Privacy Notice

Effective date: September, 2025

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Please read the following information carefully. This Privacy Notice details what personal data we collect and process and how we shall use it. This Privacy Notice applies to users of the website and representatives of business with whom we may engage as partners, service providers and clients.

CLINIGMA® is headquartered in Copenhagen, Denmark and provides expert solutions in capturing patient feedback in clinical trials.

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We are dedicated to conducting our work with fairness, integrity and respect for individuals. Privacy and data protection are fundamental human rights, and we take our responsibilities in this area seriously. By handling personal data in a lawful, ethical and transparent manner, we aim to uphold the trust placed in us and ensure that individuals’ rights are protected throughout our research activities and operations.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we may contact you to inform you.

Personal data is any information about an identified or identifiable individual. Some information we ask you for directly, but other information is collected automatically.

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We may process different kinds of personal data about you as follows:

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• Technical Data may include internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
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• Marketing and Communications Data includes your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s), including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information.
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• We also process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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• Usage Data includes information about how you use our website, products, and services.
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• Business and Transaction Data includes the services and any products you have purchased from us, and information provided during your contractual relationship with us or otherwise provided by you.
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• Profile Data may include any passwords to access our systems or portals or services, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
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• Identity and Contact Data includes first name, maiden name, last name, username or similar identifier, job title, email address, telephone numbers.

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server; only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember your preferences – e.g. choice of language.

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At CLINIGMA^® we use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences. We also use cookies to help us to improve the performance of our website to provide you with a better user experience.

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• Strictly necessary cookies; Cookies that are strictly necessary in order to enable you to move around the website and use its features.
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• Functionality cookies; Functionality cookies record information about choices you’ve made and allow us to tailor the website to you.
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• Performance cookies; Performance cookies are used across CLINIGMA^® websites for internal purposes to help us to provide you with a better user experience. Information supplied by these cookies helps us understand how our visitors use clinigma.com so that we can improve our content.
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• Advertising Cookies; Pixels are used to advertise and re-target content to users.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

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Consent means that you have provided us with a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data.

We do not collect or retain sensitive personal data relating to your health, ethnic origin, religious beliefs or political conviction etc. at this site. In the rare case where we do seek to collect other sensitive data, we will do so in strict compliance with local data privacy law.

Protecting the privacy of children is important. CLINIGMA^® does not intend to collect personally identifiable information from children (a child is defined as being under the age of 18) without permission of the parent or legal guardian. Children should NOT submit personally identifiable information to CLINIGMA^® without the explicit permission of their parent or legal guardian.

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Where appropriate, we will instruct children not to submit personal data. If your child has submitted personal data and you would like to request that such information be removed, please contact us.

We may share your personal data with the parties set out below:

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Third Parties such as:

• suppliers and those who process data on our behalf.
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• those to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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• any entity to whom we are legally required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, law enforcement agency or other regulatory authority.

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

You have the right to:

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• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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• Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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• Object to processing of your personal data in certain circumstances, including where we are processing your personal data for direct marketing purposes.
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• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

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1. If you want us to establish the data's accuracy.
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2. Where our use of the data is unlawful, but you do not want us to erase it.
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3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
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4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

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• Request the transfer of your personal data to you or to a third party in certain circumstances. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
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• Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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If you want to exercise any of these rights, please contact our Data Protection Officer.

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You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used/accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data for specified purposes. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We maintain data retention schedules which define the periods for which we will store your personal data. We will only store personal data for as long as we have a legitimate need to retain it, either for statutory/legal reasons or because we need the data to be able to provide you with services or for other legitimate business needs.

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When we no longer need this information, we will anonymise your data and/or dispose of it securely. A copy of our retention schedule is available by request to the DPO.

It may be necessary to transfer your personal data outside the EU.

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Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
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• Where we use certain service providers, we may use specific contracts approved for use in the EU which give personal data the same protection it has in the EU.

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Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

Automated decision-making is the process of making a decision by automated means without any human involvement. We do not currently process your personal data in this manner.

If you have any questions about this privacy notice or the information we process about you, please contact us at info@clinigma.com or you can reach us by telephone at +45 60 78 58 86.

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You can also contact our Data Protection Officer directly:

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David Reeves

dr@clinigma.com

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If it would be helpful to have this notice provided in another format, please let us know.

If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the relevant supervisory authority or seek redress through the courts. In Denmark, the supervisory authority is the Danish Data Protection Agency (Datatilsynet), which can be contacted by calling +45 33 19 32 00 or by visiting their website at https://www.datatilsynet.dk