Privacy Notice

Privacy Notice

This Privacy Notice explains the practices that Wugen Inc. (“Wugen”, “we”, “us”) follows in connection with the personal data that is collected in order to achieve our mission.

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How We Collect and Process Your Personal Data

Clinical Research

For the purpose of our research, we do not collect your personal data. Your personal data is collected by the clinical study centers that manage the clinical trials that we sponsor. They collect your personal data as a participant of the clinical trial or as Clinical Site investigator or personnel involved in the clinical trial.

The patient data that we obtain and use from the clinical study center is pseudonymized, de-identified, and managed through an identifier that we cannot link back to you. Only the Clinical Site that collected your personal data is able to link it with the identifier they provide to us. The data we obtain from the Clinical Site and process, with your consent, includes:

• An identifier to track future data against
• Data concerning your health and how you are responding to the clinical trial
• Genetic data

The data related to the clinical site investigator and personnel is used to verify eligibility, satisfy documentation requirements for work performed related to the clinical trial, to verify any financial conflict of interest and for other administrative purposes related to the work performed related to the clinical trial.

Our Legal Basis for Processing Your Personal Data

In order to comply with different privacy and data protection regulations around the world and specifically to comply with the General Data Protection Regulation (“GDPR”) in the European Union (“EU”) and the Data Protection Act of 2018 (“UK GDPR”) in the UK (“UK”), we are required to provide a legal basis for the processing of your personal data.

Wugen will not process your personal data unless we have a legal justification to do so. Wugen will only process your personal data if:

• We or the clinical sites we work with, have obtained your explicit consent prior to the processing of your personal data;
• If we need your personal data to perform a contractual obligation to which you are a party or where you have requested us to complete a contractual request;
• If we need to process your personal data to fulfill our legal and regulatory obligations;
• If we have a legitimate interest that will not put your fundamental rights and freedoms at risk.

Disclosure of Your Information

Wugen will only disclose your de-identified personal data to the following parties under specific circumstances:

• To Wugen personnel, if required, to fulfill your request;
• To our subsidiaries and affiliates;
• To service providers that support our systems or support the activities of the clinical trial, including the Clinical Sites that hold personal data about patients and personnel;
• To enforce or apply our terms of service or contracts;
• To law enforcement, regulatory bodies or courts, when we are required to do so under applicable laws and regulations;
• In connection with the sale or reorganization of all or part of our business, as permitted by applicable law;
• If in the future we need to disclose your personal data to any other party, we will inform you in advance and will request your consent to disclose if necessary.

Security

We maintain appropriate safeguards and take reasonable steps to protect your personal data, ensure that we limit its use and that we disclose it only to the parties that have a legitimate reason to have access to it.

We ensure that all the parties that we disclose your personal data to, internal and external to Wugen, have contractual obligations in place to protect the security and the confidentiality of your personal data at the same level that Wugen does.

Data Transfers and Storage

Your deidentified personal data will be transferred to systems that reside in the United States (“U.S.”). The data will be protected at all times and pseudonymized in some cases to ensure that the risks to your privacy are minimized.

Choices and Rights Over Your Personal Data

EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States, should direct their query to privacy@wugen.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@wugen.com.

Other Rights Over Your Personal Data

Subject to any exceptions, you have the right to request access to, update or delete your personal data.

You also have the right to request restriction of or object to the processing of your personal data. And you have the right to request to have your data provided to you in an electronic format if you desire to have a copy of it.

On each particular case, we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal, contractual, or other requirements.

During a clinical trial your rights to access, update or delete your pseudonymized personal data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and integrity of the study for reasons of public interest in public health and for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

How To Exercise Your Personal Data Rights

To submit any request about your personal data you may contact us via email at privacy@wugen.com.

Changes to Our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat personal data, we will notify you through a notice on the website home page. The date the Privacy Notice was last revised is identified at the bottom of the page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.

Data Retention

Wugen will not retain your contact information after your request has been fulfilled.

Wugen and the Clinical Sites that we work with for the purpose of clinical trials will retain your personal data for as long as necessary for the purpose of research, and to comply with legal and regulatory obligations.

California Residents Notice

Wugen does not collect, process, disclose or sell your personal data for marketing purposes or for Wugen’s business benefit.

The personal data collected, processed and disclosed for the purpose of clinical trials is not subject to the California Consumer Privacy Act. However, we welcome your contact requests by reaching out to privacy@wugen.com if you wish to verify if Wugen holds any personal data about you outside of the scope of clinical trials.

How to Contact Us

If you have any further questions regarding the personal data that Wugen or any of our partners collect and process or if you have feedback regarding this Privacy Notice, you may contact us at privacy@wugen.com.

This privacy notice was last reviewed on June 30, 2025.