to understand how you navigate through our site and which resources are of interest to you. This helps us understand our web page traffic and improve our website. We only use this information for analysis purposes. We do not use this information to attempt to identify you personally, to target personalized advertising to you, or to contact you directly.

Blocking Cookies
Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookies.

If you wish to restrict or block the cookies on our Website, or indeed any other website, you can do this through your browser or mobile device settings.

Please be aware that restricting cookies may impact or reduce the functionality of some websites.

7. Your Decisions about Your Personal Information
At any time, you can contact us to:
(a) stop receiving e-mails from us;
(b) review the Personal Information held by Leadiant;
(c) withdraw your consent for our use and disclosure of your Personal Information;
(d) request a list of third parties to which Leadiant may have provided your Personal Information; and
(e) amend your Personal Information, where possible, or by writing to us at the address provided below.

You can always unsubscribe from receiving promotional e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional e-mail from us.

If you contact us to do any of the things listed above, we may require you to provide sufficient Personal Information to allow us to identify you and tell you about the existence, use and disclosure of your Personal Information and this Personal Information will only be used for this purpose.

Generally, you may withdraw at any time your consent for us to collect, use and disclose your Personal Information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use and disclose your Personal Information as may be required to provide you with our Website, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the Personal Information we require or later contact us to withdraw your consent for us to use and disclose your Personal Information, we may no longer be able to provide you with our Website.

8. Where We Process Your Personal Information
Leadiant is located in the United States of America. Personal Information about you may be accessed by entities such as companies affiliated with Leadiant that are located outside the United States. Your Personal Information may also be accessed by staff or suppliers in, transferred to and stored at, a location outside the United States, Switzerland, Italy, the United Kingdom, Germany and France.

9. Third Party Links on our Website
The confidentiality of Personal Information transmitted over the Internet cannot be guaranteed. Leadiant urges you to exercise increased caution when transmitting Personal Information over the Internet, as we cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information.

Our Website contains links to the websites of our international affiliated companies and to other third party websites which may have their own privacy policies and terms of use. Leadiant has no control over such third-party websites or their content, and this Policy does not apply to such websites. We do not accept responsibility or liability for the policies or processing of your Personal Information by websites linked to or from our Website as we do not control the privacy practices of these third parties and we strongly recommend you review the privacy settings they have set up directly with them by visiting their respective privacy related websites and policies.

10. How We Secure and How Long We Retain Your Personal Information
The Personal Information you provide to us is covered by our security policies and standards that are designed to keep your Personal Information protected from unauthorized access, disclosure, alteration and destruction. Please note, however, that while we try to create a secure and reliable Website for users, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed.

We will retain your Personal Information for as long as it is needed for the purpose(s) for which your Personal Information was collected and any other permitted purpose. Personal Information also may be retained as long as applicable laws or regulations require, or allow.

11. International Users
Please note that our Website is directed towards users who reside in Canada. If you reside or are located in a different country, the data protection laws of that country may differ from the laws of Canada. We want you to understand that when you provide your Personal Information to us, or we obtain it through your use of our Website, your Personal Information will be processed in Canada and the United States and processed in accordance with this Policy.

12. Personal Information of Children
We do not knowingly obtain Personal Information from children under 13 years of age. If we learn that Personal Information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us as explained below under “Contact Information”.

13. Contact Information
If you have any questions in relation to this Policy, or you want to obtain more information about Leadiant privacy practices, please contact us by email at info@leadiant.com or by delivery in person, by courier or by the mail, to Leadiant at: Attn. David Sandoval, Sr. Director of Legal Affairs & Chief Compliance Officer, 9841 Washingtonian Blvd., Suite 500, Gaithersburg, MD 20878, or by calling us at +1-301-948-1041. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

EFFECTIVE: JULY 1, 2020