CONSUMER HEALTH DATA

SUPPLEMENTAL PRIVACY NOTICE

Last Updated: May 30, 2025

We at Othram, Inc., a Delaware corporation, and our affiliates and subsidiaries (“our,” “us”, or “we”) respect your privacy. This Consumer Health Data Privacy Notice (this “Consumer Supplemental Notice”) supplements, but does not replace, our Global Privacy Notice and applies to Consumer Health Data (as defined below) subject to (1) the Washington State My Health My Data Act, (2) Nevada’s Consumer Health Data Privacy Law (SB 370), and (3) similar state laws (the “Consumer Health Data Laws”). We are providing this Consumer Supplemental Notice solely for the purpose of complying with the Consumer Health Data Laws, where applicable. We do not collect Consumer Health Data for the purpose of diagnosing or treating any medical condition or for the purpose of providing health care.

Our Collection and Use of Consumer Health Data

The term “Consumer Health Data” as used in this Consumer Supplemental Notice means any personal information linked or reasonably linkable to you that identifies your past, present, or future physical or mental health status as defined in the Consumer Health Data Laws. The data we collect depends on the context of your interactions with us and, in most cases, is information you decide to share with us. Consumer Health Data does not include information considered deidentified under the Consumer Health Data Laws. Examples of Consumer Health Data we may collect include:

• “Genetic Data,” which means any data, regardless of its format, that concerns your genetic characteristics. Genetic Data includes:

  • Raw sequence data resulting from the sequencing of your complete extracted deoxyribonucleic acid (“DNA”) or a portion of the extracted DNA;

  • Genotypic and phenotypic information resulting from analyzing the raw sequence data; and

  • Self-reported health data you submit to us that is analyzed in connection with your raw sequence data.

• Information you share about your health-related conditions, symptoms, experiences, diagnoses, testing, medications, or treatments;

• Information that could identify your attempt to seek health care or genetic or DNA testing;

• Other information that may be used to infer or derive data related to the above or other health information; and

• Information described above that is derived or extrapolated from information which is not Consumer Health Data, including proxy, derivative, inferred, or emergent data derived through an algorithm, machine learning, or any other means.

We may process or use this information collected online and offline (including with your consent where required by Consumer Health Data Laws) for the following purposes:

• In the provision of services, including providing you our websites, and related services;

• To communicate with you, including to respond to your questions and comments or to notify you of changes to our services or to follow up with you;

• To identify and authenticate you;

• To help ensure security and integrity of our systems to the extent the use of Consumer Health Data is reasonably necessary and proportionate for these purposes;

• Administrative purposes, including providing customer service (such as online service), verifying customer information, providing analytic services, providing storage, or providing similar services;

• Undertaking internal research for technological development and demonstration;

• Undertaking activities to verify or maintain the quality or safety of a service owned or controlled by us and to improve, upgrade, or enhance a service owned or controlled by us;

• To protect against malicious, fraudulent, or illegal activity;

• Complying with legal and regulatory obligations;

• For commercial purposes, such as to provide investor and investment information;

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

• For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. You can unsubscribe from any marketing emails or text messages we may send you by following the instructions included in the email or text correspondence or emailing us using the contact details provided at the end of this Consumer Supplemental Notice;

• For short-term, transient use, including non-personalized advertising shown as part of your current interaction with us; and

• Other purposes we may notify you about or for which you provide your consent or authorization.

Sources From Which Your Consumer Health Data Is Collected

The Consumer Health Data we collect may come from various sources, including:

• You and those authorized to provide Consumer Health Data on your behalf, such as your caregiver or authorized representative;

• Your personal devices;

• Third parties that provide access to information you make available, such as social media services;

• Companies conducting non-clinical research, such as market research companies; and

• Business partners or other service providers that assist us in providing and improving our services.

Our Disclosure of Consumer Health Data

We may share the categories of Consumer Health Data set forth above as follows:

• Othram and Our Affiliates – We may share your Consumer Health Data internally or with our affiliates as needed for the purposes listed above.

• Providers – We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the provision of the service or that perform business or operational services for us or on our behalf, such as order fulfillment, website hosting, infrastructure provisioning, IT services, payment processing services, legal, and administrative services. We may also engage service providers to follow up with you on our behalf if you initiate and do not complete the process of placing an order for prescription medication through our website.

• Parties with Whom You Have a Direct Relationship – We may share with parties with whom you have a direct relationship for the purpose of providing services you request in circumstances where we maintain control and ownership of the data and the recipient uses the Consumer Health Data only at our direction for the purpose for or to which the Consumer Health Data was collected or consented.

• Business Transactions – We may take part in, or be involved with, a business transaction, such as a merger. We may share Consumer Health Data with a third party during the negotiation of, or in connection with, such a transaction to the extent permitted by applicable law.

• Legal Obligations and Rights – We may share Consumer Health Data with third parties (1) in connection with the establishment, exercise, or defense of legal claims, (2) to comply with laws or to respond to lawful requests and legal processes, (3) to protect our rights and property and the rights and property of others, including to enforce our agreements and policies, (4) to detect, suppress, or prevent fraud, (5) to protect the health and safety of us and others, or (6) as otherwise required by applicable law.

• With Your Consent – We may share Consumer Health Data about you to certain other service providers, other users of our Services, or publicly with your consent or at your direction.

In the event we process deidentified data, we will maintain and use deidentified data without attempting to reidentify you except as permitted by law and will contractually obligate any recipients of such data to satisfy these criteria.

Exercising Your Privacy Rights

Some Consumer Health Data Laws provide certain rights with respect to Consumer Health Data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions.

To exercise any of your privacy rights, or if you have any questions about your privacy rights, please do not hesitate to contact us at:

   E-mail: solve@othram.com

If we decline or are unable to act regarding your request, we will notify you with our reasons and will provide instructions for how you can appeal the decision. If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable attorney general or other regulatory authority in your state.

With respect to sharing identifiers, Internet, network, or other electronic activity that may constitute Consumer Health Data relating to your interaction our websites, you may withdraw consent from collection and future sharing by navigating to our cookie preference page.

Changes to this Consumer Health Data Privacy Notice

From time to time, we may change this Consumer Supplemental Notice. We will post any changes on this page. If we change the Consumer Supplemental Notice significantly, we will notify you (1) by adding a prominent notice on our websites and services, (2) by sending you an email notification, or (3) via other appropriate communication channels, as required by applicable law. To the maximum extent permitted by applicable law, any changes will become effective when we post the updated Consumer Supplemental Notice, and your use of our services following these changes means that you accept the updated Consumer Supplemental Notice. We encourage you to review this Consumer Supplemental Notice when you use our services to stay aware of our information practices.

Interpretation

In the interpretation of this Consumer Supplemental Notice, except where the context otherwise requires, (1) “including,” “include,” or “such as” does not denote or imply any limitation, (2) “or” has the inclusive meaning “and/or,” (3) “and/or” means “or” and is used for emphasis only, (4) “U.S.” or “United States” means the United States of America, (5) the singular includes the plural, and vice versa, and each gender includes each other gender, (6) captions or headings are only for reference and are not to be considered in interpreting this Consumer Supplemental Notice, (7) references to any federal, state, local, or foreign statute or law shall be deemed also to refer to all rules and regulations promulgated thereunder, and (8) “Section” refers to a section of this Consumer Supplemental Notice, unless otherwise stated in this Consumer Supplemental Notice.