Last updated: 3 October 2025

This privacy notice for Nazata Bio Ltd ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Download and use our mobile application (HeartShield), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

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SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We process sensitive health data when necessary with your consent or as otherwise permitted by applicable law for the operation of HeartShield as a medical device. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so. We maintain two separate data processing activities: Essential DiGA Operation (required for medical functionality) and Optional Product Improvement Analytics (consent-based). Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We share information with specific data processors under strict data protection agreements. We do not sell your data or use it for third-party advertising. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information, including AES-256 encryption and EU-only data residency in Frankfurt, Germany. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at [email protected]or by visiting http://www.nazatabio.com/delete-data-request. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

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TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Contact preferences
• Personal health data (including blood pressure readings, heart rate, steps, weight, medication adherence, lifestyle data)
• IP addresses
• Data on hardware used
• Data on operating system used
• Crash logs including stack traces

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Health data (special category data under GDPR Article 9)

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's biometrics, push notifications, health app on iOS, Google Health on Android, storage, camera, microphone, reminders, sensors, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.nazatabio.com/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programmes, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We maintain two separate data processing activities with different legal bases and purposes.

Data Processing Activities

We maintain two distinct data processing activities:

Activity 1: Essential DiGA Operation & Technical Stability (Required)

This processing is essential for HeartShield to function as a medical device and is required for regulatory compliance:

• Clinical Health Data Processing: To provide personalised hypertension management, safety monitoring, and to maintain records required under EU Medical Device Regulation (MDR 2017/745)
• Technical Stability Monitoring: To detect crashes, monitor performance, and ensure patient safety through pseudonymised error tracking

This activity operates independently and does not require your consent as it is necessary for the medical functionality of the device.

Activity 2: Optional Product Improvement Analytics (Consent-Based)

This processing helps us improve HeartShield but is completely optional:

• User Behaviour Analysis: To understand how users interact with the app and identify improvement opportunities
• Feature Usage Tracking: To determine which features are most valuable to users

This activity requires your explicit consent and can be disabled at any time without affecting core DiGA functionality.

Specific Processing Purposes

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user enquiries/offer support to users. We may process your information to respond to your enquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To personalise a user's treatment course based on their healthcare data, conditions, and goals.
• To develop new medical applications using data, such as early warning systems for adverse events, improved methods of improving patient lifestyle such as exercise and diet quality.
• To comply with medical device regulatory requirements, including maintaining records required under EU MDR 2017/745 for post-market surveillance and safety monitoring.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, for public good or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Article 9(2)(j) GDPR - Scientific Research

For clinical health data processing (blood pressure, heart rate, medication, lifestyle data), we rely on Article 9(2)(j) GDPR, which permits processing of special category health data for scientific research purposes. This legal basis is used specifically for:

• Operating HeartShield as a digital therapeutic medical device
• Conducting post-market surveillance and safety monitoring
• Maintaining regulatory compliance with EU MDR 2017/745
• Developing evidence-based improvements to hypertension management

This processing includes appropriate safeguards for data subjects' rights, including:

• AES-256 encryption
• EU-only data residency (Frankfurt, Germany)
• Data minimisation principles
• 10-year retention period as required by MDR 2017/745

Article 6(1)(f) GDPR - Legitimate Interests

For technical stability monitoring (crash reports, performance diagnostics), we rely on Article 6(1)(f) GDPR as we have a legitimate interest in ensuring patient safety through:

• Detecting and resolving software crashes that could impact medical functionality
• Monitoring system performance to maintain device reliability
• Identifying and addressing security vulnerabilities

This data is processed in a pseudonymised manner with no personal identifiers, and our legitimate interest in patient safety outweighs any minimal privacy impact.

Article 9(2)(a) GDPR - Explicit Consent

For optional product improvement analytics, we rely on Article 9(2)(a) GDPR (explicit consent). This processing is entirely optional and includes:

• User behaviour analysis for product improvement
• Feature usage tracking
• User experience optimisation

You have complete control over this processing and can:

• Opt out at any time without affecting core functionality
• Withdraw consent with one click in the app settings
• Continue using all essential DiGA features regardless of your analytics preference

Other Legal Bases

We may also rely on the following legal bases where appropriate:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information with specific data processors who assist in providing our Services. We have strict data protection agreements in place with all processors. We do not sell your data or use it for third-party advertising of any kind.

Data Processors

We may share your data with third-party vendors, service providers, contractors, or agents ('data processors') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We do not sell your data or otherwise use it for third-party advertising of any kind.

Our Approved Data Processors

ProcessorServiceData LocationPurposeLegal SafeguardsAmazon Web Services (AWS)Cloud infrastructure and database hostingFrankfurt, Germany (EU)Essential DiGA operation, clinical data storageStandard AWS Data Processing Agreement, ISO 27001, SOC 2SentryError tracking and crash reportingFrankfurt, Germany (EU)Technical stability monitoring (pseudonymised)Data Processing Agreement, EU data residencyPostHogProduct analyticsFrankfurt, Germany (EU)Optional product improvement (consent-based only)Data Processing Agreement, EU data residency

Important Notes:

• All data processing occurs exclusively within the European Union (Frankfurt, Germany)
• No international data transfers outside the EU/EEA occur
• All processors maintain ISO 27001 or equivalent security certifications
• We conduct annual reviews of all data processing agreements

The categories of third parties we may share personal information with are as follows:

• Data Analytics Services (consent-based only)
• Data Storage Service Providers
• Cloud Computing Services
• Communication & Collaboration Tools
• Government Entities (when legally required)
• Payment Processors
• Performance Monitoring Tools
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Regulatory Authorities. We may be required to share information with regulatory authorities such as the German Federal Institute for Drugs and Medical Devices (BfArM), the Irish Data Protection Commission, or other competent authorities as required by law.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.nazatabio.com/cookie-policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law. Different categories of data have different retention periods based on their purpose and regulatory requirements.

Clinical Health Data Retention

Retention Period: 10 years from last use of the application

Legal Basis: EU Medical Device Regulation (MDR 2017/745, Annex XV, Article 10.3) and German Regulation on Good Clinical Practice (§ 13 GCP-V)

Data Covered: Blood pressure readings, heart rate, medication records, lifestyle data, and all other health-related information collected as part of HeartShield's medical functionality

Rationale: As HeartShield is a medical device under EU MDR, we are legally required to maintain clinical records for post-market surveillance, safety monitoring, and regulatory compliance purposes.

Deletion: Clinical data will be automatically deleted 10 years after your last use of HeartShield or account termination, whichever is later.

Technical Monitoring Data Retention

Retention Period: 2 years

Data Covered: Pseudonymised crash reports, error logs, performance diagnostics

Rationale: Necessary for ongoing medical device safety monitoring and technical support

Optional Analytics Data Retention

Retention Period: 2 years (or immediate deletion upon consent withdrawal)

Data Covered: Product usage analytics, user behaviour data (only collected with explicit consent)

Deletion: If you withdraw consent for analytics, this data is deleted immediately. Otherwise, it is retained for 2 years to enable product improvement analysis.

General Account and Administrative Data

Retention Period: Duration of your account plus 6 months

Data Covered: Email address, account settings, communication preferences

Deletion: Deleted 6 months after account termination unless longer retention is required for legal, accounting, or regulatory purposes.

When we have no ongoing legitimate business need to process your personal information (and no regulatory requirement to retain it), we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures, including AES-256 encryption, EU-only data residency, and strict access controls.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. These measures include:

Technical Safeguards

• End-to-End Encryption: All health data is encrypted using AES-256 encryption both in transit and at rest
• Hardware-Secured Keys: Encryption keys are generated using hardware security features on your device
• EU Data Residency: All data is processed and stored exclusively within the European Union (Frankfurt, Germany)
• Virtual Private Cloud (VPC) Isolation: Our infrastructure operates in an isolated network environment
• Real-Time Monitoring: Automated security monitoring and alerting for potential threats
• Input Validation: Comprehensive validation of all user inputs to prevent injection attacks
• Regular Security Updates: Systematic patching and updating of all software components

Organisational Safeguards

• Privacy by Design: Privacy considerations integrated into all product development decisions
• Staff Training: Mandatory data protection training for all team members (see GDPR Training Records)
• Data Protection Officer: Independent DPO oversight of all data processing activities
• Access Controls: Strict role-based access controls limiting who can access personal data
• Incident Response: Documented procedures for detecting and responding to data breaches within GDPR timeframes

Procedural Safeguards

• Annual Security Reviews: Regular assessment of security measures and controls
• Vendor Management: Thorough vetting and ongoing monitoring of all data processors
• Data Protection Impact Assessments: Regular DPIAs to identify and mitigate privacy risks
• Audit Trails: Comprehensive logging of all access to and modifications of personal data

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Data Breach Response: In the unlikely event of a data breach, we have procedures in place to:

• Detect and contain the breach within 2 hours
• Assess risk to affected individuals within 12 hours
• Notify the Irish Data Protection Commission within 72 hours (when required)
• Notify affected individuals directly if there is high risk to their rights and freedoms
• Document all incidents and implement additional safeguards to prevent recurrence

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 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 may have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at [email protected].

We will consider and act upon any request in accordance with applicable data protection laws, typically within 30 days (1 month).

Your Specific Rights

Right of Access

You have the right to request access to the personal data we hold about you. You can:

• Export your data directly through the HeartShield app (Settings > Privacy > Export My Data)
• Request a copy via email to [email protected]

Right to Rectification

If your personal data is inaccurate or incomplete, you can:

• Update most information directly in the HeartShield app
• Contact us at [email protected] for data you cannot update yourself

Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal data. However, please note:

• Clinical health data must be retained for 10 years due to EU Medical Device Regulation (MDR 2017/745) requirements
• Other data (analytics, marketing) can be deleted immediately
• We will explain what can and cannot be deleted and the legal reasons

To request erasure, visit http://www.nazatabio.com/delete-data-request or email [email protected].

Right to Restriction of Processing

You can request that we restrict processing of your personal data in certain situations, such as when you contest the accuracy of the data.

Right to Data Portability

You have the right to receive your health data in a structured, commonly used, and machine-readable format (JSON or CSV). Use the in-app export function or contact us at [email protected].

Right to Object

You can object to processing based on legitimate interests. Note that essential medical device functions cannot be objected to, but optional analytics can be disabled at any time.

Right to Withdraw Consent

For processing based on consent (optional analytics), you can withdraw consent at any time:

• Go to HeartShield app Settings > Privacy > Analytics
• Toggle off "Share usage data"
• Withdrawal takes effect immediately and does not affect core functionality

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected] or through the in-app privacy settings.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Access and update information through the HeartShield app Settings
• Contact us at [email protected]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, subject to the retention requirements described in Section 6. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements (particularly the 10-year retention requirement for clinical data).

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.nazatabio.com/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at [email protected] or contact our Data Protection Officer at [email protected].

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollectedA. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYesB. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYesC. Protected classification characteristics under state or federal lawGender and date of birthYesD. Commercial informationTransaction information, purchase history, financial details, and payment informationNoE. Biometric informationFingerprints and voiceprintsNoF. Internet or other similar network activityBrowsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisementsYesG. Geolocation dataDevice locationYesH. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNoI. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNoJ. Education InformationStudent records and directory informationNoK. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsYesL. Sensitive personal InformationHealth dataYes

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us, plus 6 months
• Category B - As long as the user has an account with us, plus 6 months
• Category C - As long as the user has an account with us, plus 6 months
• Category F - 2 years (if analytics consent provided)
• Category G - Duration of app session
• Category K - 2 years (if analytics consent provided)
• Category L - 10 years from last use (EU MDR requirement)

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your enquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We do not sell personal data or use it for third-party advertising.

California Residents

California Civil Code Section 1798.83, also known as the 'Shine The Light' law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a 'residents' as:

1. every individual who is in the State of California for other than a temporary or transitory purpose and
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as 'non-residents'.

If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation (including EU MDR retention requirements), or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We collect sensitive personal information (health data). You have the right to direct that we limit its use to that which is necessary to perform the Services (essential DiGA functionality). To exercise this right, disable optional analytics in the app Settings or email [email protected].

Once we receive your request, we will no longer use or disclose your sensitive personal information for optional purposes (product improvement analytics) unless you provide consent for additional uses.

Please note that sensitive personal information collected for essential medical device functionality is not covered by this right, as it is necessary to perform the Services and comply with regulatory requirements.

To exercise your right to limit use and disclosure of sensitive personal information, please email [email protected] or visit: http://www.nazatabio.com/delete-data-request

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by visiting http://www.nazatabio.com/delete-data-request, by visiting https://www.nazatabio.com/contact, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.

'Sale of personal data' means the exchange of personal data for monetary consideration.

If this definition of 'consumer' applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at [email protected] or visit http://www.nazatabio.com/delete-data-request.

If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Jeff McBride:

Email: [email protected]
Phone: +353 86 2280846

You may also contact us at:

Email: [email protected]
Phone: +353 83 111 7791

Post:
Nazata Bio Ltd
Clonmellon
Navan, Co. Meath
C15 VK71
Ireland

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To request to review, update, or delete your personal information, please:

• Visit: http://www.nazatabio.com/delete-data-request
• Email: [email protected]
• Use the in-app privacy controls: Settings > Privacy

We will respond to your request within 30 days (1 month) in accordance with GDPR requirements.

Please note: Due to EU Medical Device Regulation (MDR 2017/745) requirements, clinical health data must be retained for 10 years from last use. We will explain what data can and cannot be deleted based on these regulatory obligations.

Last updated: 3 October 2025

This privacy notice for Nazata Bio Ltd ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Download and use our mobile application (HeartShield), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

​

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We process sensitive health data when necessary with your consent or as otherwise permitted by applicable law for the operation of HeartShield as a medical device. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so. We maintain two separate data processing activities: Essential DiGA Operation (required for medical functionality) and Optional Product Improvement Analytics (consent-based). Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We share information with specific data processors under strict data protection agreements. We do not sell your data or use it for third-party advertising. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information, including AES-256 encryption and EU-only data residency in Frankfurt, Germany. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at [email protected]or by visiting http://www.nazatabio.com/delete-data-request. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

​

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

​

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Contact preferences
• Personal health data (including blood pressure readings, heart rate, steps, weight, medication adherence, lifestyle data)
• IP addresses
• Data on hardware used
• Data on operating system used
• Crash logs including stack traces

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Health data (special category data under GDPR Article 9)

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's biometrics, push notifications, health app on iOS, Google Health on Android, storage, camera, microphone, reminders, sensors, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.nazatabio.com/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programmes, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We maintain two separate data processing activities with different legal bases and purposes.

Data Processing Activities

We maintain two distinct data processing activities:

Activity 1: Essential DiGA Operation & Technical Stability (Required)

This processing is essential for HeartShield to function as a medical device and is required for regulatory compliance:

• Clinical Health Data Processing: To provide personalised hypertension management, safety monitoring, and to maintain records required under EU Medical Device Regulation (MDR 2017/745)
• Technical Stability Monitoring: To detect crashes, monitor performance, and ensure patient safety through pseudonymised error tracking

This activity operates independently and does not require your consent as it is necessary for the medical functionality of the device.

Activity 2: Optional Product Improvement Analytics (Consent-Based)

This processing helps us improve HeartShield but is completely optional:

• User Behaviour Analysis: To understand how users interact with the app and identify improvement opportunities
• Feature Usage Tracking: To determine which features are most valuable to users

This activity requires your explicit consent and can be disabled at any time without affecting core DiGA functionality.

Specific Processing Purposes

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user enquiries/offer support to users. We may process your information to respond to your enquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To personalise a user's treatment course based on their healthcare data, conditions, and goals.
• To develop new medical applications using data, such as early warning systems for adverse events, improved methods of improving patient lifestyle such as exercise and diet quality.
• To comply with medical device regulatory requirements, including maintaining records required under EU MDR 2017/745 for post-market surveillance and safety monitoring.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, for public good or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Article 9(2)(j) GDPR - Scientific Research

For clinical health data processing (blood pressure, heart rate, medication, lifestyle data), we rely on Article 9(2)(j) GDPR, which permits processing of special category health data for scientific research purposes. This legal basis is used specifically for:

• Operating HeartShield as a digital therapeutic medical device
• Conducting post-market surveillance and safety monitoring
• Maintaining regulatory compliance with EU MDR 2017/745
• Developing evidence-based improvements to hypertension management

This processing includes appropriate safeguards for data subjects' rights, including:

• AES-256 encryption
• EU-only data residency (Frankfurt, Germany)
• Data minimisation principles
• 10-year retention period as required by MDR 2017/745

Article 6(1)(f) GDPR - Legitimate Interests

For technical stability monitoring (crash reports, performance diagnostics), we rely on Article 6(1)(f) GDPR as we have a legitimate interest in ensuring patient safety through:

• Detecting and resolving software crashes that could impact medical functionality
• Monitoring system performance to maintain device reliability
• Identifying and addressing security vulnerabilities

This data is processed in a pseudonymised manner with no personal identifiers, and our legitimate interest in patient safety outweighs any minimal privacy impact.

Article 9(2)(a) GDPR - Explicit Consent

For optional product improvement analytics, we rely on Article 9(2)(a) GDPR (explicit consent). This processing is entirely optional and includes:

• User behaviour analysis for product improvement
• Feature usage tracking
• User experience optimisation

You have complete control over this processing and can:

• Opt out at any time without affecting core functionality
• Withdraw consent with one click in the app settings
• Continue using all essential DiGA features regardless of your analytics preference

Other Legal Bases

We may also rely on the following legal bases where appropriate:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information with specific data processors who assist in providing our Services. We have strict data protection agreements in place with all processors. We do not sell your data or use it for third-party advertising of any kind.

Data Processors

We may share your data with third-party vendors, service providers, contractors, or agents ('data processors') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We do not sell your data or otherwise use it for third-party advertising of any kind.

Our Approved Data Processors

ProcessorServiceData LocationPurposeLegal SafeguardsAmazon Web Services (AWS)Cloud infrastructure and database hostingFrankfurt, Germany (EU)Essential DiGA operation, clinical data storageStandard AWS Data Processing Agreement, ISO 27001, SOC 2SentryError tracking and crash reportingFrankfurt, Germany (EU)Technical stability monitoring (pseudonymised)Data Processing Agreement, EU data residencyPostHogProduct analyticsFrankfurt, Germany (EU)Optional product improvement (consent-based only)Data Processing Agreement, EU data residency

Important Notes:

• All data processing occurs exclusively within the European Union (Frankfurt, Germany)
• No international data transfers outside the EU/EEA occur
• All processors maintain ISO 27001 or equivalent security certifications
• We conduct annual reviews of all data processing agreements

The categories of third parties we may share personal information with are as follows:

• Data Analytics Services (consent-based only)
• Data Storage Service Providers
• Cloud Computing Services
• Communication & Collaboration Tools
• Government Entities (when legally required)
• Payment Processors
• Performance Monitoring Tools
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Regulatory Authorities. We may be required to share information with regulatory authorities such as the German Federal Institute for Drugs and Medical Devices (BfArM), the Irish Data Protection Commission, or other competent authorities as required by law.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.nazatabio.com/cookie-policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law. Different categories of data have different retention periods based on their purpose and regulatory requirements.

Clinical Health Data Retention

Retention Period: 10 years from last use of the application

Legal Basis: EU Medical Device Regulation (MDR 2017/745, Annex XV, Article 10.3) and German Regulation on Good Clinical Practice (§ 13 GCP-V)

Data Covered: Blood pressure readings, heart rate, medication records, lifestyle data, and all other health-related information collected as part of HeartShield's medical functionality

Rationale: As HeartShield is a medical device under EU MDR, we are legally required to maintain clinical records for post-market surveillance, safety monitoring, and regulatory compliance purposes.

Deletion: Clinical data will be automatically deleted 10 years after your last use of HeartShield or account termination, whichever is later.

Technical Monitoring Data Retention

Retention Period: 2 years

Data Covered: Pseudonymised crash reports, error logs, performance diagnostics

Rationale: Necessary for ongoing medical device safety monitoring and technical support

Optional Analytics Data Retention

Retention Period: 2 years (or immediate deletion upon consent withdrawal)

Data Covered: Product usage analytics, user behaviour data (only collected with explicit consent)

Deletion: If you withdraw consent for analytics, this data is deleted immediately. Otherwise, it is retained for 2 years to enable product improvement analysis.

General Account and Administrative Data

Retention Period: Duration of your account plus 6 months

Data Covered: Email address, account settings, communication preferences

Deletion: Deleted 6 months after account termination unless longer retention is required for legal, accounting, or regulatory purposes.

When we have no ongoing legitimate business need to process your personal information (and no regulatory requirement to retain it), we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures, including AES-256 encryption, EU-only data residency, and strict access controls.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. These measures include:

Technical Safeguards

• End-to-End Encryption: All health data is encrypted using AES-256 encryption both in transit and at rest
• Hardware-Secured Keys: Encryption keys are generated using hardware security features on your device
• EU Data Residency: All data is processed and stored exclusively within the European Union (Frankfurt, Germany)
• Virtual Private Cloud (VPC) Isolation: Our infrastructure operates in an isolated network environment
• Real-Time Monitoring: Automated security monitoring and alerting for potential threats
• Input Validation: Comprehensive validation of all user inputs to prevent injection attacks
• Regular Security Updates: Systematic patching and updating of all software components

Organisational Safeguards

• Privacy by Design: Privacy considerations integrated into all product development decisions
• Staff Training: Mandatory data protection training for all team members (see GDPR Training Records)
• Data Protection Officer: Independent DPO oversight of all data processing activities
• Access Controls: Strict role-based access controls limiting who can access personal data
• Incident Response: Documented procedures for detecting and responding to data breaches within GDPR timeframes

Procedural Safeguards

• Annual Security Reviews: Regular assessment of security measures and controls
• Vendor Management: Thorough vetting and ongoing monitoring of all data processors
• Data Protection Impact Assessments: Regular DPIAs to identify and mitigate privacy risks
• Audit Trails: Comprehensive logging of all access to and modifications of personal data

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Data Breach Response: In the unlikely event of a data breach, we have procedures in place to:

• Detect and contain the breach within 2 hours
• Assess risk to affected individuals within 12 hours
• Notify the Irish Data Protection Commission within 72 hours (when required)
• Notify affected individuals directly if there is high risk to their rights and freedoms
• Document all incidents and implement additional safeguards to prevent recurrence

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 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 may have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at [email protected].

We will consider and act upon any request in accordance with applicable data protection laws, typically within 30 days (1 month).

Your Specific Rights

Right of Access

You have the right to request access to the personal data we hold about you. You can:

• Export your data directly through the HeartShield app (Settings > Privacy > Export My Data)
• Request a copy via email to [email protected]

Right to Rectification

If your personal data is inaccurate or incomplete, you can:

• Update most information directly in the HeartShield app
• Contact us at [email protected] for data you cannot update yourself

Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal data. However, please note:

• Clinical health data must be retained for 10 years due to EU Medical Device Regulation (MDR 2017/745) requirements
• Other data (analytics, marketing) can be deleted immediately
• We will explain what can and cannot be deleted and the legal reasons

To request erasure, visit http://www.nazatabio.com/delete-data-request or email [email protected].

Right to Restriction of Processing

You can request that we restrict processing of your personal data in certain situations, such as when you contest the accuracy of the data.

Right to Data Portability

You have the right to receive your health data in a structured, commonly used, and machine-readable format (JSON or CSV). Use the in-app export function or contact us at [email protected].

Right to Object

You can object to processing based on legitimate interests. Note that essential medical device functions cannot be objected to, but optional analytics can be disabled at any time.

Right to Withdraw Consent

For processing based on consent (optional analytics), you can withdraw consent at any time:

• Go to HeartShield app Settings > Privacy > Analytics
• Toggle off "Share usage data"
• Withdrawal takes effect immediately and does not affect core functionality

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected] or through the in-app privacy settings.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Access and update information through the HeartShield app Settings
• Contact us at [email protected]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, subject to the retention requirements described in Section 6. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements (particularly the 10-year retention requirement for clinical data).

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.nazatabio.com/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at [email protected] or contact our Data Protection Officer at [email protected].

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollectedA. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYesB. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYesC. Protected classification characteristics under state or federal lawGender and date of birthYesD. Commercial informationTransaction information, purchase history, financial details, and payment informationNoE. Biometric informationFingerprints and voiceprintsNoF. Internet or other similar network activityBrowsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisementsYesG. Geolocation dataDevice locationYesH. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNoI. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNoJ. Education InformationStudent records and directory informationNoK. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsYesL. Sensitive personal InformationHealth dataYes

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us, plus 6 months
• Category B - As long as the user has an account with us, plus 6 months
• Category C - As long as the user has an account with us, plus 6 months
• Category F - 2 years (if analytics consent provided)
• Category G - Duration of app session
• Category K - 2 years (if analytics consent provided)
• Category L - 10 years from last use (EU MDR requirement)

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your enquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We do not sell personal data or use it for third-party advertising.

California Residents

California Civil Code Section 1798.83, also known as the 'Shine The Light' law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a 'residents' as:

1. every individual who is in the State of California for other than a temporary or transitory purpose and
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as 'non-residents'.

If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation (including EU MDR retention requirements), or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We collect sensitive personal information (health data). You have the right to direct that we limit its use to that which is necessary to perform the Services (essential DiGA functionality). To exercise this right, disable optional analytics in the app Settings or email [email protected].

Once we receive your request, we will no longer use or disclose your sensitive personal information for optional purposes (product improvement analytics) unless you provide consent for additional uses.

Please note that sensitive personal information collected for essential medical device functionality is not covered by this right, as it is necessary to perform the Services and comply with regulatory requirements.

To exercise your right to limit use and disclosure of sensitive personal information, please email [email protected] or visit: http://www.nazatabio.com/delete-data-request

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by visiting http://www.nazatabio.com/delete-data-request, by visiting https://www.nazatabio.com/contact, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email [email protected] or visit http://www.nazatabio.com/delete-data-request.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.

'Sale of personal data' means the exchange of personal data for monetary consideration.

If this definition of 'consumer' applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at [email protected] or visit http://www.nazatabio.com/delete-data-request.

If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Jeff McBride:

Email: [email protected]
Phone: +353 86 2280846

You may also contact us at:

Email: [email protected]
Phone: +353 83 111 7791

Post:
Nazata Bio Ltd
Clonmellon
Navan, Co. Meath
C15 VK71
Ireland

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To request to review, update, or delete your personal information, please:

• Visit: http://www.nazatabio.com/delete-data-request
• Email: [email protected]
• Use the in-app privacy controls: Settings > Privacy

We will respond to your request within 30 days (1 month) in accordance with GDPR requirements.

Please note: Due to EU Medical Device Regulation (MDR 2017/745) requirements, clinical health data must be retained for 10 years from last use. We will explain what data can and cannot be deleted based on these regulatory obligations.