Privacy Policy — Efferon

This Privacy Policy explains how Efferon OÜ ("Efferon", "we", "us", or "our") collects, uses, and discloses information when you visit our website at https://efferon.com and any other websites that link to this Policy (collectively, the "Site").

Efferon OÜ is a company registered in Estonia (registration number 16449268), with its registered office at Mooni tn 18, Kristiine linnaosa, 10613 Tallinn, Harju maakond, Estonia. Efferon OÜ is the controller of personal data processed through the Site.

If you do not agree with this Policy, please do not use the Site.

1. Scope

This Policy applies to information collected through the Site. It does not apply to information we collect offline, through clinical trials, through our products or distribution partners, or through channels operated by other companies in the Efferon group (which are governed by their own privacy notices).

The Site is intended for use by healthcare professionals, institutional partners, investors, and other business contacts. It is not directed to children under 16, and we do not knowingly collect personal data from children.

2. Information We Collect

We collect the following categories of personal data:

Information you provide to us. When you contact us by email (for example at info@efferon.com), request our pitch deck or other materials, subscribe to updates, or otherwise communicate with us, we collect the information you choose to share — typically your name, email address, employer or institution, job title, country, and the content of your message.

Information collected automatically. When you visit the Site, our servers and our analytics providers automatically receive certain information, including your IP address, approximate location derived from your IP address, browser type and version, operating system, referring URL, pages viewed, links clicked, time and duration of your visit, and similar usage data. This information is collected through cookies and similar technologies (see our Cookie Policy).

Information from third parties. We may receive limited information from service providers we engage (for example email delivery, analytics, or hosting providers) to operate the Site.

We do not knowingly collect special categories of personal data (Article 9 GDPR), including health data, or any other patient data through the Site. Please do not submit any patient-identifiable information to us through the Site.

3. How We Use Information

We use the information we collect to:

respond to your inquiries and fulfill your requests (for example, send a pitch deck or follow up on a partnership conversation);
send you updates, news, and educational materials about Efferon and our products, where you have requested them or where permitted by applicable law;
operate, maintain, secure, and improve the Site and our content;
understand how visitors use the Site and measure the effectiveness of our communications;
comply with applicable laws, including medical device regulations and tax obligations, and respond to lawful requests from authorities;
detect, prevent, and respond to fraud, security incidents, and misuse of the Site; and
establish, exercise, or defend legal claims.

We do not sell personal data, and we do not use personal data for cross-site tracking or behavioral advertising.

4. Legal Bases for Processing

We process personal data under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and Estonian data protection law, relying on the following legal bases:

Consent (Article 6(1)(a) GDPR) — for non-essential cookies and for marketing communications, where required.
Contract or pre-contractual steps (Article 6(1)(b) GDPR) — to respond to your requests and discuss potential collaboration.
Legitimate interests (Article 6(1)(f) GDPR) — to operate and secure the Site, understand how it is used, and communicate with business contacts. You may object to processing on this basis as described in Section 8.
Legal obligation (Article 6(1)(c) GDPR) — where we are required to retain or disclose information under applicable law.

5. How We Share Information

We share personal data only as described below:

Group companies. We share information with other companies in the Efferon group for the purposes described in this Policy, including responding to inquiries, coordinating partnership discussions, and managing our business.
Service providers. We share information with vendors that process information on our behalf — for example website hosting (Vercel Inc.), analytics providers, email delivery services, and customer relationship management providers. These vendors act as processors and are bound by contractual confidentiality and data protection obligations.
Legal, safety, and compliance. We may disclose information if we believe in good faith that disclosure is required by law, regulation, or legal process; to respond to medical device safety obligations; to protect the rights, property, or safety of Efferon, our personnel, or the public; or to enforce our Terms of Use.
Business transactions. If Efferon is involved in a merger, acquisition, financing, reorganization, or sale of assets, personal data may be transferred as part of that transaction, subject to confidentiality protections.

6. International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA), including in the United States. When we transfer personal data to a country that has not been designated by the European Commission as providing an adequate level of protection, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses. You may request a copy of those safeguards by contacting us at the address in Section 12.

7. Retention

We retain personal data for as long as needed to fulfill the purposes described in this Policy, including responding to your inquiries, maintaining business records, and complying with legal, accounting, tax, and regulatory obligations. When information is no longer needed, we delete it or anonymize it.

8. Your Rights

Under the GDPR, you have the following rights with respect to your personal data:

to access the personal data we hold about you and to receive a copy;
to rectify inaccurate or incomplete information;
to erase your personal data ("right to be forgotten");
to restrict or object to certain processing, including processing based on our legitimate interests and processing for direct marketing;
to data portability, where processing is based on consent or contract and carried out by automated means;
to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal; and
to opt out of marketing communications at any time, using the unsubscribe link in any marketing email or by emailing us at the address below.

To exercise any of these rights, please contact us at info@efferon.com. We will respond within the time period required by applicable law. We may need to verify your identity before acting on your request.

You also have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, email info@aki.ee, website https://www.aki.ee. You may also contact the supervisory authority in your country of residence or place of the alleged infringement.

9. Cookies and Analytics

We use cookies and similar technologies for site operation and for analytics. We use Vercel Web Analytics (provided by our hosting provider) and Google Analytics to understand how visitors find and use the Site. These tools may collect IP addresses, device identifiers, and usage data. Where required by law, we will request your consent before setting non-essential cookies. For details and your choices, see our Cookie Policy.

10. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal data from unauthorized access, disclosure, alteration, and destruction. No method of transmission over the internet or method of electronic storage is completely secure, however, and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the "Last updated" date at the top of the Policy. If we make material changes, we will provide additional notice as required by applicable law (for example, by posting a notice on the Site).

12. Contact Us

For privacy questions, requests, or complaints, please contact us at:

Efferon OÜ
Attn: Privacy
Mooni tn 18, Kristiine linnaosa
10613 Tallinn, Harju maakond
Estonia
Email: info@efferon.com