Anthos Privacy Notice

Last updated and effective as of January 17, 2025.

Introduction

This Privacy Notice explains the practices that Anthos Therapeutics, Inc. (“Anthos”, “we”, “us”, “our”) follows in connection with the personal data that we collect through this website, when you contact us directly, when you apply for a job with us, and through our research.

We may change this Privacy Notice at any time by posting the revised Privacy Notice on this site and indicating the effective date of the revised Privacy Notice. You will be notified of any material changes to this Privacy Notice by email if you have provided that information to us. We will not materially change the rights you may exercise under this Privacy Notice without your explicit consent.

What is Personal Data?

In the context of the work that Anthos performs, personal data refers to any information that relates to an identified or identifiable individual. Examples include name, email, mailing address, phone number, or any information related to an individual’s health for the purposes of our research.

Personal Data Collection and Processing

The following are the types of personal data we may collect and process from you:

Communication

For communication about general and/or media inquiries with our representatives through our website contact form, email, or phone, we directly collect your contact information such as your name, email address, and contact message.

Careers

When you reach out to us about career opportunities and/or apply for employment through our website contact form, we directly collect your contact information and details related to your professional qualifications. This includes your name, email address, and contact message. You may choose to also provide additional details such as your phone number, company, and social media profile (e.g., LinkedIn).

Research

For our research purposes, we do not collect your personal data directly. Your personal data is collected through our partners (“Clinical Sites”) that manage the clinical trials we sponsor. These partners collect your personal data either as a participant of the clinical trial or as an employee or contractor affiliated with the Clinical Site.

The patient data that we obtain and use from Clinical Sites are pseudonymized and managed through an identifier that we cannot link back to you. Only the Clinical Sites that have collected your personal data can link you with the identifier they provide to us. The personal data we obtain and process from Clinical Sites, with your consent, may include the following:

  • An identifier to track future data against;
  • data concerning your health and how you are responding within the clinical trial;
  • genetic and biometric data.

The employee or contractor data that we obtain from Clinical Sites are used to conduct background checks, verify the qualifications of individuals, satisfy documentation requirements for their employment or work performed in connection with the clinical trial, and for other administrative purposes related to their work performed in connection with the clinical trial. The personal data we require the Clinical Sites to share with us regarding prospective employees, contractors, or job candidates that perform work in our clinical trials may include:

  • Name;
  • mailing address;
  • curriculum vitae;
  • training records;
  • financial disclosures;
  • any correspondence between the Clinical Site and the employee or contractor related to their interest in performing work or being employed in connection with the clinical trial.

Purpose of Personal Data Processing

Anthos will process your personal data for the following purposes:

  • to acknowledge, communicate, and respond to your contact requests;
  • to start the recruitment process if you wish to apply to one of our open positions;
  • to provide you with a better navigation experience when you visit our website;
  • to review the outcomes of the clinical trial;
  • to review the qualifications of the Clinical Site employees and contractors assigned to perform work on the clinical trial.

Legal Basis for Processing

In order to comply with different privacy and data protection regulations around the world, and specifically to comply with the General Data Protection Regulation (“GDPR”) in the European Union (“EU”), we are required to provide a legal basis for the processing of your personal data.

Anthos will not process (e.g., which includes to disclose, share, or otherwise disseminate) your personal data unless we have a legal justification to do so. Anthos will only process your personal data when:

  • we or the Clinical Sites we partner with, have obtained your explicit consent prior to the processing of your personal data;
  • we need your personal data to perform a contractual obligation to which you are a party or where you have requested us to complete a contractual request;
  • we need to process your personal data to fulfill our legal and regulatory obligations; or
  • we have a legitimate interest that will not put your fundamental rights and freedoms at risk.

Personal Data Disclosure

Anthos will only disclose your personal data without your consent to the following parties under specific circumstances:

  • to Anthos personnel if required to fulfill your request;
  • to service providers that support our systems or support the activities of the clinical trial, including the Clinical Sites that hold personal data about patients, employees, and/or contractors;
  • to law enforcement, regulatory bodies, or courts in response to legal requests by public authorities, including to meet national security or law enforcement requirements or when we are required to do so under applicable laws and regulations;
  • in connection with the sale or reorganization of all or part of our business, as permitted by applicable law.

Personal Data Security

Anthos is committed to protecting the personal data we collect, process, and disclose about you. We maintain appropriate safeguards and take reasonable steps to protect your personal data, limit its use, and disclose it only to the parties that have a legitimate reason to have access to it.

We ensure that all the parties that we disclose your personal data to, internal and external to Anthos, have contractual obligations to protect the security and the confidentiality of your personal data.

Personal Data Transfers

Your personal data will be transferred to systems that reside in the United States (“US”). The data will be protected and pseudonymized in some cases to ensure that the risks to your privacy are minimized.

We have also implemented Standard Contractual Clauses, where appropriate, with parties that reside in the EU and that will transfer personal data to Anthos in the US.

Personal Data Retention

For clinical trials, Anthos and the Clinical Sites that we partner with will retain your personal data for as long as necessary to support research purposes, typically for a period of 25 years, and to comply with legal and regulatory obligations.

Rights You Can Exercise About Your Personal Data

Subject to any exceptions provided by law, you have the right to request access to, update, or deletion of your personal data. Additionally, you have the right to request restrictions on or object to the processing of your personal data, and you have the right to request to have your data transferred to another organization in a commonly used format.

For each particular case, we will inform you of the potential consequences of your request and if there are any exemptions to honouring your requests based on legal or contractual requirements.

During a clinical trial, your rights to access, update, or delete your pseudonymized personal data may be limited as permitted by law. This is to preserve the integrity and accuracy of research for reasons of public interest in public health, as well as for archiving in public interest, scientific, or historical research purposes, or for statistical purposes.

How To Exercise Your Personal Data Rights

To submit any request to exercise your rights concerning your personal data, you may contact us via email at Privacy@anthostx.com.

European Union Representative

MyData-TRUST France
Valpark – rue Louis Duvant, 1 – 59220 Rouvignies (FRANCE)
Contact : Gautier Sobczak
+33 9 70 70 20 09
anthos.dpr.eu@mydata-trust.info

United Kingdom Representative

Waldeck House, Lyne Lane, Chertsey, KT16 0AW (UNITED KINGDOM)
Contact : Gautier Sobczak
+44 56 0375 0073
anthos.dpr.uk@mydata-trust.info

EU Individuals – Right to Lodge a Complaint with A Supervisory Authority

If you reside in the EU and want to lodge a complaint with a Supervisory Authority, you may do so in the Member State where you reside, where you work, or where you may have experienced an issue with the processing of your personal data. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Contact Us

If you have any further questions regarding the personal data that Anthos or any of our partners collect and process, or if you have feedback regarding this Privacy Notice, please contact us at Privacy@anthostx.com.