PRIVACY POLICY

Pharmaspectra Privacy Policy

Last updated: December 13, 2019

PRIVACY STATEMENT

Introduction

Pharmaspectra US, LLC (“Pharmaspectra US”) is a New Jersey Limited Liability Company with its
principal place of business located at 210 Main Street, Madison, New Jersey (United States). Pharmaspectra US,
together with its affiliates Pharmaspectra Group Ltd and Fortnite Bidco India Private Limited shall be referred to
herein together as the “Company.” This statement (“Privacy Statement”)
sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from
or about individuals located within the European Union (“EU”), the European Economic Area
(“EEA”) and Switzerland, as well as from individuals located in the United States and elsewhere in
the world. It is the Company’s policy to respect, and protect, personally identifiable information obtained
from individuals as set forth in this Privacy Statement.

There are certain provisions of this Privacy Statement that only apply to individuals from the EU or
EEA. Those sections are denoted as “EU/EEA Data Subjects Only.”

There are certain provisions of this Privacy Statement that do NOT apply to individuals from the EU or
EEA. Those sections are denoted as “Not Applicable to EU/EEA Data Subjects.”

You should also review our Terms and Conditions of use of the website, which can be found at https://www.pharmaspectra.com/terms-and-conditions/ and is applicable and
binding upon you with respect to your use of the website and is incorporated herein.

1. What Is the Scope of this Statement?

This Privacy Statement sets forth the principles under which the Company collects, uses, processes, retains, and
discloses personal data and/or sensitive data in the United States or the European Economic Area (“EEA”) or
elsewhere from individuals, including by and through our website located at https://www.pharmaspectra.com/ and services provided by the Company as referenced therein
(together, the “website”) and information you provide to us based upon information from our website
(i.e., if you send us an e-mail at an e-mail address identified on the website) or through our website (i.e., using
contact us). This statement covers information received in electronic and all other formats.

2. Terms

The terms “we”, “us” and “our” refer to the Company, and its
officers, directors, owners, employees and agents.

The term “personal data” means any data which relates to a natural person (as opposed to a business
or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term
personal data may include:

  • Names and contact information, including phone number, physical address, fax and e-mail, all only to the extent
    provided by you to us, or which you manifestly make public;
  • Potentially gender and nationality;
  • Title, position, business/company/institution name for whom you work or provide services as indicated in public
    information or as provided by you to us;
  • Referral source data (i.e., how you ended up at the website);
  • Any other similar information provided to us by you in connection with our services or through the website.

The term “data controller” means the person or entity which decides the purposes for which, and the
way in which, any personal data is processed.

The term “data processor” means the person or entity which processes personal data on behalf of the
data controller.

The term “processing” means any operation or set of operations performed on personal data.
Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or
saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or
destruction of data, or the making available of data.

3. What Information We Collect About You

We may collect all types of personal data about you as described in Section 2 above under the definition of
personal data.”

You agree that we may collect and process all such personal data that you provide to us, or that you or your employer
(or other entity for whom you provide(d) services) manifestly make public through publication or otherwise, and/or
any entity which retains us and provides to us to enable us to provide the services (the
Services”) for which we were retained by said customer and as otherwise set forth in the agreement
related to such Services. In addition to the Services identified on the website, these Services may also
include Services in connection with the use and management of the website and all content and services therein.

You also hereby consent that we may use your personal data for the following additional purposes which may be
included in, or part of, the Services:

  • Updating our records;
  • In connection with any application for employment with the Company;
  • Internal analysis for our business management purposes;
  • Any statutory or regulatory purpose which requires the processing of your personal data;
  • Legal and regulatory compliance;
  • Fraud and crime prevention;
  • Internal or external audits; and
  • Any other purpose for which valid consent is obtained.

In addition to the above, we may also collect other data from you which is not personal data, such as information
about your employer, the content of articles or other information you publish or otherwise make public, etc.

Please do not supply the following to us:

  • Any other person’s personal data, unless the Company explicitly asks you to do so;
  • Any categories of your personal data that have not been explicitly requested by the Company;
  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by
    the Company to provide; and
  • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to
    not provide to or share with the Company

4. How We Collect Information About You

We collect information about you (including personal data) when:

  • You Give Us Information – You may provide us information when:
  • you set up an account with us; you provide it to us by filling out forms;
  • you send us e-mail; you provide information via phone or in person;
  • you provide us with information in writing and send it to us other than via e-mail,
    phone or in person (i.e., mail, FedEx, etc.);
  • you provide us with documentation;
  • you provide us with information which may contain personal data;
  • you provide it to use through our “Contact Us” page on the website;
  • you provide us with information in connection with seeking employment with the
    Company.
  • We Collect Information Automatically – We automatically collect certain types of information when you visit our
    website (as explained below).
  • We Collect Information From Other Sources – We may also obtain information about you from outside sources. For
    example, we may obtain commercially available information about you from third-parties or purchase e-mail lists
    from third parties for advertising and marketing purposes. We may also receive information from
    third-parties who provide services for us through web-beacons and other technologies described in this Privacy
    Statement.

    5. Use of Cookies

About Cookies

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a
    web browser and is stored by the browser. The identifier is then sent back to the server each time the browser
    requests a page from the server.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web
    browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a
    session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  • Cookies do not typically contain any information that personally identifies a user, but personal data that we
    store about you may be linked to the information stored in and obtained from cookies.
  • Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that
    are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner
    consistent with the purposes for which they were designed unless you are specifically notified that we intend to
    use them for a specific service.

Cookies That We Use

We use cookies for the following purposes related to the services we provide for and to you and our users:

  • authentication – we use cookies to identify users of the website and/or the location of individuals accessing
    the website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalization – we use cookies to store information about your preferences and to personalize the website for
    you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including
    preventing fraudulent use of login credentials, and to protect our website and services generally;EU/EEA Data Subjects OnlyYou have the right to disable advertising cookies.
    However, the website does not use advertising cookies;
  • analysis – we use cookies to help us to analyze the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies Used By Our Service Providers And Vendors

Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our
website. These service providers and vendors may include, but may not necessarily be limited to:

Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en
and information therein)

  • You should review the privacy and cookie policies of the above website to learn more about the cookies that are
    used in connection with the above.
  • The above website and cookies may change from time to time as we use different vendors or service providers to
    provide some or all of the services offered or provided by the above services and websites, or additional
    services we decide to include. While we will periodically update our list of such vendors and service providers,
    the above list may not be complete at any given time.

Managing Cookies

  • Except as set forth herein, our use of web beacons, clear-gifs, pixel tags and JavaScript is critical to proper
    functionality our website, and disabling them may impact the functionality of the website and the services we
    provide.
  • We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript
    plug-ins, placed on the website and in our emails to you.
  • These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or
    in an email message which are used for such things as recording webpages or advertisements clicked-on by a user,
    or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online
    behavior and measure the effectiveness of our website and our marketing.
  • We may also work with third-party service providers that help us track, collect, and analyze this
    information. Third-party entities with whom we have agreements may place these devices on the website
    and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which
    you may click in emails. These third-party providers may also place cookies onto your computer. Those
    third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and
    your preferences from these third-party sources as well as our information we have about you. See above for more
    information on our cookies.
  • EU/EEA Data Subjects OnlyYou may be able to disable use of web beacons,
    clear-gifs, pixel tags and JavaScript
    if you provide us with notice as set forth in Section 13 hereof.
    However, doing so may impact your ability to use our website and/or our services and/or impact the cost of our
    services to you.

    7. Server Logs

  • A web “server log” is a record of activity created by a computer that delivers certain webpages to your
    browser. Certain activities that you perform on our website may record information in server logs. For
    example, if you enter a search term on the website or enter your login information, the server log may record
    the search term, the link you clicked on to bring you to our website and/or information about your browser, such
    as your IP address and the cookies set on your browser.

    8. How We Use Your Personal Data

  • We process your personal data identified in this Privacy Statement to perform the Services as defined above. The
    legal basis for this processing is your consent set forth herein, your consent based upon certain information
    you manifestly make public, as well as our contractual obligations.
  • We may process your personal data identified in this Privacy Statement where necessary for the establishment,
    exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an
    administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests,
    namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • We may process your personal data identified in this Privacy Statement where necessary for the purposes of
    managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate
    interests, namely the proper protection of our business against risks.
  • We may process your personal data identified in this Privacy Statement where such processing is necessary or
    advisable for compliance with a legal obligation to which we are subject (in the United States, the United
    Kingdom, the EEA, the EU, Switzerland or elsewhere), or in order to protect your vital interests or the vital
    interests of another natural person.

    9. Providing Your Personal Data To Others

  • We may disclose your personal data to our affiliate company located in India, Fortnite Bidco India Private
    Limited.
  • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably
    necessary for the purposes, and on the legal bases, set out in this Privacy Statement, including to provide or
    potentially provide Services to you or for your benefit.
  • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes
    of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims,
    whether in court proceedings, ADR or in an administrative or out-of-court procedure.
  • We may disclose certain of your personal data to the suppliers and subcontractors pursuant to separate consent
    provided by you to us.
  • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for
    assisting us in providing our Services to you, storing data and in connection with the administration of our
    business.
  • In addition to the specific disclosures of personal data set out in this Section 9, we may disclose your
    personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject,
    or in order to protect your vital interests or the vital interests of another natural person. We may also
    disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of
    legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or
    out-of-court procedure.

    10. International Transfers of Your Personal DataFor EU/EEA Data Subjects Only

  • In this Section 10, we provide information about the circumstances in which your personal data may be
    transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia,
    Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania,
    Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United
    Kingdom), Switzerland or the United Kingdom should the United Kingdom cease to be part of the EEA.
  • Pharmaspectra US, LLC is a New Jersey Limited Liability Company with its principal place of business located at
    210 Main Street, Madison, New Jersey (United States). The European Commission has made an “adequacy decision”
    with respect to the data protection laws of the United States. In the event the Company transfers any of
    your personal data to a third party in the United States or elsewhere outside of the EEA, Switzerland or the
    United Kingdom should the United Kingdom cease to be part of the EEA, such transfers will be protected by
    appropriate safeguards through the use of standard data protection clauses adopted or approved by the European
    Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en,
    or other similarly applicable law concerning the United Kingdom.
  • By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal
    data to and in the United States, India and any other countries as identified herein in accordance with this
    Privacy Statement. Such transfers and processing may include, but not be limited to, one or more transfers of
    your personal data to our affiliate company located in India, Fortnite Bidco India Private Limited.
  • By using our Services, you are agreeing to the transfer and processing of your personal data to and in the
    United States, India and any other countries as identified herein in accordance with this Privacy Statement.

    11. Retaining And Deleting Personal Data

  • This Section 11 sets out our data retention policies and procedure, which are designed to help ensure that we
    comply with our legal obligations in relation to the retention and deletion of personal data.
  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for
    that purpose or those purposes.
  • We will retain your personal data:
  • to the extent your personal data that we hold was obtained from data you knowingly,
    intentionally and manifestly made public or which is in the public domain independent of any act or action of
    us, it will be retained in that form for as long as it is needed or required for the purposes for which we
    obtained the information from the public record, or as otherwise required by applicable law;
  • to the extent your personal data that we hold was pulled by us and separated from
    data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any
    act or action of us, it will be retained by us for as long as required by us ifor the purpose for which it was
    obtained and as required by our contractual requirements with third-party clients or as otherwise required by
    applicable law.
  • In some cases it is not possible for us to specify in advance the periods for which your personal data will be
    retained. In such cases, we will determine the period of retention based upon the performance of our Services,
    and any applicable industry and governmental standards.
  • We may also retain your personal data where such retention is necessary for compliance with a legal obligation
    to which we are subject, or in order to protect your vital interests or the vital interests of another natural
    person.

    12. Amendments

  • We may update this Privacy Statement from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this Privacy Statement.
  • We may notify you of significant changes to this Privacy Statement by email or through the private messaging system on our website.

13. Your Rights – EU/EEA Data Subjects Only

  • In this Section 13, we have summarized the rights that EU/EEA data subjects have under applicable data
    protection law, including the GDPR. Some of the rights are complex, and not all of the details have been
    included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
    authorities for a full explanation of these rights.
  • Your principal rights under data protection law are:
  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent under certain circumstances.
  • You have the right to confirmation as to whether or not we process your personal data and, where we do, access
    to the personal data, together with certain additional information. That additional information includes details
    of the purposes of the processing, the categories of personal data concerned and the recipients of the personal
    data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your
    personal data. The first copy will be provided free of charge, but additional copies may be subject to a
    reasonable fee.
  • You have the right to have any inaccurate personal data about you rectified and, taking into account the
    purposes of the processing, to have any incomplete personal data about you completed.
  • In some circumstances you have the right to the erasure of your personal data without undue delay. Those
    circumstances include: the personal data are no longer necessary in relation to the purposes for which they were
    collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate
    basis for retention exists; you object to the processing under certain rules of applicable data protection law;
    the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
    However, there are exclusions of the right to erasure. The general exclusions include where processing is
    necessary: for exercising the right of freedom of expression and information; for compliance with a legal
    obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.
  • In some circumstances you may have the right to restrict the processing of your personal data. Those
    circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure;
    we no longer need the personal data for the purposes of our processing, but you require personal data for the
    establishment, exercise or defense of legal claims; and you have objected to processing, pending the
    verification of that objection. Where processing has been restricted on this basis, we may continue to store
    your personal data. However, we will only otherwise process it: with your consent; for the establishment,
    exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for
    reasons of important public interest.
  • You have the right to object to our processing of your personal data on grounds relating to your particular
    situation, but only to the extent that the legal basis for the processing is that the processing is necessary
    for: the performance of a task carried out in the public interest or in the exercise of any official authority
    vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an
    objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds
    for the processing which override your interests, rights and freedoms, or the processing is for the
    establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your personal data for direct marketing purposes (including
    profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal
    data for this purpose.
  • You have certain rights to object to our processing of your personal data for scientific or historical research
    purposes or statistical purposes on grounds relating to your particular situation, unless the processing is
    necessary for the performance of a task carried out for reasons of public interest.
  • If you consider that our processing of your personal data infringes data protection laws, you have a legal right
    to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU
    member state of your habitual residence, your place of work or the place of the alleged infringement.
  • To the extent that the legal basis for our processing of your personal data is consent, you have the right to
    withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the
    withdrawal.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your
    personal information with other entities as stated in this Privacy Notice, please provide us with your exact
    name and address and advise us that you wish to opt-out for information sharing or receiving information from us
    or both as the case may be. Please note that de-identified and aggregate data including your personal
    information may still be shared, but it will not be identified or identifiable to you. Please direct your
    opt-out request, or your request to exercise any of your rights in relation to your personal data by written
    notice to us at:

Pharmaspectra US, LLC
210 Main Street, 2nd Floor
Madison, New Jersey 07940 (United States)
Attention: Privacy Officer (privacy@pharmaspectra.com)

With a copy (including the words “Pharmaspectra – GDPR” in the subject line) to:

OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

14. YourChoices About Information We Collect – Not Applicable to EU/EEA Data Subjects

  • If you do not consent to the way in which we may use your personal information, please do not submit any
    personal information to us. Please note that if you do not provide us with certain personal information the
    Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise
    could be.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your
    personal information with other entities as stated in this Privacy Notice, please provide us with your exact
    name and address and advise us that you wish to opt-out for any information sharing or receiving information
    from us or both as the case may be. Please note that de-identified and aggregate data including your
    personal information may still be shared, but it will not be identified or identifiable to you. Please direct
    your opt-out request to the following contacts:

Pharmaspectra US, LLC
210 Main Street, 2nd Floor
Madison, New Jersey 07940 (United States)
Attention: Privacy Officer (privacy@pharmaspectra.com)

With a copy (including the words “Pharmaspectra – Privacy” in the subject line) to:

OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

15. Privacy of Children WhoVisit the Website

We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is
not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally
identifiable information from children under the age of 18. If you are under age 18, you do not have
permission to use this website or our Services.

16. Your California PrivacyRights

  • We collect various types of personal information about you during the course of your relationship with us. Under
    California law, if you are a resident of California, you may make a written request to us about how we have
    shared your information with third parties for their direct marketing purposes. In response to your written
    request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing
    your information with third parties with whom we do not share the same brand name, if the third party will use
    such information for its direct marketing purposes.
  • If you would like to exercise your rights under California law, please send your written request to the e-mail
    address or postal address below. Please include your postal address in your request and the words
    CALIFORNIA OPT-OUT” in the subject line of your request. Within thirty (30) days of receiving
    your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request
    that your personal information not be disclosed to third parties for their direct marketing purposes.

E-mail Address:
privacy@pharmaspectra.com

Postal Address:
Pharmaspectra US, LLC
210 Main Street, 2nd Floor
Madison, New Jersey 07940 (United States)
Attention: Privacy Officer

© Pharmaspectra Group Limited, 2020
All Rights Reserved
2 Eastbourne Terrace
London, W2 6LG