Additional Information for Individuals Located in the EEA, Switzerland, or UK

This GDPR Privacy Addendum (the "GDPR Privacy Addendum") supplements the information contained in our Privacy Policy and applies solely to the users of Services who are located in the European Economic Area, the United Kingdom, or Switzerland. We adopt this GDPR Privacy Addendum to comply with the European Union's General Data Protection Regulation, and any laws implementing the foregoing by any member states in the European Economic Area, the United Kingdom (including the UK Data Protection Act and the UK-GDPR), and or Switzerland (collectively, the "GDPR"). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our Privacy Policy have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our Privacy Policy.

If you have any questions about this GDPR Privacy Addendum, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section.

Information We Collect About You and How We Collect It

The Personal Data we collect and the ways in which we collect it is described in our Privacy Policy, including such sensitive or special categories of personal data as set forth in the California Privacy Addendum.

The Personal Data we collect from you is provided with your consent, is required to enter into a contract with us, for us to perform under the contract, and/or to provide you with our Services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Lawful Basis for Processing Your Personal Data

GDPR requires us to have a legal basis for collecting and using or otherwise processing your Personal Data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter.

Automated Decision Making

We may use automated decision-making to evaluate an individual's questionnaire responses and determine whether such individual qualifies for a clinical trial. We use such automated decision-making to enable Curebase to deliver clinical trial qualification decisions within a shorter time frame and to improve efficiency. You may have the right to request that a human review the decision or to opt-out of the automated decision-making by contacting us using the "Contact Information" below.

How We Use Your Information

We use your Personal Data as described in our Privacy Policy.

Disclosure of Your Information

We do not share or otherwise disclose your Personal Data for purposes other than to the entities and for the purposes described in our Privacy Policy.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

The GDPR provides you with certain rights with regard to our processing of your Personal Data. These rights replace the similar rights provided in our Privacy Policy or are supplemental to such rights.

• Access and Update. You may contact us if you wish to review or change any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. You have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used, and machine-readable format under certain conditions. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Object. You have the right to object to our processing of your Personal Data when the processing is based on our legitimate interests and your objection is not overridden by a compelling legitimate ground. You have the right to object to marketing activities at any time.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided through our Services, including User Contributions, is governed by our Terms of Service.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law. We will aim to respond to your request within thirty (30) days and in accordance with any deadline or extension set forth in applicable law.

Important: The exact scope of these rights vary depending on where you live and applicable law. There are also several exceptions, including research-specific exceptions, where we may not have an obligation to fulfill your request. We will not discriminate against you for exercising any of these rights.

Consent to Processing of Personal Data In Other Countries Outside the European Economic Area, the United Kingdom, and Switzerland

In order to provide our Services, we may transfer your Personal Data outside of the EEA, the UK, or Switzerland, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. You represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States. Such processing is conducted pursuant to the lawful bases described above.

When we transfer personal information subject to the data protection laws of the European Economic Area ("EEA"), the United Kingdom ("UK"), or Switzerland outside of the EEA, UK, or Switzerland to the United States, we rely on the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-US DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For more details, please review the Curebase Data Privacy Framework Policy which applies to Personal Data transferred from member countries of the European Economic Area, the United Kingdom (and Gibraltar), and Switzerland pursuant to the DPF.

Data Retention

Unless you request us to delete your Personal Data (subject to the above) earlier, we will retain your Personal Data as set forth in our Privacy Policy.

Changes to This GDPR Privacy Addendum

We may change this GDPR Privacy Addendum at any time. It is our policy to post any changes we make to our GDPR Privacy Addendum on this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this GDPR Privacy Addendum to check for any changes.

Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or this GDPR Privacy Addendum, have any requests related to your Personal Data described in the Privacy Policy or this GDPR Privacy Addendum, or otherwise need to contact us, you can do so at the contact information below.

• Email: privacy@curebase.com
• Telephone: 1-833-977-3116
• Postal Mail: 548 Market Street PMB 86319, San Francisco, CA 94104-5401

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is: Instant EU GDPR Representative Ltd.

Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.