Privacy Policy

PRIVACY POLICY

Last Update: September 22, 2023

At Inversago Pharma Inc. (“INVERSAGO”, “we”), we respect your privacy and are committed to maintaining your trust. This Privacy Policy (the “Policy”) describes our privacy practices regarding the collection, use, storage, sharing and protection of your Personal Information by INVERSAGO on our website (the “Site”).

By visiting our Site you consent to the collection, use and disclosure of your Personal Information as set out in this Policy, and to our Terms and Conditions, which should be read.

1. PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, including any information that directly or indirectly identifies such individual. In general, Personal Information does not include business contact information, such as your name, title, or business contact information when it is collected, used and disclosed solely for the purpose of communication in relation to your business or profession.

2. PERSONAL INFORMATION MANAGEMENT PROGRAM

In order to protect your Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold. To obtain more information about such policies, practices and procedures, we invite you to contact our Privacy Officer:

Privacy Officer (all countries except Serbia)

1100 René-Lévesque Blvd West, Suite 1110
Montreal, Quebec  H3B 4N4 Canada

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Privacy Officer (Serbia)

1100 René-Lévesque Blvd West, Suite 1110
Montreal, Quebec  H3B 4N4 Canada

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3. BASIS FOR PROCESSING PERSONAL INFORMATION

INVERSAGO may need to collect and process some of your Personal Information in order for you to use our Site. When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Policy. We use Personal Information in accordance with the privacy laws applicable to our business.

As required by applicable privacy legislation, INVERSAGO collects the majority of your Personal Information on the basis of your voluntary consent, favouring collection directly from you. For example, INVERSAGO undertakes to obtain your explicit consent for the collection of any sensitive Personal Information, in particular where your employment is concerned. However, when permitted by applicable privacy laws, INVERSAGO may collect Personal Information without your express consent, for example, to comply with obligations under applicable laws or to fulfill our contracts.

4. PERSONAL INFORMATION COLLECTED

Depending on the nature of your activity on the Site, we may collect your Personal Information, including:

• Information relating to the use of the Site: for example, date and time of visits, geolocation data (with your consent), duration of presence on the Site, pages clicked and connection IP address);

• Information relating to applications you may submit to us: for example, name, curriculum vitae, address and employment history;

• Feedback information: for example, when you fill in forms that we may include on our Site.

5. PURPOSES OF COLLECTING PERSONAL INFORMATION

We only collect Personal Information that we consider necessary for the following purposes:

• To present our services via the Site;

• To answer your questions, queries, comments or complaints;

• To meet our business objectives, such as developing new products and services, improving or modifying our products and services;

• For data analysis purposes, including the identification of usage trends, and to determine the effectiveness of our promotional campaigns and commercial activities;

• To send you administrative information, for example, information about our services and changes to our terms, conditions and policies;

• If you have consented to it, to send you marketing communications that we think may be of interest to you, such as newsletters, one-time promotional e-mails, direct mailings, business contacts or newsletters;

• For audit, surveillance and fraud prevention purposes;

• To comply with or act under any applicable law or regulation, including but not limited to: (i) respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (ii) to protect our operations and legitimate interests or those of our subsidiaries; (iii) to enable us to pursue available remedies or limit the damages we may suffer, etc.

• To facilitate and improve the use of our Site, as long as the Personal Information collected is used proportionally to this purpose;

• For any other purpose to which you have consented.

If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law.

6. DISCLOSURE OF PERSONAL INFORMATION

Your Personal Information will not be sold to third parties.

We share your Personal Information with third parties to: (i) fulfill our purposes, (ii) respond to requirements or requests made under applicable laws. Most of the time, you have already consented to such sharing. Sometimes applicable laws also allow us to share your Personal Information with third parties without your consent, in specific cases. Specifically, we may need to share your Personal Information, sometimes without your consent:

• With our employees. In the course of their work, our employees and officers may have access to your Personal Information, for example when you contact us. Their access is limited to what is necessary for the performance of their duties.

• With our service providers. Our business partners may need to access or receive certain Personal Information in order to perform their services (such as cloud data hosting, maintenance, analysis, fraud detection and development). In such cases, we implement reasonable contractual and technical safeguards to ensure that these third parties keep all Personal Information they process strictly confidential. Please note that these third parties may not be located in your province, state, territory or country of residence.

• With authorities or persons authorized by law. We may share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with applicable laws; (ii) comply with the order of a competent judicial authority in any jurisdiction; (iii) comply with legal proceedings; (iv) protect and defend the rights of INVERSAGO; (v) to the extent applicable, enforce or verify your compliance with any part of your contracts with us; (vi) prevent fraud or other illegal activity perpetrated through the service; or (vii) act in urgent circumstances to protect the personal safety of users of our services or the general public.

• With potential buyers of our company. We may need to share your Personal Information without your consent in the event of a merger, acquisition or sale of all or part of the business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.

• Third parties abroad. Your Personal Information may be disclosed and stored outside your province, state, territory or country of residence. Our business partners and service providers may be located in the province of Quebec or in other provinces, states, territories or countries. Please be aware that we have contractual agreements with these third parties to ensure that your Personal Information is handled in accordance with the laws applicable to us. Where applicable, we conduct privacy impact assessments prior to any transfer of Personal Information to another jurisdiction, such as outside Quebec.

7. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

INVERSAGO will retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected or to comply with applicable legal, tax or regulatory requirements. After such period, any Personal Information concerned and held by INVERSAGO will be destroyed, deleted or anonymized.

8. SECURITY

The security of your Personal Information is a priority for us. Your Personal Information is hosted by our service providers who are committed to using reasonable security measures to preserve the integrity and confidentiality of your Personal Information. Our employees and suppliers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorized access to Personal Information. We maintain our service and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your Personal Information. These safeguards vary according to the sensitivity of the data in our possession, and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), you may contact our Privacy Officer.

9. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

Depending on applicable laws, where you live and how you interact with the Site, you may be granted certain rights with respect to the Personal Information we hold about you. For example, you may be entitled to:

• Obtain access to the Personal Information we hold about you;

• Request correction of Personal Information we hold that is inaccurate, misleading or incomplete;

• Request the deletion of your Personal Information;

• Obtain additional information, for example on the categories of third parties to whom we communicate your Personal Information;

• Request the portability of your Personal Information in a structured, commonly used and machine-readable format;

• Withdraw your consent (if any);

• File a complaint with a privacy control authority, such as a privacy commissioner or the Commission d’accès à l’information.

File a complaint. You may file a complaint with the Privacy Officer of INVERSAGO if you are dissatisfied with our handling of your Personal Information or compliance with this Policy. You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.

Exercising your rights. You can exercise your rights listed above by sending a written request to our Privacy Officer. He or she will be happy to assist you in any way he or she can. We may need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within 30 days.

10. YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF PERSONAL INFORMATION

The information you provide may be used by INVERSAGO for marketing purposes, including, but not limited to, one-time promotional e-mails, direct mailings and business contacts. We offer you several choices regarding our use and disclosure of your Personal Information with respect to marketing, location data, Cookies or online advertising. You may opt-out:

• Our electronic marketing communications. We will not send you electronic marketing communications unless you opt-in. You may later unsubscribe from our electronic mailing lists at any time. If you so request, we will not use your contact information for future marketing purposes. Please note that we may nevertheless send you messages for administrative purposes, and you cannot refuse to receive these messages without ceasing to use the associated product or service.

• Non-essential cookies. You can deactivate these cookies by following the procedure described in the “How to manage cookies” section.

11. COOKIES

A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. In this Policy, the term “Cookie” includes other tracking technologies, including but not limited to web beacons and tracking pixels. These tracking technologies are not necessarily stored on your computer or device. Any Personal Information we collect using Cookies or on our behalf is treated with the same level of confidentiality as any other Personal Information we hold.

a. Essential cookies. These Cookies are necessary for the operation of the Site and provide basic functions and may include maintaining your session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Site. However, if you wish, you can block or delete them by changing your browser settings and forcing all Cookies on the Site to be blocked.

b. Non-essential cookies. Non-essential Cookies provide certain non-essential functionalities on our Site, for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.

• Functional Cookies: We use these Cookies to facilitate non-essential functionalities of our Site, such as the integration of content such as videos or the sharing of Site content on social media.

• Advertising Cookies: Our Site does not display advertisements but if it did, these Cookies would help us to track the effectiveness of our advertising campaigns and to personalize our ads so that they are meaningful to you.

• Analytical Cookies: These Cookies store information such as the number of visitors to our Site or the page they have visited. They help us to understand and analyze the performance of our Site and our potential improvements.

c. How to manage Cookies. You can manage and deactivate Cookies through your browser’s Cookie settings and your mobile device’s advertising settings. However, if you refuse Cookies, you may not be able to use all the features of the Site. We do not display advertisements but if we did and you refuse Cookies, you would continue to receive it, but it would no longer be as tailored to your needs.

12. CHANGES TO THIS PRIVACY POLICY

We revise the Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice on our Site or by e-mail. However, in all other circumstances, the posting of a new version of the Policy on our Site or your continued use of the Site will suffice as notice and consent to the Policy changes.