Privacy Policy

Effective as of October 10, 2024

This Privacy Policy describes how Ulys Holdings Inc. (“Ulys,” “we,” “us,” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the “Site”)).

Index

• ● Personal information we collect
• ● How we use your personal information
• ● How we share your personal information
• ● Your choices
• ● Other sites and services
• ● Security
• ● International data transfers
• ● Children
• ● Changes to this Privacy Policy
• ● How to contact us

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Site or otherwise includes:

• ● Contact data, such as your first and last name and email address.
• ● Communications data based on our exchanges with you, including when you contact us through the Site, email, social media, or otherwise.
• ● Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• ● Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above and demographic information that we obtain from other sources, such as:

• ● Public sources, such as social media platforms, and other publicly available sources.
• ● Private sources, such as data providers, social media platforms and data licensors.
• ● Marketing partners, such as joint marketing partners.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Site, our communications and other online services, such as:

• ● Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• ● Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• ● Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. We will store a record of your preferences in respect of the use of these technologies in connection with the Site. Some of the automatic collection described above is facilitated by the following technologies:

• ● Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers’ place.
• ● Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• ● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• ● provide and operate the Site and our business;
• ● enable security features of the Site;
• ● communicate with you about the Site, including by sending Site - related announcements, updates, security alerts, and support and administrative messages; and
• ● provide support for the Site, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to personalize the Site for you, which may include using your personal information to:

• ● understand your needs and interests;
• ● personalize your experience with the Site and our Site - related communications; and
• ● remember your selections and preferences as you navigate the Site.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Site and our business and to develop new products and services.

Marketing. We and our service providers may collect and use your personal information to send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

Service improvement and analytics. We may use your personal information to analyze your usage of the Site, improve the Site, improve the rest of our business, help us understand user activity on the Site, including which pages are most and least visited and how visitors move around the Site, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

• ● comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• ● protect our, your or others’ rights, privacy, safety or property(including by making and defending legal claims);
• ● audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• ● enforce the terms and conditions that govern the Site; and
• ● prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events such as changes of control, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de- identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• ● Technical operation. To allow the technical operation of the Site.
• ● Functionality. To enhance the performance and functionality of our services.
• ● Analytics. To help us understand user activity on the Site, including which pages are most and least visited and how visitors move around the Site, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose.You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Service providers. Third parties that provide services on our behalf or help us operate the Site or our business (such as hosting, recruitment, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Ulys, financing of Ulys, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Ulys as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non- marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning. Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Site may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Site is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Site from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Site after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Site and our business.

How to contact us

● Email: contact@ulysapp.com