Spain

VitalTrax, LLC, d/b/a PatientWing, together with its subsidiaries, affiliates, and related entities (hereinafter referred to as “PatientWing,” “us,” “we,” or “our”) provides this Privacy Notice to describe the types of information we collect from you when you use our Services (which we define below), how and why we use it, and your rights with respect to the information.

1. Who We Are

PatientWing helps connect clinical trial candidates to researchers and doctors who are running clinical trials to help discover new treatments for diseases and to advance medicine (“the Services”). We provide these Services on behalf of the Sponsor whose clinical trial you are applying to (the “Clinical Trial”). PatientWing is a Processor for the Sponsor, meaning that the Sponsor directs what information we collect and how we use it.

This Privacy Notice applies only to the information we collect to provide the Services for the Clinical Trial. PatientWing offers other services directly to individuals, and when you consent to receive these services, our use of your information will be subject to a separately provided privacy notice.

2. Identity and Contact Details of the Controller

The Controller for the information we process is the Sponsor of the Clinical Trial:
Chemomab Ltd

3. Information We Collect

As directed by the Sponsor, we may collect the below information from you when you apply to participate in the Clinical Trial. All of the information we collect about you is referred to as “Information.”

Your contact information including name, email address, postal address, and telephone number(s).
Health information, including any conditions you may have, details of clinical trials you have participated in the past, and Information in medical release forms you authorize us to share.
Date of birth, gender, and race.

4. Our Uses and Disclosure of Your Information

As directed by the Sponsor, we use your Information to:

Provide the Services to you.
Verify your identity and ability to participate in the Clinical Trial.
Assist you in participating in the Clinical Trial.
Respond to your inquiries and provide you with information you request.
Comply with any applicable laws and respond to lawful requests.

As directed by the Sponsor, we use your Information to:

The clinical research site offering the Clinical Trial, to help see if you qualify for the Sponsor’s Clinical Trial and participate in the Clinical Trial if so.
Healthcare providers, if you instruct us to submit medical release forms or other information to your healthcare providers to help you participate in the Clinical Trial.
Third-Party Service Providers that perform certain functions or services on our behalf that help us provide our Services to you (e.g., to host Information or provide customer service).

We may also share your Information with supervisory or regulatory authorities or other legal bodies, solely to comply with our legal obligations.

5. Lawful Basis for Processing Your Information

We process your Information on the basis of your consent. Additionally, and as described above, when we process your Information due to a legal obligation, our lawful basis for such processing is to comply with our legal obligations.

6. Your Rights

PatientWing works with the Sponsor to support it in fulfilling your data subject requests. You have the right to:

Restrict the way that your Information is processed and shared.
Transfer your Information to a third party.
Provide you with access to your Information.
Remove your Information if no longer necessary for the purposes collected.
Update your Information so it is correct and not out of date.
Object to the processing of your Information.

You may also revoke your consent for processing of your Information.

Note that certain Information may be exempt from such requests, and you may need to provide additional information to confirm your identity when making a request.

You also have the right to lodge a complaint with the supervisory authorities applicable to you and your situation.

If you wish to exercise your rights described in this section, please contact us as described in Section 9 below and we will facilitate and/or fulfill your request.

7. Data Retention

As directed by the Sponsor, we will retain your Information only for as long as needed to provide you with the Services. However, we may also retain your Information if we have a legal obligation to retain it to comply with laws applicable to us. If we have a legal obligation to retain your Information, we will retain it for only as long as needed to comply with the legal obligation.

8. Data Transfer

We are operated in the United States, and we may use service providers based in the United States to provide the Services to you. Please be aware that Information that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Information in accordance with applicable data protection laws and regulations.

9. Contact Details of PatientWing

If you have questions or wish to exercise your rights, you can contact us in the following ways:

Email: privacy@patientwing.com

Call us: 610-589-0515

Write us: VitalTrax, LLC
Attn: Data Protection Officer
3675 Market St.
PatientWing – Suite 200
Philadelphia, PA 19104

SPRING PSC, Version 1.0, 29Mar23, UpdatedPrivacyNotice_Spain