RegDesk Privacy Notice

Effective Date: November 9, 2024

RegDesk, Inc. (“RegDesk”) provides regulatory compliance software for medical device providers that facilitates the regulatory approval process for medical device products and technologies (our “Digital Platform”). This Privacy Notice describes how we collect, maintain, share, and otherwise processpersonal information via our Digital Platform and our corporate website, https://www.regdesk.co (our “Website”). This Privacy Notice is addressed to our customers and their employees, representatives, distributors, registered agents, and consultants (“Customers”) and visitors to our Website (“Visitors”) located within the United States.

For individuals who interact with us online, we collect information you choose to give us and other information that may be collected from your use of our Website and Digital Platform, including from your device. We use that information to operate our business and for the purposes set forth below. Below, we also describe the choices we offer with respect to your information.

This Privacy Notice does not apply to information which is not processed by RegDesk. This Privacy Notice does not apply to information that cannot be identified by any individual, household, or their devices, such as de-identified or anonymized information. If you are a Customer or Visitor residing in the European Union, United Kingdom, or European Economic Area, please refer to our EU/UK/EEA Privacy Notice.

Information We Collect:

We collect information about individuals from a variety of sources, including:
– Directly from Customers or Visitors when provided to us, for instance when contacting us via the Website or Digital Platform, placing an order, or responding to our inquiries or a survey.
– Automatically as you utilize the Website or Digital Platform.
– From third parties. We may collect information from advertisers, marketing service providers, affiliates, promotional partners, and application providers. These and other third parties may provide us information in connection with content, widgets, components, or other tools deployed on our Website and Digital Platform. We may use this information to provide you with interest-based advertising or other targeted content and for other purposes, such as to better understand our Website’s and Digital Platform’s audience.

We may collect and process personal data as detailed in the chart below:

Category of Individual	Personal Information Collected	Key Information Uses
Visitors	Data you communicate to us while using the Website. Information you provide in response to a form or survey. Usage Data, as defined below.	Provide Website functionality, including facilitating your interactions with others on the Website. Address your inquiries submitted through website forms. Develop analytics to understand our Website audiences, develop business strategies and marketing plans. Provide information about new or related products or services we may offer. For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).
Customers	First and last name. Email addresses. Phone numbers. Mailing address. Job title and professional certifications or affiliations. Purchase history and account information related to our services. Payment data as necessary to sign up for our Digital Platform or any other service. Usage Data, as defined below.	Communicate with you regarding the regulatory process via our Digital Platform. Permit you to login to/access the Services. Manage the business relationship with you and services provided to you. Provide service functionality, including facilitating your interactions with others on the Digital Platform. Provide information about new or related services we may offer. For other general purposes noted below (e.g., to maintain records, enforce legal terms or comply with law) (see Other Ways We Use Information We Collect).

Information Collection on our General Website

If you are a Visitor, we may collect your name, email address, and other information you choose to submit when you browse our Website, complete forms, fill in surveys, request information from us, sign up for our mailing list or newsletters, or otherwise visit or interact on our Website.

Other Information Collection, Logging, and Automatically Collected Information

If you are a Visitor to our Website or a Customer accessing our Digital Platform, your browser or device will be subject to collection of logging and other automatically collected information. This may include information collection via cookies, web beacons, and other automatically collected information. The information we automatically collect may include your IP address, date and time you access our websites or online services and the pages and content you access during your visit, language preferences, websites that you link to or from, whether you receive or open an email or other communication from us and the links you click on within those emails, information from your mobile device or your computer about how you interact with our website or online services, including unique device identifier, mobile network information, the type of device used and the operating system on that device, browser type, a list of files downloaded or pages viewed, and any errors encountered (collectively, “Usage Data”).

If you are a Visitor on our Website or a Customer accessing our Digital Platform, please note that third parties may collect personal information about your online activities over time and across third-party websites and online services. These third parties may provide us information in connection with content, widgets, components, or other tools offered on our Website and Digital Platform. These third parties may collect information from these sources when you use our Website. They may use this information to provide you with interest-based advertising or other targeted content, and for other purposes. We may not control personal information once collected by these parties. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party websites or online services.

In all cases, we may collect and use other information you choose to provide or with your consent.

Other Ways We Use Information We Collect

In addition to the uses described above, we may use all of the information we collect in order to:

Maintain, analyze, customize, and improve your experience on our Website and Digital Platform.
Support business development, research, marketing and promotional purposes, press inquiries or aggregate statistical analysis and site customization.
Communicate with Visitors and Customers about our Website and Digital Platform, including technical notices, security alerts, and support and administrative messages. We may also provide customer and technical support, including notices about accounts and subscriptions and changes to our service.
Send promotional and marketing materials, support contests and other promotions, notify you about incentives and rewards.
Provide you information that you request from us or otherwise respond to your communications and questions.
Monitor and enforce our contracts, legal terms, acceptable use or other policies or similar terms.
Comply with the law and satisfy our regulatory and compliance obligations. Additionally, to support compliance efforts on behalf of others and ourselves that support our provision of services to you.
Provide a personalized experience. Automatically collected and device information may also be used to help us estimate our audience size, usage patterns, and analyze trends and administer our services, and used for research and marketing purposes.
Help detect and prevent fraudulent use of our Website and Digital Platform and other prohibited, illicit, or illegal activity. We may use information to compare information for accuracy and to verify identity.
Monitor information security, manage and protect our technical infrastructure (servers, networks, etc.), and to protect the rights and vital interests of you, others, and ourselves.
Address existing or anticipated disputes and to protect our legal interests.
Otherwise operate our business, including support for transactions impacting our company as a whole (such as mergers, acquisitions, reorganizations, underwriting or asset purchases).
Fulfill any other purpose for which you provide your information to us and for other purposes disclosed to you in connection with our services.
Other purposes permitted by law or to which you consent.

We may also retain and use your information in an anonymized or de-identified format where your identity is not recognizable. Such information is not subject to the same usage restrictions as personal information and can be used to improve our products and services, conduct research, or for our other business purposes.

As permitted by law, we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our services, content, and advertising.

How We Secure Information

We are committed to maintaining measures to protect the security of your personal information maintained in our systems. However, no network or system is ever entirely secure, and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf. If we face a security breach, we may notify you as required by law via email or conspicuous posting on this site.

The safety and security of your personal information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone.

How We Share Information

We may share your information with third parties as reasonable to operate our business (including for the purposes described above), to provide the Website and Digital Services to you and others, as permitted or required by law, or as directed or authorized by you. For example:

Affiliated Organizations. We may share some or all of your information with our parent organizations, subsidiaries, affiliates, joint ventures, or other organizations or entities under common control with us.

Third Party Sharing. We work with third parties to help us provide our Website and Digital Platform and to support internal operations. In some cases, they may use your information subject to their own
privacy policies and to comply with their own legal and regulatory obligations. We work with different types of third parties, presently including:

Data hosting, storage, and cloud service providers.
Platform and/or application security service providers.
Technical and customer support providers;
Marketing and analytics providers; and
Other third parties.

Professional Advisors, Law Enforcement and Regulators. We share information with our professional advisors who provide legal, compliance, auditing, accounting, banking, consulting, or other professional services, and with regulators, law enforcement, or government agencies to:

Comply with our legal and regulatory obligations, including those compliance obligations offederal, state or local regulators;
Protect our interests, property or legal rights, or those of our customers or third parties;
Respond to a subpoena, court order, or similar law enforcement request, or when we believe i good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms;
For other legal purposes, such as to enforce our terms and conditions, or to exercise or defend legal claims.

Transaction Impacting the Organization as a Whole. In the event of a transaction or reorganizationimpacting us as an entity or organization, we may share your personal information. We may share yourinformation in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, restructuring, divestiture, or dissolution of all or a portion of our business, or other similar event.

Other Disclosures. In addition to the above disclosures, we may disclose personal information in the event that we believe such disclosure is:

necessary to provide our services or operate our business;
in accordance with purposes we describe when you share it with us;
permitted by law;
with your consent or at your direction.

We may disclose aggregated or deidentified information that does not identify any individual without restriction.

International Data Transfers

RegDesk may share personal information with our internal employees, contractors, partners, or affiliates located outside the United States for the purposes outlined above, including as necessary to provide and support our Website and Digital Platform or as described in the “Other Ways We Use Information We Collect” section.

What Choices Do I Have?

Update personal information. If you are a Customer with which we have an ongoing business relationship, you may request changes to your information by emailing us at privacy@regdesk.co or by Phone +1 267 607 3375. As permitted by law, we may deny a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or prevent the provision of our services.

Marketing communications. You may receive marketing communications from RegDesk, including if you sign up for marketing or other communications. You may opt out of receiving marketing emails by following the unsubscribe link in each email, or by contacting us at privacy@regdesk.co. Please note that you may continue to receive non-marketing emails from us after you opt out. Please note that we do not control communications from others. If you have received marketing communications from third parties, you should contact those third parties directly to understand the communication choices they may provide you. Third parties include those who may be interacting with us on your behalf in connection with group activities.

Cookies. You have choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s settings to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly or at all as a result.

RegDesk is not responsible for any practices employed by websites linked to or from our website, not their information or content. Please remember that when you use a link to go from our website to another website, this Privacy Notice is no longer in effect.

Children’s Privacy

Our Services are not intended to interact in any way with minors. Any access to or use of the Website or Digital Platform by anyone under the age of 13 is unauthorized. If you are under 13, and you provide any information on or through our Website or Digital Platform, we may contact your parent or guardian about your communications. If we learn we have improperly collected or received personal information from a child, we will delete that information consistent with law. If you are a parent or guardian or otherwise believe we might have any information from a child under 13, you may contact us.

Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the email address in our records. We encourage you to periodically review our Privacy Notice to be sure you are familiar with the most current version.

Contact Information

If you have any questions or concern about this Privacy Notice or the privacy practices at RegDesk, please contact us at privacy@regdesk.co.