Privacy Policy

PRIVACY POLICY, January 1, 2025

ABOUT PATCHABLE LLC

Patchable LLC is a limited liability corporation based in Pennsylvania that specializes in transdermal products.

We process personal data in different contexts and we do so by respecting your privacy, as part of our unwavering commitment to ethical and responsible practices. We process personal data collected through our website (“Website”), we also gather personal data for corporate communication purposes, and for conducting our day-to-day business, including research studies.

ABOUT THIS PRIVACY NOTICE

This Privacy Notice is designed to help you understand what information we gather from you when you visit our Website or interact with us, and what we do with that information.

This Privacy Notice applies to information collected by Patchable LLC through our Website or in the course of our business activities, including information from our suppliers, their personnel and other health care professionals, and researchers that participate in research studies that we sponsor. We have a specific polices for how we process personal data from our Website, including Cookies, for our employees.

PERSONAL DATA WE COLLECT

Personal data as used herein means all information that can directly or indirectly identify you or other individuals. We collect different types of personal data depending on the context of your interactions with Patchable LLC.

Patchable LLC collects the following types of personal data:

  • Personal data collected through the Website: including contact information provided directly by you when you submit information through the Website, request investor information or subscribe to our news alerts. Some information is also collected automatically through the use cookies, including Internet Protocol (“IP”) address, browser type, and web log data.
  • Personal data from job applicants: when you apply for a job posting with Patchable LLC, information collected includes your contact details, resume, employment history and other information that you submit for our consideration.
  • Personal data from health care professionals and our vendors.
    Personal data collected from public sources.
  • Other personal data provided directly by you: we collect your contact details if you request information or submit questions to us, including other personal data that you decide to share with us.

USE OF PERSONAL DATA

The purposes for which we collect and use your personal data varies depending on the type of relationship you have with us, for example if you are a Website user or applying for an open job position

We will use your personal data:

1.For our everyday business purposes, including recruitment practices and notices of any legal updates;

2.To provide you with requested information;

3.To operate the Website, and to analyze it for trends and statistics.

4.To provide company informational materials and content, as well as other communications that may include invitations to events hosted or sponsored by Patchable LLC.

5.To comply with laws and regulations, including court orders, or in the course of litigation or defense from legal claims;

6.To protect the rights, property or safety of Patchable LLC, or any of our respective business partners, or other third parties in accordance with Data Privacy Laws;

7.To cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to other users, including suspected fraud, or situations involving potential threats to the physical safety of any person;

8.To share your personal data for other uses that you specifically authorize us based on your consent.

DISCLOSURE OF PERSONAL DATA

At times, Patchable LLC engages third party contractors or service providers to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

Disclosures to Third Parties Assisting in Our Operations. We engage with contractors and service providers for the following services: email solutions, providing cloud hosting services, analyzing data and usage of the Website, or providing support and maintenance services for the Website, as well as agents, legal, regulatory, audit and other professional and business advisors. Such recipients may be located in the United States (US) or in other jurisdictions such as the European Economic Area (EEA), the United Kingdom (UK) or Asia Pacific. If the engagement involves the transmission of personal data, we require the service provider to sign a data processing agreement consistent with this notice before any data is disclosed. These companies do not have any independent right to share or use this information.

Disclosures required by law. We may provide information about you, to respond to subpoenas, court orders, search warrants, legal processes or governmental regulations or inquiries, or to establish or exercise our legal rights or defend against legal claims.

Other Parties with Your Consent or at Your Direction. In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you consent to or request such sharing.

Business Transfers. We may share your personal data with another business entity in connection with the license, sale, assignment, merger or other transfer of all or a portion of Patchable LLC’s business to such business entity.

PRIVACY SETTINGS / OPT-OUT / CHANGES / ACCESS

At certain locations on the Website where information about you may be requested, you are offered the opportunity to opt-out of receiving communications from Patchable LLC. You may also review and request changes to your personal data that Patchable LLC has collected, including the removal of your personal data from Patchable LLC databases in order to prevent receipt of future communications, by contacting us at privacy@patchable.com.

If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email or by contacting us at privacy@patchable.com.

You can also contact us at privacy@ patchable.com for your opt-out and access rights related to research studies.

European Data Protection Rights

If you reside or otherwise find yourself in the territory of the European Economic Area (EEA), the United Kingdom, or Switzerland, we are committed to facilitate the exercise of your rights granted by the data protection laws of these territories.
For the purposes of the European Data protection law we are controllers of your personal data. You can contact our Legal Department with any inquiries you may have regarding the processing of your personal data at privacy@patchable.com.

Patchable LLC assigns a legal basis for each data collection and use:

  • For our everyday business purposes, including our research studies, legal communications and responses to your requests: legitimate interest to conduct our day-to-day business, communicate with you or to respond to your inquiries.
  • Recruitment practices: Necessity to enter into a contract.
  • Information collected automatically (cookies): consent when legally required and legitimate interest of Patchable LLC to analyze trends and website statistics.
  • Corporate communication and informational communications: legitimate interest of Patchable LLC to send corporate communication and informational material, or consent when you directly request this information.
  • Compliance with laws and regulations: compliance with legal obligation.
  • Protect the rights, property and safety of Patchable LLC or third parties: legitimate interest of Patchable LLC or other third parties to protect their rights, property or safety. Patchable LLC recognizes your Data Privacy Rights We remind you that you may exercise certain rights you may have under applicable law and regulation, including the following rights:
  • Right to access, rectification, restriction of processing, erasure, and data portability: we provide you with access to your own personal data. In addition, we will rectify your personal data when it is incorrect or inaccurate, and we will ensure the right to erasure, portability and to restriction of processing when these rights are not incompatible with other legal obligations.
  • Right to object: for all Patchable LLC, Inc. corporate communications, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced to ensure that it is not incompatible with local regulations or our legitimate interests.
  • Right to withdraw consent at any time. When we use your information based on your consent, you have the right to withdraw such consent at any time.
    Patchable LLC does not engage in automated decision making, including profiling.
  • Right to lodge a complaint with your supervisory authority. If you are not satisfied with our response or how we process your personal data, you can complain to the data protection authority of your habitual residence.


For your rights in the context of research studies, please contact us at privacy@patchable.com.

Data Privacy Rights requests should be submitted as follows:

  • Opt-out of corporate communications: If you wish to opt out of informational emails, you may do so by following the “unsubscribe” instructions in the email.
  • To enforce the rest of your rights, or for any further privacy-related question or concerns you may have, you can contact us by email at privacy@patchable.com . We will attend to your request as required by law in a timely manner, but in any event endeavor to respond within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
  • You also have the right to lodge a complaint with a supervisory authority: A list of the European data protection authorities is available here, the contact of the UK Information Commissioner's Office (ICO) is available here, and the contact of the Federal Data Protection and Information Commissioner of Switzerland is available here.


Transfers of Personal Data Outside of Your Local Jurisdiction
If you are located outside the United States and you interact with our Website or provide us personal data, then your personal data may be transferred to the United States or to other jurisdictions.

Please note that when you send us personal data from these jurisdictions (e.g. via email or via our website), Patchable LLC, located in the United States, processes them according to this Privacy Policy and applicable US law, which may not provide the same level of data protection as the country where you are located. However, we provide appropriate safeguards to ensure the same level of protection of your personal data.

We process your personal data to the United States (US) whenever you send us information through our Website or interact with us. If you are located in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland, please note that the US has not obtained adequacy status from the European Union. However, Patchable LLC has elected to self-certify to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework ("Privacy Shield") for commercial data. Please note that the European Court of Justice has invalidated the Privacy Shield by its “Schrems II” decision dated 07/16/2020. Until the United States and the EU Commission will agree on a successor to the Privacy Shield, Patchable LLC will until further notice not rely on its Privacy Shield registration and certification for EEA/Swiss data transfers.

Rather, in the context of our research studies, we use other transfer mechanisms such as the Standard Contractual Clauses approved by the European Commission and/or informed consent (Art. 49 (1) (1) GDPR) when necessary for instance, when the trial involves transferring personal data to other jurisdictions with less stringent data privacy laws.

For personal data originating in the EEA, UK and Switzerland, this Privacy Notice demonstrates our commitment to processing your personal data in accordance with these data transfer mechanisms. For additional information see your European Data Protection Rights. If you have inquiries in this regard, contact us at privacy@patchable.com.

In accordance with our policy regarding disclosure and sharing of data, detailed in section 5 above, your personal data will only be shared as appropriate with third parties that process information on behalf of, or with, Patchable LLC in the U.S. If we disclose personal data received under the data transfer mechanism to a third party, Patchable LLC in the U.S. ensures that the third party has contractual provisions that require the same level of security and confidentiality safeguards as required under the data transfer mechanism, as the case may be. Under certain circumstances, Patchable LLC in the U.S. may remain liable for the acts of certain third parties if those third parties process the EEA/UK/Switzerland-originating personal data that Patchable LLC discloses to them in a manner that is inconsistent with the data transfer mechanism.

Children's Privacy Protection

You should be at least 18 years old to use this Website.

The Website does not seek to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us via this Website.

Notwithstanding the foregoing, individuals under 18 years of age who have provided personal data to us through the Website may have the personal data that they have provided to us through the Website deleted by contacting us at privacy@patchable.com and requesting deletion.

Retention Periods

Patchable LLC retains personal data for the length of time required to fulfill the purpose for which the data was collected.

According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes for which they have been processed. The retention periods are established considering the purposes defined in this privacy notice, all relevant legal requirements and the context in which we process your personal data. For instance, we keep the personal data of prospective employees that have not been successful in joining the company only for the duration of the hiring process, unless they consent to us keeping their data for future hiring campaigns. In addition, personal data collected automatically through the Website through cookies can be kept for 1 year. After the retention period expires, the personal data is deleted.

Security

Patchable LLC understands that storing our data in a secure manner is essential. We take reasonable precautions to keep all information secure against unauthorized access and use.

Patchable LLC stores personal data by using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification.

In addition, our information security team has developed policies, standards and procedures to support and enforce preventive and detective operational controls to ensure the confidentiality, integrity, and availability of Patchable LLC’s data.

Please note, however, that while Patchable LLC has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Website or via email cannot be guaranteed.

The Website may contain links to other websites. Patchable LLC is not responsible for the privacy practices or the content of those websites. This Privacy Notice applies solely to information collected by the Website. Users should be aware of this when they leave the Website, and should review the privacy statements of each third-party website.

Notice to California Residents

Please refer to our CCPA California Resident Privacy Notice.

Changes to this Privacy Notice

This Privacy Notice may be revised from time to time as we add new features, as laws change, and as industry privacy and security best practices evolve.

If we update the Privacy Notice, we will let you know about any changes that we consider material by placing a note on the Website. The most current version of the Privacy Notice will always be available on the Website. You can check the "effective date" posted to see when the Privacy Notice was last updated.

Contact

All questions or comments may be directed to privacy@patchable.com.

You may also contact us at the mailing address below.

Patchable LLC
2395 Lancaster Pike, 1st Floor
Reading, PA 19607

© 2025 Patchable LLC. All rights reserved.