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PharmaCadence Analytical Services, LLC Privacy Policy

Effective Date: March 27, 2026

1. Commitment to the Data Privacy Framework

PharmaCadence Analytical Services, LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

PharmaCadence Analytical Services, LLC has certified to the U.S. Department of Commerce that it adheres to the 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. PharmaCadence Analytical Services, LLC has certified to the U.S. Department of Commerce that it adheres to the 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/.

2. Scope and Role

PharmaCadence Analytical Services, LLC operates as a Contract Research Organization (CRO) providing bioanalytical sample analysis services. In this capacity, we primarily act as a Data Processor (Service Provider) on behalf of our clinical trial sponsors.

Data Types Collected: We process personal data including:

· Pseudonymized Clinical Data: Biological sample data, subject IDs, and bioanalytical results provided by Sponsors.

· Business Contact Information: Names, titles, and email addresses of our Sponsors’ and vendors’ employees for contract management and project communication.

3. Choice (Opt-Out/Opt-In)

Individuals have the right to opt out of (a) their personal data being disclosed to a third party (other than our agents/sub-processors), or (b) their personal data being used for a

purpose that is materially different from the purpose for which it was originally collected. To exercise these rights, please contact us at privacy@pharmacadence.com. For clinical trial data, we will coordinate your request with the relevant Trial Sponsor.

Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information.” We will not use Sensitive Information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless you have provided your affirmative and explicit consent (opt-in).

4. Accountability for Onward Transfer

PharmaCadence Analytical Services, LLC remains responsible and liable under the DPF Principles if third-party agents (sub-processors) that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless PharmaCadence Analytical Services, LLC proves that it is not responsible for the event giving rise to the damage.

PharmaCadence discloses personal information to the following types of third-party agents for the specified purposes:

· Cloud Infrastructure and Hosting Providers: Used to host applications and provide secure data storage for our analytical services.

· Business Productivity and Collaboration Platforms: Used for internal communication, document management, and project coordination.

· Laboratory Information Management Systems: Used for the secure management of laboratory data and scientific documentation to ensure data integrity.

These third parties are authorized to process personal information only as necessary to provide these services to us and according to our documented instructions.

5. Data Integrity and Purpose Limitation

We process personal data only in a way that is compatible with and relevant to the purpose for which it was collected or authorized by the individual. We take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.

6. Data Subject Rights (Access)

Individuals in the EU, UK, and Switzerland have the right to access their personal data and to limit the use and disclosure of that data. Because we process pseudonymized data for

clinical trials, individuals should first contact their clinical site or the trial Sponsor to exercise these rights. Per the DPF Pharmaceutical and Medical Products Supplement, the right to access or erase data may be restricted if doing so would undermine the scientific integrity of the clinical research.

7. Dispute Resolution and Recourse

In compliance with the DPF Principles, PharmaCadence Analytical Services, LLC commits to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints should first contact our Information Security Officer at: privacy@pharmacadence.com.

PharmaCadence Analytical Services, LLC has further committed to refer unresolved DPF complaints to BBB National Programs, an independent dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

8. Binding Arbitration

Under certain conditions, you may invoke binding arbitration for complaints not resolved by any of the other DPF mechanisms. For more information, please see Annex I of the DPF Principles: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

9. Regulatory Oversight and Verification

The Federal Trade Commission (FTC) has jurisdiction over PharmaCadence Analytical Services, LLC’s compliance with the DPF. We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. PharmaCadence Analytical Services, LLC verifies its compliance through an annual internal self-assessment.

Download our Privacy Policy here