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Privacy Statement

(Last updated on 28 August, 2025)

1. Introduction

Harvest Integrated Research Organization (“HiRO”) is committed to maintaining your trust by protecting your personal data.
Personal data is any information relating to an identified or identifiable natural person. Your name, address, phone number,
or any other detail that is specific to you are examples of personal data.

As a global organization, HiRO operates through legal entities across multiple jurisdictions. We ensure all processing
activities strictly adhere to applicable data protection laws and regulations. Where local laws impose stricter requirements
for personal data protection, such provisions will take precedence.

Any personal data you provide when interacting with HiRO will only be used in accordance with this Privacy Statement.

This Privacy Statement applies to all personal data gathered for and on behalf of HiRO through various means, including
websites, applications, email communications, and offline activities such as sales and marketing engagements.

2. Types of Personal Data We Process and Purposes

HiRO processes personal data to ensure the efficiency and effectiveness of its services and products. When you contact HiRO
to request or access information, you may be asked to provide personal data.

2.1 Website Registration and Usage

If you register on HiRO websites, including www.harvestiro.com,
we may use the information you provide to personalize your user experience. We may also collect technical information such
as IP address, browser type, operating system, domain name, access times, and referring website addresses.

2.2 Cookies

HiRO websites use cookies. Please refer to our Cookies Policy for further information.

2.3 Employment Applications

If you submit a resume or curriculum vitae to apply for a position with HiRO, we will use that information to evaluate your
qualifications and match you with relevant job opportunities.

2.4 Contact Requests

If you register to receive customized information or submit a “Contact Us” form, we may collect your name, contact details,
and email address.

2.5 Clinical Investigators and Healthcare Professionals

For clinical investigators, study researchers, data safety monitoring board members, and other healthcare professionals,
we collect professional contact information to assess suitability for clinical trial participation and may share this
information with clients.

2.6 Clinical Trial Participants

HiRO processes only pseudonymized medical and health information for clinical trial participants. This information is
collected by investigators at study sites and handled in accordance with informed consent documentation.

In sponsor-supported studies, the sponsor acts as the data controller and HiRO acts as a data processor.

2.7 Sensitive Personal Data

HiRO generally does not collect sensitive personal data unless required by law or voluntarily provided with explicit
consent. Sensitive data includes information related to health, biometrics, race, religion, political beliefs, criminal
records, or financial details.

3. Lawfulness of Processing

3.1 Consent

Where required, HiRO processes personal data based on your explicit consent. You may withdraw consent at any time by
contacting dataprotection@harvestiro.com.

3.2 Performance of a Contract

Personal data may be processed where necessary to perform contractual obligations or provide requested services.

3.3 Legitimate Interest

  • Employment and investigator opportunities
  • Service improvement
  • Website security
  • Protection of rights and property
  • Regulatory compliance

3.4 Legal Obligation

HiRO may process personal data to comply with applicable laws, regulations, and legal processes.

4. Profiling

HiRO does not use automated decision-making that produces legal effects without explicit consent. Profiling may be used
to personalize communications based on legitimate interests.

5. Data Sharing with Third Parties

Personal data may be shared with clients, service providers, regulators, or legal authorities where required. HiRO does
not sell or lease personal data.

6. Security

HiRO applies appropriate technical and organizational safeguards to protect personal data. While absolute security cannot
be guaranteed, access is restricted to authorized personnel only.

7. Worldwide Transfer of Personal Data

Personal data may be transferred internationally in compliance with applicable data protection laws and approved
transfer mechanisms.

8. Data Retention

Personal data is retained only as long as necessary to meet business, legal, and regulatory obligations.

9. Data Subject Rights

  • Right to be informed
  • Right of access
  • Right to correction
  • Right to erasure
  • Right to restrict processing
  • Right to data portability
  • Right to object
  • Rights related to automated decision-making

Requests can be made by contacting the Data Protection Officer.

10. Links to Other Websites

HiRO websites may contain links to third-party sites. HiRO is not responsible for their privacy practices.

11. Changes to This Privacy Statement

HiRO may update this Privacy Statement periodically. Updates will be reflected in the “Last Updated” date.

12. Further Information

Data Protection Officer (DPO)
Email: dataprotection@harvestiro.com