Privacy Policy

Effective Date: 16 APR 2026

Bringing Meaningful Therapies from One to Many

1. PRIVACY NOTICE

Actio Biosciences, Inc. and affiliates (“Actio,” “we,” “us” or “our”) utilizes genetics and precision medicine to develop treatments targeting the shared biology of rare and common diseases. This Privacy Notice describes how Actio processes personal information that we collect through our digital or online properties or services that link to this Privacy Notice (including as applicable, our website and social media pages) as well as activities described in this Privacy Notice (collectively, the “Service”). Actio may provide additional or supplemental privacy notices to individuals for activities we engage in (such as clinical trials) at the time we collect personal information.

3. PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
1. Contact data, such as your first and last name, salutation, email address, mailing address, professional title and organization name, and phone number.
2. Demographic data, such as your city, state, country of residence, postal code, and age.
3. Personal health data, such as medical history, medical diagnosis, and genetic testing results.
4. Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
5. Company updates, such as press releases, program updates including informational updates regarding clinical trials.
6. Job application data, such as your professional and educational qualifications, employment history, work-related skills, resume/CV, and other data or content you may provide to us in connection with your application to work at Actio.
7. Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.
Through our digital or online properties, unless we specifically direct you otherwise, we ask that you not provide us with any health-related information (including any information regarding your past, present or future physical or mental health status).
Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
1. Public sources, such as government agencies, public records, and other publicly available sources.
2. Private sources, such as data providers, social media platforms and data licensors.
3. Collaborators, such as advocacy groups, academic partners, and event co-sponsors.
4. Service providers that provide services on our behalf or help us operate the Service or our business.
5. Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
1. Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
2. Online activity data, such as pages or screens you viewed, content you viewed or otherwise engaged with, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
3. Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
For more information concerning our automatic collection of data, please see the Tracking & other technologies section below.

4. TRACKING & OTHER TECHNOLOGIES

Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:
1. Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
2. Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
3. Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.

5. HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:
1. Provide the Service and operate our business;
2. Enable security features of the Service;
3. Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
4. Provide support for the Service, and respond to your requests, questions and
  feedback.
Service personalization. This may include using your personal information to:
1. Understand your needs and interests;
2. Personalize your experience with the Service and our Service-related communications; and
3. Remember your selections and preferences as you navigate webpages.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Clinical Trial Communications. We and our service providers collect and use your personal information only if you voluntarily sign up to receive updates about our products in clinical trials. These communications may be tailored based on the information you provide. You can opt out of receiving these updates at any time, as described in the Your Choices section below.
Compliance and protection. We may use your personal information to:
1. Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
2. Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
3. Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
4. Enforce the terms and conditions that govern the Service; and
5. Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Recruitment and hiring. We may use your personal information, such as data submitted to us in a job application, to facilitate our recruitment activities and process job applications.
Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de- identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

We may share your personal information with the following parties (or as otherwise described in this Privacy Notice, in other applicable notices, or at the time of collection).

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Actio, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Actio as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

7. YOUR CHOICES

Opt-out of communications. You may opt-out of company emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.
Cookies and other technologies. Cookie preferences are device- and browser-specific, and most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, some features of the Service may not function as intended. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals, and you may use other mechanisms described in this section (such as cookie controls) to manage your privacy preferences. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide our Services. If you do not provide the information we identify as required or mandatory, our ability to provide the Service to you may be limited or impaired.
For California residents. California residents may send us requests (to privacy@actiobio.com) for information regarding third parties to whom we have disclosed certain personal information (as defined under California’s “Shine the Light” law, Cal. Civ. Code Section 1798.83) during the preceding calendar year for those third parties’ own direct marketing purposes and the categories of personal information disclosed. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

8. OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

9. STORAGE AND SECURITY

Currently, we store this personal information in a file only accessible to the Chief Operating Officer and a dedicated advocacy advisor.

Upon launch of patient websites, we will store this personal information in a HIPAA-compliant cloud-based customer relationship management (CRM) platform that provides secure backend database functionality for our patient education websites. When patients or family members sign up for more information, their contact details and related information are stored in the protected environment. If you have signed up to receive updates, but no longer wish to have your personal information stored, please email privacy@actiobio.com to be removed from the platform.

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. These include secure transmission protocols, access controls, and vendor contractual requirements ensuring continued compliance with applicable privacy and data-protection regulations. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.

10. INTERNATIONAL DATA TRANSFER

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States and other locations, where privacy laws may not be as protective as those in your state, province, or country.

11. CHILDREN

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

12. DATA PROTECTION RIGHTS

If you live in Australia, you have the following rights set out below.

Access and Correction. You have the right to access and seek correction of your personal information held by us. Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.
Complaints. You have the right to complain about your privacy rights. If you have such a complaint, please contact us using the information provided in the How to contact us section below.

You may exercise any of the above rights by contacting us through any of the methods provided in the How to contact us section below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your personal information, you may be charged a fee subject to a maximum set by applicable law.

13. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on the Service or other appropriate means. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Notice indicates your acknowledging that the modified Privacy Notice applies to your interactions with the Service and our business. Depending on the kind of change we make to this Privacy Notice, we might notify you of the change or request your consent to it.

14. HOW TO CONTACT US

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.