Privacy Policy — SMS Program & Website

1.Who we are and what this policy covers

This Privacy Policy covers only the Program and use of this site. It applies to:

• the CAD Therapeutics Internal Operations Alerts SMS program (the “Program”); and
• your use of this website.

It does not cover information about clinical study participants. Clinical study participant information is governed separately by the applicable study’s informed consent documents and by applicable law.

2.About the SMS Program

The Program sends one nightly summary text message, at approximately 10:00 PM Eastern Time, about the work of the CAD Ad Studio bot team. Messages are sent from (917) 590-4077 to authorized CAD Therapeutics personnel only. The Program does not send marketing messages and is not used for patient recruiting.

Message frequency: about 1 message per day. Msg & data rates may apply. Reply STOP to cancel. Reply HELP for help. Full Program terms are in our Terms and Conditions — SMS Program.

3.Information we collect

• Name of the enrolled staff member.
• Mobile phone number provided to the Program administrator.
• Consent record, including the date and time consent was given (and, if applicable, withdrawn or renewed).
• Message content and delivery logs, such as messages sent, timestamps, and delivery status.
• STOP and HELP replies and any other replies you send to the Program number.
• Basic website logs, if any, such as IP address, browser type, pages requested, and time of request, which a web host may record automatically. This site does not use advertising trackers.

4.How we collect it

You provide your name and mobile number directly to the Program administrator when you opt in. Message, delivery, and reply records are generated when the Program operates. Basic site logs, if any, are generated automatically when you visit this site.

5.How we use information

We use this information only to operate the Program, including to: enroll you and record your consent; send the nightly summary messages; respond to HELP requests; honor STOP and other opt-out requests; troubleshoot delivery; and keep records needed to show compliance with messaging rules and applicable law. We use basic site logs, if any, only to operate and secure this site.

6.Service providers

We use Twilio Inc. to send and receive Program text messages. Twilio processes mobile numbers, message content, and delivery data on our behalf, as needed to provide the messaging service, under Twilio’s terms and privacy policy. Wireless carriers handle messages as part of delivering them. We may also use a web hosting provider to operate this site. These providers are used only to operate the Program and this site, not for their own marketing.

7.No sharing for marketing

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

Apart from the service providers described above, we disclose information only when required by law or legal process, or to protect our rights or the safety of others.

8.No sale of personal information

We do not sell, rent, or trade personal information, including mobile phone numbers and opt-in data.

9.Retention

We keep consent records for as long as you are enrolled in the Program and for up to 4 years after you opt out or leave the Program, so we can demonstrate compliance with messaging rules and applicable law. Other Program information, such as message content and delivery logs, is deleted when it is no longer needed to operate the Program, subject to any legal requirements.

10.Security

We use reasonable administrative, technical, and organizational measures to protect Program information, including limiting access to people who need it to run the Program. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Standard SMS messages are not encrypted end to end, so Program messages are not used to send sensitive personal or health information.

11.Your choices and rights

• Opt out: reply STOP to any Program message, or email admin@cadtherapeutics.com. You will receive one confirmation message and then no further Program messages.
• Access: ask what Program information we hold about you.
• Correction: ask us to correct inaccurate information, such as an outdated mobile number.
• Deletion: ask us to delete your information. We may keep a consent and opt-out record where needed to show compliance or to make sure we do not message you again.

To make a request, email admin@cadtherapeutics.com. We may need to confirm your identity before acting on a request.

12.Children

The Program and this site are not directed to anyone under 18. We do not knowingly collect information from anyone under 18 through the Program or this site.

13.Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will post the updated policy on this page and change the effective date. Material changes will be communicated to enrolled personnel.

14.Contact us

CAD Therapeutics, Inc.
6 St. Johns Ln, New York, NY 10013
Email: admin@cadtherapeutics.com
Program phone number: (917) 590-4077