PRIVACY NOTICE

Last updated November 15, 2023

Welcome to the Privacy Notice of OASYS NOW ('Company', 'we', 'us', or 'our'). This describes how and why we, acting as a controller of personal information might collect, store, use, and/or share ('process') your information when you use and enjoy our services ('Services'), such as when you:

• Visit our website at http://www.oasysnow.com, or any website of ours that links to this Privacy Notice.
• Create an account, or use any Services related to our (web)application.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns on the way the data is processed, please contact us at info@oasysnow.com, or by post at the following address: YES!Delft at Molengraaffsingel 12, 2629 JD Delft, The Netherlands.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with OASYS NOW and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? In accordance with our commitment to the protection of personal data and in line with the principles set forth in the General Data Protection Regulation (GDPR), we consistently strive to employ state-of-the-art technical and organisational measures. This encompasses the pseudonymisation and encryption of personal data, ensuring the ongoing confidentiality, integrity, availability, and resilience of our processing systems and services, as well as maintaining a proactive stance in restoring data availability and access following any physical or technical incidents. However, it is essential to acknowledge that, given the inherent vulnerabilities of internet-based data transmission and storage technologies, it is not feasible to guarantee absolute security. Our measures are designed to ensure a high level of security appropriate to the identified risks while upholding the rights and freedoms of natural persons. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting info@oasysnow.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what OASYS NOW does with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

SUMMARY OF KEY POINTS

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

Information automatically collected

Information collected from other sources

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data
• Billing addresses
• Location
• Date of birth
• Login information for social media and/or email accounts that you connect to your Account. For more information about this, see section 6 “How do we handle your social logins”.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Health data
• Medical diagnosis
• Sex assigned at birth
• Information revealing race or ethnic origin

Social Media and e-mail Login Data. We may provide you with the option to register with us using your existing social media or e-mail account details, like your Google account, Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.

Once you register, you will be able to review and change this information at any time just by logging into your OASYS NOW account. It is your responsibility to ensure that all personal information that you provide to us are kept up to date. All the personal information provided by you must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, when you visit our site or when you use our App, we may collect information by using cookies and similar Technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services, as we use this information to personalise our services and make the experience easier for you.

If you have given us access to your location, but wish to turn this off, you can do so by the following methods:

1. iPhone app – settings 🡪 privacy 🡪 location services 🡪 OASYS NOW
2. Android – settings 🡪 location 🡪 OASYS NOW 🡪 permissions 🡪 location

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, subscriptions, payments, returns, and exchanges made through the Services.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and Prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

• To create user profiles based on health & DNA data. We may use personal information to create user profiles in order to match a user to relevant studies and clinical trials.

• To perform internal statistical analysis of our users' data. We may use personal users' information in order to perform internal statistical analysis of our user base.

• To test new technologies and processes designed to enhance and improve the App/Sites. We may use personal users' information in order to test new technologies and processes designed to enhance and improve the App/Sites.

1.  OUR MATCHING ALGORITHMS

• We have developed matching algorithms to predict your compatibility with relevant studies and clinical trials we think are a good match for you. Our matching algorithms use the following data about you to predict your compatibility with different studies and clinical trials and to generate recommendations: the things you tell us about yourself in your profile; information about your activity in our app; and your device coordinates, which are necessary to understand your proximity to relevant studies or clinical trials. The legal basis for processing profile and proximity information is that this is necessary for the provision of our contractual services to you pursuant to Article 6(1)(b) GDPR. Where we process information about your app activity, this is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, and specifically our legitimate interest in generating more personalised and relevant recommendations for you with in our App. If you have chosen to include sensitive information in your profile, such as information about your beliefs, health information, DNA information, race, among others, the processing of this information is based on your voluntary and explicit consent.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses.

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. You have the right to object to our use of your data under this legal basis. For example, we may process your personal information for some of the purposes described in order to:

• Analyse how our Services are used so we can improve them to engage and retain users.
• Diagnose problems and/or prevent fraudulent activities.
• Understand how our users use our products and services so we can improve user experience.
• Match a user profile to the eligibility criteria of research studies.
• Perform internal statistical research.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are Involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Hereby, to provide a more detailed overview of the legal bases we use we have set out the table below.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services
• Data Analytics Services
• Data Storage Service Providers
• Government Entities
• User Account Registration & Authentication Services
• Healthcare parties

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using an email or a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins), or your gmail account details. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, troubleshooting problems, assisting with investigations, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us, unless statutory requirements require us to keep your personal information for a longer period of time.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

In accordance with our commitment to the protection of personal data and in line with the principles set forth in the General Data Protection Regulation (GDPR), we consistently strive to employ state-of-the-art technical and organisational measures. This encompasses the pseudonymisation and encryption of personal data, ensuring the ongoing confidentiality, integrity, availability, and resilience of our processing systems and services, as well as maintaining a proactive stance in restoring data availability and access following any physical or technical incidents. However, it is essential to acknowledge that, given the inherent vulnerabilities of internet-based data transmission and storage technologies, it is not feasible to guarantee absolute security. Our measures are designed to ensure a high level of security appropriate to the identified risks while upholding the rights and freedoms of natural persons.

Although we will do our very best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Some handy tips to help you keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account.
2. Please do not share the password you use to access your OASYS NOW Account with anyone else.
3. Change your password periodically.

If you ever think someone has had access to your password or Account, we recommend that you update your password immediately. Please reach out to our Support Team directly with any other concerns at info@oasysnow.com.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use OASYS NOW. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. Furthermore, we will verify the identity of users that create an account with us, to the best of our ability. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@oasysnow.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any Time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include:

1. Right to be informed about what personal data an organisation is processing and why (we provide this information to you in this Privacy Notice).
2. Right to request access and obtain a copy of your personal information.
3. Right of rectification and correction of inaccurate personal data.
4. Right to request erasure and deletion of your personal data in certain circumstances.
5. Right to restrict the processing of your personal information: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability by requesting a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances, including where data is processed on the basis of legitimate interests or for the purpose of marketing, you may object to that processing.
8. Rights not to be subject to automated decision making.

You can exercise such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files if required or permitted by law, for reasons such as preventing fraud, troubleshooting problems, enforcing our legal terms and/or comply with applicable legal Requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at info@oasysnow.com.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@oasysnow.com or contact us by post at:

OASYS NOW

Molengraaffsingel 12

Delft, Zuid-Holland 2629 JD

Netherlands

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at: info@oasysnow.com. If you have an account with us via our application, you can delete your personal information via your personal profile page.