Bluefin Clinical Inc. Privacy Policy

Last Updated: October 3, 2023

This Privacy Policy is designed to help you understand how Bluefin Clinical Inc. and our affiliated companies (“we,” “us,” or “our”) collects, uses, processes, and shares your personal information, and to help you understand and exercise your privacy rights.

SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Policy easier to read, our websites, and other offerings are collectively called the “Services.”

We may provide additional privacy notices to individuals at the time we collect their personal information. For example, we may provide a specific privacy notice to participants that describes our privacy practices in connection with conducting clinical trials or when you submit your information for recruitment to one of our clinical trials. These additional privacy notices may supplement this Privacy Policy or may apply in lieu of this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY. WE MAY REVISE THIS PRIVACY POLICY FROM TIME TO TIME IN OUR SOLE DISCRETION. IF THERE ARE ANY MATERIAL CHANGES TO THIS PRIVACY POLICY, WE WILL NOTIFY YOU AS REQUIRED BY APPLICABLE LAW. YOU UNDERSTAND AND AGREE THAT YOU WILL BE DEEMED TO HAVE ACCEPTED THE UPDATED PRIVACY POLICY IF YOU CONTINUE TO USE OUR SERVICES AFTER THE NEW PRIVACY POLICY TAKES EFFECT.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain states, additional disclosures about the information we collect is available in our supplemental disclosure below.

Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

Our uses of these Technologies fall into the following general categories:

Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

Administrative Purposes

We use your information for various administrative purposes, such as:

We may use your information for other legitimate business purposes as permitted by law.

Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, text messages, and custom audiences advertising

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

We may also share your information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.

SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES

This Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Utah and Virginia (collectively, “Applicable State Laws”).

The following table describes the categories of personal information we have collected and whether we disclose that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

Category of Personal Information Collected by us

Identifiers.

A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.

Personal information categories

A name, physical characteristics or description. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

Internet or other electronic network activity

Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of certain state law, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under California law, you may limit such sharing by following the instructions found above in the section titled, Your Privacy Choices and Rights > Your Privacy Choices > Cookies and Personalized Advertising, or by contacting us as set forth in “Contact Us” below.

Additional Privacy Rights for Residents of Certain States

Non-Discrimination. Residents of certain states have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by applicable law.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of Virginia, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

CONTACT US

We are the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Bluefin Clinical Inc.  [email protected]

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