Introduction

This Website Privacy Policy sets forth the privacy practices of Elixion Biotech AG. and its affiliates (collectively referred to as “us” or “we” or “the Company”) through the website www.elixionbiotech.com and relevant related services (together referred to as the “site”).

Elixion Biotech AG (the “Company”) is committed to protecting your privacy online and understands its responsibilities to protect the privacy and security of personal data it collects from you or other sources.  

Please read the information below to learn how we collect, use, and protect personal data that we obtain from your and other from other sources.

This Website Privacy Policy (together with Website Terms of Use and Cookies Policy) describes how we may use your personal data and how that information may be used or disclosed by us.

Updates and Changes

We reserve the right to change this Website Privacy Policy at any time. Such changes, modifications, additions or deletions will be immediately effective and will be made available on this page. We encourage you to review the Website Privacy Policy periodically to be informed of how we use your Personal Data and to be aware of any changes. Where we are required to do so, we will communicate to you any changes to the Website Privacy Policy by sending a communication to the email address provided by the registered users.

Personal Data Collected from this Website

This section applies to all personal data collected through www.elixionbiotech.com.

For purposes of this privacy policy, “Personal Data” means any data related to you as an identified or identifiable natural person. Personal Data that we collect about you includes:

Your personal details (e.g., Your name, job title, name of employer, email address, language, and country or location, etc.) or contact details (e.g., telephone number, email address, postal address, etc.).

Information you have provided as part of the job application and selection process (such as resume, curriculum vitae (CV), candidate status, compensation, job title, location, reference letters, application materials, offer letter, immigration status, right to work in a particular country, education, etc.).

We may also ask You for Personal Information (such as when You report a problem with the Website).

Information on your use of the site, which includes but is not limited to usage details, IP addresses, location data and other communication data which will be used in accordance with the Company’s Cookie Policy.

How We Collect Your Personal Data

The types of Personal Data that we may collect and receive while you use the site include both Personal Data that you provide to us, Personal Data that we collect automatically when you use the website and Personal Data that we receive from third parties. In particular:

Personal Data That You Provide Us
You provide Personal Data to us when you:

• Visit our site;
• Register for or order services and register your email address with us;
• Complete a form;
• Apply for a position with the Company;
• Download material;
• Subscribe to receive materials, information, newsletters and job alerts; and
• Send email messages, feedback and transmit other information by telephone or letter.

We might ask you to provide other information when necessary for a requested service, where an employment opportunity is being processed or where services as an investigator in a clinical trial are being offered.

We collect Personal Data to support delivery of a diverse range of clinical research and consulting services in the pharmaceutical, biotechnology, diagnostic, and medical device industry.

We may use Personal Data to further inform you about Company news, company experience, the service offering, industry trends, or other scientific or clinical development topics.

Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory information requested with respect to a particular activity, you will be unable to engage in that activity.

Data That May Be Collected Automatically
When you use this website, we also may collect certain usage and device data automatically, including:

IP Address

We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit this website. An IP address identifies the electronic device you use to access the site, which allows us to maintain communication with your computer as you move around this website and allows us to personalize the content.

Cookies and Other Tracking Technologies

We may use cookies (and equivalent technologies) to collect and analyse information on the performance of our website and to enable it to function better. Cookies may also allow us and third parties to tailor the content and advertisements you see when you visit our website and other third-party websites in the same online network, including social networks. You can find out more information in our Cookie Policy.

Data Collected from Other Sources

We may combine Personal Data about you that is collected through the website with Personal Data that we have collected offline, as well as with Personal Data provided to us by third parties.

Use of Your Personal Information

We may use your Personal Data to provide you with the services you request, communicate with you, improve your experience on this website, process your job application, and for other internal business purposes, as described in more detail below:

Delivery of Services and Information about the Company

If you choose to submit a website form, we use the Personal Data that you provide to respond to your questions and provide you with the information or services that you request. We may use Personal Data to deliver information to you via the postal service, by email, or by phone.

Creating and Publishing Content Relevant to You

We may use your IP address and the data that we obtain automatically through the use of cookies or similar tracking technologies to make our website easier to use and navigate, as well as to personalize the content provided on the site by anticipating the information and services that may be of interest to you.

In addition, we use your IP address to diagnose problems with our servers and software, to manage our website and to gather demographic information.

Analytics and performance

We may use the information that you provide and the information we collect automatically about your use of our website to monitor user traffic patterns and preferences for our legitimate business interests of improvement, analytics, and optimization.

Provide updated information about our services

If you choose to subscribe to receive our newsletters, service updates, company news, or job alerts, we include your Personal Data in our contact database to send you communications. You may unsubscribe from receiving these communications at any time using the link in the emails we send or as described in the section below “Your rights to your Personal Data”.

Careers

Users may apply for employment at the Company through the Careers section of the website. The information supplied by candidates is collected and accessed by the Company during the recruitment process.

We use your Personal Data to communicate with you and conduct the recruitment and selection process. If you create a job candidate profile from an existing profile on an external social account or job board such as LinkedIn, the Company may collect relevant content from your application via those websites to build your candidate profile. If you register with external recruitment agencies, they may send us your job candidate profile in response to vacant positions the Company has posted. If we are provided with your Personal Data from these external parties, we will upload your profile details into our recruitment database to progress our selection process and pre-employment steps, as appropriate.

Personal Data in our recruitment database may be used to contact you about future employment opportunities in which we think you may be interested.

The Company may collect candidate feedback and opinions periodically (e.g., surveys) for business purposes, such as improving recruitment processes, subject to local legal requirements. You may respond to these surveys voluntarily or may elect not to respond and will not suffer any reprisals for your decision.

Legal and contractual obligations

We may also use your Personal Data to resolve disputes, troubleshoot problems and enforce our agreements with you, including our site Terms of Use and this Privacy Policy. 

Data Security

The Company takes appropriate technical and organisational measures, consistent with applicable laws and current industry standards, to prevent unauthorised access, accidental loss, destruction or damage to Personal Data and any unauthorised disclosure or processing. However, there is always some risk that an unauthorised third-party could intercept an internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the Internet. The Company cannot guarantee that unauthorised third parties will not gain access to your Personal Data; therefore, when submitting Personal Data to the website, you must weigh both the benefits and the risks.

In addition, your Personal Data resides on a secure server that only selected personnel of the Company and contractors have access to via password. We encrypt your Personal Data, as well, and thereby prevent unauthorised parties from viewing such information when it is transmitted to us.

We store the Personal Data you provide in a secure electronic database in order to provide you with the information and/or services you request or to comply with regulations and legal requirements. This site and the electronic database have security measures in place to protect the loss, misuse, unauthorized access or disclosure, alteration or destruction of the information under our control.
The handling of health/medical information obtained in clinical research is governed by national and international data protection regulations, laws and rules regarding the development of medicinal products and medical confidentiality. Any medical information collected is maintained under these regulations.

The Company has put in place security measures to protect the manual and electronic processing of Personal Data and prevent its misuse, subject to local legal requirements.

The Company also ensures adequate security is observed by third parties and affiliates processing Personal Data on behalf of the Company, subject to local legal requirements.

Data Retention
We will only keep Personal Data as long as necessary to fulfil the purposes outlined above, except as required by applicable laws or court orders.

We will retain your Personal Data as necessary to comply with our legal obligations, process your job application, resolve disputes, and enforce our agreements; or to the extent otherwise permitted by applicable law.

At the end of the defined retention period, the Company will delete your Personal Data unless the Company has the right to keep your Personal Data under a different legal basis or legitimate interest which allows a longer retention period.

International Transfer

The Company is a Swiss headquartered organisation. To operate as a global business, it may be necessary to process and transfer Personal Data within a group or location.

Please note there might be additional safeguards or other legal instruments which allow the transfer of Personal Data outside the EEA also without your express consent, for example, the application of Standard Contractual Clauses (SCCs) and any additional safeguards which would allow the Company to transfer data without the consent of the data subject. The Company reserves the right to use those safeguards and legal instruments to transfer Personal Data abroad for its business purposes.

If you wish to know what safeguards we use to transfer your Personal Data, please contact us using the contact information set out below.

Disclosure to Third Parties

We do provide some of our services through contractual arrangements with third parties. In particular, we share your Personal Data with:

Group of Companies

We may in due course share your Personal Data with affiliates, which adhere to our privacy and data-security requirements. In addition, during negotiations of corporate transactions, including any merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including as part of any bankruptcy or similar proceedings), we may transfer your Personal Data to third parties involved in these transactions. Under these circumstances, such third parties will enter into a confidentiality agreement with us and are obligated to protect any information and Personal Data provided as part of the transaction.

Third Parties Service Providers

We share certain information with selected service providers, vendors, hosting companies, consultants, and other providers that carry out functions or services on our behalf and that enable our business operations, including the protection and securing of our systems and services. Such service providers must abide by our privacy and data-security requirements and are not allowed to use Personal Data they receive from us for any other purpose.

Client Sponsor of Clinical Research Studies

If you apply to participate in a clinical research study as an investigator or a clinical site, we may share your Personal Data with our client sponsors, whose clinical research studies are within your stated area of interest, as part of the contracted services that we provide to them.

Disclosure to protect the Company and to comply with legal requirements

Occasionally we may be required by law enforcement or judicial authorities to provide Personal Data to governmental authorities. We may disclose Personal Data upon receipt of a court order, or subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

The Company may be obliged to disclose certain Personal Data to third parties such as government authorities.  It may also be necessary to disclose Personal Data so as to protect the legal interests and exercise other rights of the Company, subject to local legal requirements.

A complete list of third parties to whom the Personal Data are shared can be obtained by contacting the Company’s Data Privacy Officer (“DPO”) at data_privacy@elixionbiotech.com.

Sensitive or Special Category of Personal Data

The Company ensures special protection for Sensitive or Special Category of Personal Data. This includes Personal Data relating to:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetic data
• biometric data
• data concerning health
• data concerning a natural person’s sex life or sexual orientation
• health data

The Company may process this type of Personal Data for the purposes of equal opportunities monitoring, or if it is prescribed by applicable law, or it is needed for the protection of life, health or freedom, or if it is required for the performance of your employment contract, subject to appropriate security safeguards and local legal requirements.

If required by local law, your explicit consent may be obtained to the processing of this type of Personal Data.

Exceptions

Except as described herein, we will not otherwise use or disclose any of your Personal Data, except to the extent reasonably necessary:

• to correct technical errors and to technically process your Personal Data;
• to protect the security and integrity of elixionbiotech.com;
• to protect any Company property or rights or obligations and/or the property, rights or obligations of third parties where the Company may have an obligation or liability in respect of these;
• to take precautions against potential liability on the part of the Company;
• to any extent required by law, applicable regulation or judicial process;
• to any extent permitted under any other applicable legal or regulatory provisions to provide information to law enforcement agencies or to provide information in respect of a matter related to public safety.

Use of Cookies

When you use our website, we may store cookies on your computer in order to facilitate and customize your use of our website. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you. Our cookies store randomly assigned user identification numbers and identify the country where you are located; the cookies make your use of the site easier, make the site run more smoothly and help us maintain a secure site. You are free to decline cookies, but some parts of our site may not work properly in that case.

The Company may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our site, the owner or service provider of the social plug-in can place a cookie on your computer or other electronic device that enables that operator to recognize individuals who have previously visited our site. If you are logged into a social media website (e.g. Facebook, LinkedIn, Twitter) while browsing on our site, the social media plug-in allows that social media website to receive information that you have visited our site. The social media plug-in also allows the social media website to share information about your activities on our site with other users of their social media website. These sharing settings are managed by the social media website and governed by its privacy policy.

For detailed information on the cookies used by our site and purposes for which they are used, please our Cookie Policy.

Your Privacy Choices

You may contact the Company to ask questions, discuss privacy matters, exercise your rights (to the extent applicable) or report your concerns. In particular, you may contact us by email at data_privacy@elixionbiotech.com or in writing to:

Elixion Biotech AG

c/o Superlab Suisse Schlieren AG

Zürcherstrasse 39D,

8952 Schlieren, Zurich

Switzerland

For the attention of the Data Privacy Officer (“DPO”).

Please provide sufficient detail for the Company to properly assess and respond to your request. The Company may be unable to respond to incomplete or vague requests. The Company will require you to provide proof of identity and proof of address before proceeding with your request. If more information is required, such as the provision of one or more forms of valid government identification, we will contact you and request additional verification.

You may authorise a third-party representative to make a request on your behalf. Any third-party representative making a request on your behalf must indicate that he/she is acting as your representative and provide the name, email address and description of the relationship with you, and a certification that he/she has permission to submit a request on your behalf. The Company may require proof of the delegation of authority to the third-party representative, including your written permission to the third-party representative, and/or a valid power of attorney. The Company reserves the right not to respond to requests that failed to show a valid proof of identity, address and/or delegation of authority.

Protection of Personal Data of Children

The Company does not knowingly collect or use any Personal Data directly of children on www.elixionbiotech.com. We do not knowingly allow children to communicate with us, or to use any of our online services. It is the Company’s view that the nature of the subject matter is unlikely to be of general interest to children. If you are a minor, please do not use the site or send any Personal Data about yourself to us. If you are a parent or the authorized legal guardian of a minor and become aware that your child has provided us with Personal Data or other information, please contact us using one of the methods specified in the section “Your Privacy Choices”, and we will work with you to address this issue.

Data Collected from Other Sites

Except as otherwise discussed in this Website Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy if you want to receive information on third parties’ online activities.

Additionally, our website may provide links to other sites. When you click on one of these links, you are leaving our site and entering another site that we do not control and for which we cannot be responsible. The companies linked or referenced on our site may collect Personal Data and other information about you when you view or click on their sites through the use of cookies. You should contact these companies directly if you have any questions about their use of the information that they collect.

Intellectual Property Notice

The graphics, documents and articles contained on this website are the copyrighted work of the Company and contain proprietary trademarks and trade names of the Company. We reserve the right to take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of this website. We also reserve to right take any action to prevent the unauthorized use of our intellectual property rights.

Additional details for Residents of the European Economic Area («EEA») and UK Residents

This section supplements the Website Privacy Policy and applies solely to residents of the European Economic Area (“EEA”) and UK residents.

Data Controller and Data Privacy Officer (“DPO”)

The Data Controller of your Personal Data, meaning the person who determines purposes and means of data processing, is Elixion Biotech AG, with a registered office at:

c/o Superlab Suisse Schlieren AG

Zürcherstrasse 39D,

8952 Schlieren, Zurich

Switzerland.

The Company has also appointed a Data Privacy Officer (“DPO”), who is responsible for overseeing compliance with EU Regulation 2016/679, the UK GDPR, and the UK Data Protection Act 2018 regarding the personal data processed by the Company. You can contact the DPO by email at data_privacy@elixionbiotech.com.

Legal Bases for Processing of Personal Data

We rely on different legal basis for the processing of your Personal Data, which also depend on the context of your interactions with the Company. Such legal basis may be your consent, a company legitimate business interest, a legal or contractual obligations.

In some cases, we process your Personal Data to comply with a contractual obligation we have with you, or to take steps that you request before we enter into that contract. We may also process your Personal Data where necessary for our compliance with a legal obligation.

If we process your Personal Data under consent provided by you, you have the right to withdraw that consent at any time as set out in the section below “Data Subjects Rights”. Your withdrawal of consent, however, will not affect the lawfulness of any processing we have undertaken before the withdrawal.

Finally, we process Personal Data we collect through the site for certain legitimate business interests. These legitimate interests relate to conducting and managing our business. When we process Personal Data for these purposes, we will ensure that we take into account your interests and privacy rights. You can object to this processing as described in the section below “Data Subjects Rights”.

Data Privacy Principles

Personal Data will be collected for the purposes specified in this Privacy Policy and used accordingly. The collection and processing of Personal Data will be limited to what is strictly necessary to fulfil these purposes and you are hereby informed in advance of the purposes and uses of such data.

Personal Data will be adequate, relevant and not excessive and relating to the purposes for which they are processed.

Personal Data will be as accurate as possible and, where necessary, kept up to date.

Personal Data will not be kept longer than is appropriate or necessary for the purposes for which it is being processed or local legal requirements.

Personal Data will be collected, used and retained in accordance with the legal rights available to the data subjects.

Data Subjects Rights

The Company would like to make sure you are fully aware of all of your data protection rights. In particular, you are entitled to the following:

The right to access: You have the right to request the Company to have access to your Personal Data or receive copies of your Personal Data or a description of the categories of Personal Data we process and the processing activities we perform.

The right to rectification: You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete information you believe is incomplete.

The right to erasure: You have the right to request that the Company erase/delete your Personal Data under certain conditions (i.e. when the Personal Data is no longer necessary for the purpose of the processing). We inform you that requests for deletion of Personal Data are subject to current legal requirements to retain documents imposed on us by laws or regulations, if applicable.

The right to restrict processing: You have the right to request that the Company restrict the processing of your Personal Data, under certain conditions, for example when you have issues with the content of the information we hold or how we have processed your personal data.

The right to object to processing: You have the right to object to the Company’s processing of your Personal Data that are based on legitimate interests, under certain conditions.

The right to data portability: You have the right to receive a copy of Personal Data in a structured, commonly used and readable by automatic devices and, where possible, request that the Company transmit the Personal Data that we have collected to another data controller, or directly to you (if technically feasible).

The right to withdraw consent: Where given, you have the right to withdraw consent at any time and without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.

The right to refuse automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Under the European Data Protection Regulation 2016/679, the Swiss nFADP, the UK GDPR and the UK Data Protection Act 2018, you have also the right to lodge a complaint directly with the Supervisory Authority of the country where you live, work or where an alleged infringement has occurred.

Please see the Your Privacy Choices section if you would like to exercise any of your rights.

When contacting us, please make sure that you include your name, email address, postal address and/or telephone number to make sure we can handle your request correctly.

If you exercise any of your rights, we have one month to respond to you. If the Company is unable to provide the requested information or make the change you request, you will be provided with reasons for such a decision.

Please be advised that if you are a patient in a clinical trial, the Company has no means by which to identify you and therefore cannot respond to privacy rights requests. You should contact the doctor/medical provider who is treating you from the clinical trial site for any requests.

Effective Date : 20 May 2025.