Privacy Policy

This Privacy Policy applies to your use of the EDC / eCRF solutions (the Yonalink Solutions shall collectively be referred to herein as the “Solution”) allowing for the collection of clinical and other data from clinical trial participants through varied sources, including questionnaires, medical (including wearable) hardware and the linking of Electronic Health Records with the applicable clinical trial database provided by Yonalink Ltd. (“Yonalink”, “us”, “our”, “we”). “You” or “Your” means a clinical trial participant who is a user of the Solution on behalf of a sponsor (“Participant”), a person who has signed up or is using the Solution as a standalone user (the “Standalone User”) or a user (“Administrator”) on behalf of the entity licensing the Solution (“Customer”). If you do not agree to the terms of this Privacy Policy, please do not click “Log In” or “Sign up” and do not use the Solution.

Yonalink Ltd. respects your right to privacy. Your ability to make informed choices about the uses of your information is important to us. This privacy policy details how we collect, use and store information and data that we receive. If you have any comments or questions about our privacy policies, please contact us at privacy@yonalink.com.

Please also review the Terms of Use of the Solution (the “Terms”). Terms capitalized but not defined herein have the meaning given to them in the Terms. As used in this privacy policy, “Personal Information” means information that can be directly associated with a specific person or entity such as a name, address or e-mail address.

Information We Collect

In order to sign up for the Solution you will either (i) create an account by providing us with certain information, including your name and password, (ii) click your consent through a designated link forwarded to you by Yonalink, the Customer and/or a third party on their behalf. If you are a Participant, by signing up you consent to the transfer of your Personal Information, in de-identified form, to the clinical trial database, clinical trial sponsor in accordance with the terms of the Informed Consent Form / eConsent Form that you signed when you signed up for the clinical trial. If you are a Standalone User, your Personal Information will be stored on a Yonalink database, in order to provide you with certain services and offerings included in our Solution such as identifying clinical trials that may be suitable to you. We may also ask you to give us access to your medical files and medical history located in various databases and collect information from you about your medical condition, characteristics and habits all of which will also be stored in our database. If you sign up and/or request the connection as a legal guardian, you hereby represent and warrant that you have full rights and/or have received consent from the person for the use of their Personal Information in accordance with the terms of this Privacy Policy.

The Personal Information of a Participant and/or a Standalone User which is accessed and transferred will include such information as is collected in connection with a clinical trial, including health data, gender, age and/or response to treatment and clinical trial data, as defined in the approved trial protocol or as otherwise provided by the Participant (the “Participant Information”) or Standalone User ( the “Standalone User Information”).

If you are an Administrator, during your use of the Solution we may collect sign up information as well as information concerning your use of the Solution and specific features thereof. Such Personal Information may include your name, email, address, and other contact information as well as metadata, use habits and preferences and security settings (together, the “Administrator Information”).

You are not required by law to provide us with any of the information described herein, but by using the Solution you agree to provide us with such information.

How We Use Information

We will not share your Personal Information with third parties without your explicit permission, except when required by law, regulation, subpoena or court order or as otherwise expressly set forth herein. We may use Personal Information and other information internally – for example, to provide you with goods and services, to help diagnose problems with our servers, and to make our services more useful for you and for our other customers.

We share the Participant Information with the applicable clinical trial database and trial sponsor or sponsor representative which will use it in connection with running the clinical trial. We may moreover use and share Administrator Information as needed in order to provide the Customer with services and may moreover share this Administrator Information with our third-party subcontractors that we use to assist in providing services. For example, we use third party payment processors to assist in processing your payment details. We may use and share, including with our third-party subcontractors, Standalone User Information as needed to provide you with services or for our own internal business purposes.

Your information may be shared within the Company with employees with a need to know and/or service such information

In addition, by analyzing all information we receive, we may compile anonymized and/or deidentified statistical information across a variety of users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is does not indicate individuals’ identities, and we will not link Statistical Information to any Personal Information. We may share Statistical Information, which does include clinical or medical information, with our partners, pursuant to commercial terms that we determine in our sole discretion. In addition, we may provide any information to third parties, so long as we have removed any information that identifies any particular individual or user, such as a name, address or contact information.

If you reside or are located in the United States and as a Participant or Standalone User you registered for the Solution through your healthcare provider, insurer, or any other covered entity, the Yonalink’s provision of the Solution to you will be subject to the Health Insurance Portability and Accountability Act of 1996, Subtitle D of the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”), and regulations and other guidance promulgated under both laws by the U.S. Department of Health and Human Services (collectively, “HIPAA”).

How we Protect Information

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Cookies

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. A “persistent” cookie may be used to help save your settings and customizations across visits. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please

note that some features of the Solution may not function properly when cookies are disabled or removed.

Correcting or Updating your Information.

Yonalink allows you to view the information you provided during registration and to alter any data, inaccuracies or errors. To request such access, or correct, update, or amend your personal information please contact us at the following e-mail address: privacy@yonalink.com

We will retain your Participant Information for as long as you participate in the clinical trial. We will retain Administrator Information and Standalone User Information after termination of your association with us. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at the e-mail address listed above or contact the clinical trial investigator. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Communications

If you are a Standalone User or an Administrator, we may send you email or other messages about us or our products and services as well as messages about products and services of selected third parties. By accepting the Terms (including the terms of this Privacy Policy which are incorporated therein) or using the Services, you affirmatively consent to receive such commercial messages. As a registered member, you can remove your personal information from our mailing list and to stop receiving future communication from us by following the unsubscribe link located at the bottom of each communication or by emailing us at privacy@yonalink.com. You will also be given the opportunity to unsubscribe from commercial messages in any such email we send.

Other Uses or Transfer of Your Information

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behavior of any user suspected to have engaged in illegal behavior.

We may share data with our affiliates, which may be located in countries other than your own and send them information we receive. We may also use subcontractors that are located in countries other than your own and send them information we receive. For example, we may send your information to any countries outside your jurisdiction and/or outside the United States or the European Union. All our subcontractors will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not as high as in your country of residence or business.

We may transfer our databases containing your Personal Information if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Information, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Policy. By providing such information, you expressly consent to such transfer and use, including transfers outside of the country of your residence.

Changes

We may update this privacy policy from time to time, and we encourage you to review it periodically.

Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at privacy@yonalink.com.

Last updated: June 2022