Date updated: October 22, 2026

Clinical Trial Privacy Notice

Introduction

Cellular Intelligence (referred to as “We”, “Our”, "Us”, "CI", or "the Company") is committed to protecting the privacy and security of Your Personal Data. This Clinical Trial Privacy Notice (“Trial Notice”) explains how We use Personal Data in connection with Our clinical trials. It applies if You are:

A participant in a CI clinical trial, or in a clinical trial funded by CI;
The partner or child of a CI clinical trial participant; or
A healthcare professional (“HCP”) involved in conducting a CI clinical trial.

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1.1 How this Trial Notice fits with Our Privacy Notice

This Trial Notice supplements, and should be read alongside, CI’s Privacy Notice. The Privacy Notice sets out information that applies across CI, including definitions, Your rights, security, international transfers and how to contact Our Data Protection Officer (DPO) or make a complaint. This Trial Notice sets out the information specific to clinical trials: the Personal Data We collect, why We use it, who We share it with and how long We keep it. Terms defined in the Privacy Notice have the same meaning here. If the two documents conflict in relation to Personal Data processed for a clinical trial, this Trial Notice prevails.

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1.2 Taking Part in a Trial and Data Protection Legislation

This Trial Notice does not replace the information given to You when You take part in a trial, such as the participant information sheet and informed consent form. Agreeing to take part in a trial (informed consent to participate) is separate from the legal basis, We rely on to use Your Personal Data under data protection law. In some countries, consent is also the legal basis for using Your Personal Data. In others, We rely on a different basis, such as legitimate interests or legal obligation. It is important that You read this Trial Notice so that You are aware of how and why We are using such information.

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Your Personal Data

We collect Personal Data in accordance with Data Protection Legislation and the clinical trial laws that apply to each trial, such as the EU Clinical Trials Regulation (EU CTR). The Personal Data We use, and how We obtain it, depends on Your relationship with Us. Where We are the funder of a clinical trial sponsored by another organisation, We do not collect Your Personal Data from You directly, because the Sponsor is responsible for the trial and for the identifiable Personal Data of participants. We receive it in coded form from the Sponsor of the trial, or from the Sponsor's Research Sites, contract research organisations or laboratories. The Personal Data We receive is generated during the conduct of the trial, including from Your medical records, clinical assessments, imaging and laboratory analyses.

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Data Subject Type	Data Fields
Participants in CI-funded trials (sponsored by another organisation)*	Coded identification number(s); Coded demographic information (date of birth, age, sex); Coded health data, including safety information, adverse events, medical images and scans, and trial analysis results
Participants in CI-sponsored trials, and their partners and children*	Name; Demographic information (date of birth, age, gender, ethnicity); Contact details (telephone number, email address), and a parent’s contact details for a child; where applicable, Name and contact details of a legally authorised representative, partner, child or parent**; where applicable, Financial information (e.g. bank details) for payments; Coded identification number(s); Health data (medical records, test results, images and scans, family history, biological samples and their analysis); Genetic data
Healthcare Professionals (HCPs)*	Name; Employment details; Contact details (telephone number, email address, mailing address); where relevant, Financial information (e.g. bank details) for payments

* You are under no statutory or contractual requirement or obligation to provide Us with Your Personal Data; however, We may require some of the information above in order for Us to deal with You for the purposes requested by You.

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** Identifiable Personal Data relating to participants, and where applicable, their partners and children, is collected by CI’s Research Sites. This data may be shared with clinicians, health authorities, ethics bodies, and other personnel as authorised by CI, but only where CI is legally obligated to provide this data in accordance with Clinical Trial Regulations and other applicable laws. CI will not directly receive identifiable Personal Data relating to clinical trial participants, or where applicable, their partners and children, and will not instruct Our Data Processors or Research Sites to process or share this information other than where the law requires. If We become aware that We have received identifiable Personal Data relating to participants, or where applicable, their partners and children, We will make commercially reasonable efforts to delete such information from Our records.

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How We Use Your Personal Data

We use Your Personal Data for the purposes below. Where EU or UK GDPR applies, the table shows the lawful basis for each. Please see CI’s Privacy Notice for general information on how We use Personal Data.

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Data Category	Processing Activity	Lawful Basis (Applicable where EU or UK GDPR applies)
Participants in CI-funded trials	To receive and use coded data to evaluate the safety of the investigational product, support its further development (including future trials and applications to health authorities) and conduct related scientific research	Legitimate interests (developing the investigational product and conducting scientific research)
Participants in CI-funded trials	To receive and use coded safety and efficacy data to meet Our safety and efficacy reporting and pharmacovigilance obligations, including reporting to health authorities and maintaining a global safety database	Legal obligation (where it arises under UK or EU law); otherwise Our Legitimate interests
Participants in CI-Sponsored Clinical Trials, and Participants Partners and Children	To collect information from You and process Your health information in order to conduct a clinical trial	Depends on the country where the trial takes place: Consent (or that of Your parent or legal guardian, if You are a child); Legitimate interests in conducting clinical research; or Legal obligation
Participants in CI-Sponsored Clinical Trials, and Participants Partners and Children	To process Your information where We are legally required to do so, including under laws on clinical trials, safety reporting, healthcare and scientific research	Legal obligation
Participants in CI-Sponsored Clinical Trials	Optional future research, including storing samples and developing and training Our AI models (see 3.2)	Consent
HCPs	To collect Your contact and employment information in order to plan, deliver or oversee a clinical trial, and to communicate with You about the trial.	Legitimate interests (conducting clinical research)
HCPs	To take or make payments, or to give or request refunds	Contract (where You contract with CI directly); otherwise legitimate interests
HCPs	To retain accounting information for statutory retention periods	Legal obligation
HCPs	To correspond with You, including using AI-powered tools to assist with drafting, summarising or analysing correspondence	Legitimate interests
Participants in CI-funded trials, Participants in CI-Sponsored Clinical Trials,Participant partners and children, and HCPs	To respond to and defend against legal claims and for pharmacovigilance obligations, including reporting to health authorities and maintaining a global safety database	Legitimate interests (establishing, exercising or defending legal claims), Legal obligation
Participants in CI-funded trials Clinical Trial participants, partners and children HCPs	To protect Your vital interests or those of a third party	Vital interests

3.1 Special Category Data

Health data, genetic data, biological samples and ethnicity are special category personal data. We use them only where an additional condition under Article 9 of UK or EU GDPR applies, in each case with appropriate safeguards. In the UK, We also rely on the corresponding conditions in Schedule 1 of the Data Protection Act 2018 where relevant.

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3.2 Clinical Trial Future Research

If You take part in one of Our trials, You may be asked whether You agree to Your Personal Data or samples being used beyond running the trial. This may include storing samples for future research, and using information from Your samples or the trial to develop and train Our AI models. These models help Us understand how cells behave, and We may use them across Our wider research, including work on treatments unrelated to the study You took part in. These uses are optional and are asked about separately. You can agree to some, all or none, and Your decision will not affect Your treatment or Your place in the study. Where You agree, Your information is labelled with a code rather than Your name, and We do not try to identify You. You can withdraw Your agreement at any time and stay in the study. Results from research already completed stay in those results, and information already used to build a model cannot be taken back out. The consent form for Your study sets out the details, including how long We keep Your data and Your rights. If You have questions, please contact the hospital or clinic where You took part.

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Who We Might Share Your Information With

In addition to the sharing described in the Privacy Notice, We may share Your Personal Data with:

Our contract research organisation (CRO) and clinical trial data processors, who act on Our instructions under Data Processor Agreements;
Our strategic clinical trial partners; and
Health authorities, ethics bodies and other recipients where the law requires.

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How Long We Keep Your Information For

The Privacy Notice explains Our general approach to retention. Where EU or UK GDPR applies, and unless the law requires otherwise, We keep Your Personal Data for the periods below and then securely delete it in accordance with Our internal policies.

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Participants in CI-funded trials (sponsored by another organisation)	The period set out in Our agreement with the Sponsor and, in any event, as long as needed to meet Our safety reporting, pharmacovigilance obligations,and regulatory storage requirements which may continue after the trial ends.
Participants, partners and children, and HCPs involved in a trial, in the EU/EEA and UK	25 years after the end of the trial (EU Clinical Trials Regulation and the UK Medicines for Human Use (Clinical Trials) Regulations 2004).
Participants, partners and children, and HCPs involved in a trial, outside the EU/EEA or UK	At least 5 years after the end of the trial, or longer where local law requires.
HCPs, for research, academic, publication, marketing or commercial (non-clinical trial related) opportunities (EU/EEA/UK)	6 years

How We Keep You Updated

Where You are a clinical trial participant or an HCP involved in a CI clinical trial, We may contact You, or We may contact You through Our CRO where it is necessary to do so.

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Your Rights Over Your Information

Your rights are set out in Our Privacy Notice. Where We fund or sponsor a clinical trial, We hold only coded data and cannot identify You from it. To exercise Your rights in relation to that data, please contact the trial team at Your Research Site in the first instance. They can identify Your records and will liaise with Us where necessary. You may also contact Us directly, in which case We may need to work with the Sponsor to respond.

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Security, International Transfers and Business Changes

Our security practices, Our approach to international transfers and what happens if Our business changes hands are set out in Our Privacy Notice.

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Where We receive Personal Data from a Sponsor or Research Site in the European Economic Area (the EEA), the transfer is made under the standard contractual clauses approved by the European Commission. Where the data originates in the UK, those clauses are supplemented by the UK International Data Transfer Addendum issued by the Information Commission’s Office (ICO) or the International Data Transfer Agreement (IDTA). We are bound by those clauses in respect of the Personal Data We receive and will provide a copy on request.

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Contact Us and Changes to This Notice

Our contact details are provided in Our Privacy Notice. We may update this Trial Notice from time to time, for example if the law changes, so please check it regularly.