In consideration of the foregoing and in compliance with the EU Regulation 2016/679 (“GDPR”) and the Swiss Federal Act on Data Protection, APR hereby provides the following privacy policy (the “Privacy Policy”) to inform the guests of the Site and any person that has granted APR the permission to receive newsletters or periodical updates on APR's activities, about:

• which types of data that APR collects through the Site
• how APR may use such data
• who are the third parties which such data may be shared with
• the rights recognized to any person that has granted APR the permission to use its data

2) DATA PROTECTION OFFICER

APR has appointed a Data Protection Officer who can be contacted at the following email address: dpo@relieftherapeutics.com.

3) REPRESENTATIVES IN EU and UK

APR has appointed, as its representative in the European Union, APR Applied Pharma Research - Italy S.r.l., a company existing under the laws of Italy and having its registered office at Corso Vittorio Emanuele II, 154 - 00186 Rome, Italy, VAT 03736410139, which can be contacted by phone at 0039 06 6869927 or at the following email address: privacy@apr-italy.it

APR has appointed, as its representative in the United Kingdom, Rickert Services Ltd UK, PO Box 1487, Peterborough, PE1 9XX, United Kingdom who can be contacted by email at art-27-rep-apr@rickert-services.uk

4) CATEGORIES OF PERSONAL DATA

The data collected through the Site can be:

• Navigation Data:  these kinds of data are collected automatically by the Site and the permission to their collection is implicit in the Internet usage protocols. In particular, these kinds of data do not allow an identification of the guest of the site but, through particular elaborations and in association with other data, they can lead to an identification of the guest. By means of example, these kind of data include, but are not limited to, the IP addresses, the URI (Uniform Resource Identifier), the indication of the time spent on the Site, the information related to the operative system of the guest, other information related to web navigation.
  
  APR uses this data in an aggregate and anonymous form in order to track information such as the total number of visits to the Site, the number of visitors to each page of the Site and the domain names of the visitors of the APR's Internet service providers. APR uses this information to improve the services offered through the Site.
  
  These data, in combination with other information, may lead to an identification of the guest of the Site. APR does not use these data for such purposes and does not try to identify in any way the guests to this Site.
  
  
• Data disclosed, on voluntary base, by the guest:  these data are disclosed only on voluntary base by the guest of the Site and may include name, surname, living address, e-mail address, telephone, nationality. These data are collected through the filing of a format and are used by the APR to answer to specific requests of the guest or, always upon voluntary base, to insert the guest in a mailing list for periodical newsletters or updates in relation to APR activities and products.

5) PURPOSES OF THE PROCESSING

APR uses the Data disclosed on voluntary base for the following purposes:

• To respond to specific request:  in the event of questions addressed to APR through this Site, data (such name and e-mail address) are necessary to processing the request and provide the guest with an answer. Guests are not obligated to provide such data but in the event they do not, APR shall not be able to provide an answer to the specific request;
  
  
• To activate a newsletter system:  APR, through a newsletter system, shall provide guests with helpful information in relation to new products, news, updates and services. APR shall activate this service only upon the grant of the guest permission and provided the right of any guest to require in any moment the cancellation of his data and/or the service.

Please by informed that the Site services do not require any form of registration, allowing the guests to visit the Site without providing any personal data (and in general, any Data disclosed on voluntary base).

6) COOKIES

The Site uses cookies. Please see the Section “Cookie Policy” for information about the cookies policy.

7) DATA PROTECTION

Any data collected by APR is treated in accordance this Privacy Policy and with any applicable legal or ethical reporting or documentation retention requirements and in full adherence with the GDPR and the Swiss Federal Act on Data Protection

APR is committed to protecting the security of the collected data and shall take commercially reasonable steps to protect such data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and all other unlawful forms of processing.

The data collected are protected by firewalls that meets or exceed industry standards.

8) SHARING INFORMATION WITH THIRD PARTIES

The Navigation Data may be shared, in aggregate and anonymous form, with third parties to improve the Site services by studying the guests' experiences on the Site.

APR does not elaborate the Navigation Data in order to obtain indirect information in relation to the guests of the Site.

The Data disclosed on voluntary base by the guests are not shared with third parties.

9) DATA RETENTION AND DELETION

Data collected through the Site are stored in servers that are operated and maintained by a different company from APR. Such company has not access to any data collected by APR and provides to APR a simple server service.

APR only retains the data collected as long as and to the extent needed to fulfill the purposes for which they were originally collected, unless otherwise provided by law or differently requested by the guest.

10) LINKS TO THIRD PARTIES' WEB SITES

The Site may provide links to third party web sites as a service to its guests. This Privacy Policy does not apply to those sites. APR has not the possibility to control or manage the contents of such sites, nor the possible use of the data eventually collected by those sites.

For these reason APR takes no responsibility in relation to any data processing performed by those sites. Please review the privacy policies and terms of use posted on each site you visit.

11) GUESTS' RIGHTS

In accordance with the terms and conditions set forth in applicable laws and regulations governing the processing of persona data, the guest of the Site is entitled to: (i) the right to be informed about the collection and the use of their personal data; (ii) the right to access personal data and supplementary information; (iii) the right to have inaccurate personal data rectified, or completed if it is incomplete; (iv) the right to erasure; (v) the right to restrict processing; (vi) the right to data portability; (vii) the right to object to processing; (viii) rights in relation to automated decision making and profiling; (ix) the right to withdraw consent at any time provided that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal; (x) the right to complain to the data protection authority. Except for the complaint to the data protection authority, the rights can be exerted by contacting APR at the address set forth Section 1.

12) OTHER PRIVACY DOCUMENTS

We invite You to carefully consider the following documents:

• Privacy Notice for Business Partners
• Privacy Contact Form

13) PRIVACY POLICY UPDATES

APR may occasionally update all or parts of this Privacy Policy at any time and without any individual notice to the Site's guests.

APR encourage to periodically review this Privacy Policy to stay informed about its information practices.