Proteus Services Privacy Policy Proteus Digital Health, Inc. and/or its subsidiaries and affiliates (“Proteus” or “we”) provides the InForm Medication Adherence Insights Service (the “Service”) as described in the Proteus Clinical Services Agreement. The Service is offered as a product to companies that sponsor human clinical trials (the “Customer” or “you”). This Privacy Policy applies to the information of Customer that is made available to Proteus in connection with the Services or third party information that Customer permits Proteus to access or collect in connection with the Services (collectively, “Information”), including medical information and data pertaining to clinical trial subjects (“Subjects”). Proteus treats Information according to the terms of this Privacy Policy, and treats Information as confidential in accordance with the terms of your order for Services. This Privacy Policy provides you with details of Proteus’ privacy practices, including: What Information is collected when you use the Service; How Information will be used and disclosed; and Your rights with respect to collection and use of Information. Please read this Privacy Policy carefully. By using the Service you expressly consent to the collection, use and disclosure of the Information in accordance with this Privacy Policy. As described in the Proteus Clinical Services Agreement, you will be responsible for ensuring that each Subject provides appropriate authorizations and/or waivers under HIPAA and/or other applicable privacy laws. 1. What information will Proteus collect and how will that information be used? In this Privacy Policy, ‘Your Information’ includes all of the following: the information Customer provides to us when Customer contracts for the InForm Medication Adherence Insights service (e.g., specifics of the clinical trial design, specifics about the study drug). the information relating to Subjects engaged in Customer clinical studies that is generated by the Service when it is used (e.g., information about when Subjects take study medications, activity levels, rest patterns, other physiologic metrics, patch connection to the body and the Service, patch battery status, etc.); the information generated when you or Subjects contact the Support Line or us (for example with a question about the Service) or if we contact you in connection with the Service; and We may monitor and record calls and messages from you, Subjects, or other clinical trial participants, such as clinical trial sites or clinical research organizations, for training and quality purposes. 1142760 v6/HN Proteus will use the Information to: provide you with the Service; contact you about the Service with administrative/service related notices; investigate, and assist you with, any questions or complaints that you may have about the Service; analyze your use of the Service; analyze the performance of the Service; enhance the Service and to develop new products and services; contact you for feedback, opinions and suggestions related to the Service and via email, website surveys, telephone calls and other similar means. Your participation in such feedback activities is voluntary. 2. Disclosing Your Information Proteus will not share the Information with third parties except as described in this Privacy Policy. Proteus may disclose Your Information to: our services providers who are involved in providing the Service; these third parties are required not to use the Information other than to provide the services requested by Proteus; where there is a change in the ownership of Proteus (e.g., another company acquires Proteus’s business or assets, whether by merger, sale of assets, sale of stock, through bankruptcy, or otherwise), to the new owners; the new owners will assume the rights and obligations regarding the Information as described in this Privacy Policy; in connection with any legal investigation or where Proteus (or our service providers) are required to do so by law, regulation or legal proceedings or to respond to subpoenas or warrants. To protect or defend the rights or property of Proteus (our service providers) or other users. 3. Anonymizing and aggregating Your Information Proteus may anonymize or aggregate Your Information into a form that can no longer identify you, and may use that non-identifiable information for any purpose, including to conduct and publish statistical analysis and other research on usage of the Service, to enhance the Service and, and to develop new products and services. Proteus may also pass that non-identifiable data to third parties, such as business partners, in its sole discretion. 4. Cookies A “cookie” is a text file placed on your computer or mobile device which identifies your computer/mobile device whenever you visit that website. It is used to collect standard internet log information and visitor behavior information. This information is used to track visitor use of 1142760 v6/HN the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. In order to provide the Service, Proteus may need to place cookies on your and Subjects’ computers or mobile devices. If you or Subjects alter your browser settings to reject cookies on your computer or mobile device, the Service will not function on that computer/mobile device. We may also collect your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We may use third party analytics service providers (as described below) to collect data on your usage of the Service. 7. Where Proteus stores and processes the Information Your Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of the Information may be less stringent than the laws in the country in which it was collected. 8. Retention of the Information Proteus will keep the Information for as long as it is necessary to fulfill the purposes for which it was collected, or to the extent permitted or required by law. If your access to the Service is terminated, Information pertaining to your use of the Service will only be available to you for the limited time period specified in the terms of your order for Services but may be retained by us for up to 5 years thereafter. 9. Security Proteus is committed to protecting the security of the Information. We use a variety of industrystandard security technologies and procedures to help protect the Information from unauthorized access, use, or disclosure. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Proteus uses reasonable efforts to protect the Information, Proteus cannot guarantee its absolute security. 10. Changes To This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any changes in the way we use the Information that result in a material reduction in the level of protection provided to your Information (a “Material Change”), we will notify you by sending you an e-mail to the last email address you provided to us. Any such Material Changes to this Privacy Policy will be effective upon thirty (30) calendar days following our dispatch of an e-mail notice to you. Material Changes will be effective immediately for new users. In any event, Material Changes to this Privacy Policy may affect our use of the Information that you provided us prior to our 1142760 v6/HN notification to you of the Material Changes. If you do not wish to permit Material Changes in our use of the Information, you must notify us prior to the effective date of the Material Changes that you wish to cease using the Service. Continued use of the Service, following notice of such Material Changes shall indicate your acknowledgement of such Material Changes and agreement to be bound by the terms and conditions of such Material Changes. Changes to this Privacy Policy that are not Material Changes will be effective immediately for all users. 11. Contacting us about Your Information Please contact Proteus Customer Support if you have any questions about the information that Proteus holds about you: Proteus Contact Information: Proteus Digital Health, 2600 Bridge Parkway, Suite 101, Redwood City, CA 94065 Customer Support: U.S. Phone: +1 877 285 9803 English language support available 24 hours a day, seven days a week U.K. Phone: +44 800 011 3991 English language support available 24 hours a day, seven days a week All geographies, Helpdesk Email: helpdesk@proteus-support.com 1142760 v6/HN