CANOPY PRIVACY POLICY

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Canopy Immuno-Therapeutics Ltd. (“Canopy”, “we”, “our” or “us”), use, collect and store personal information that we collect or receive from or about you (“you”) in connection with [https://canopy-biotech.com/] (together with its subdomains, the “Website”).

We greatly respect your privacy, which is why we make every effort to provide a Website that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. With respect to Israeli privacy law, you are not legally required to provide us with personal information, and the provision of your personal information is voluntary and is provided based on your free will and consent. However, please note that if you choose not to provide certain information, we may not be able to provide you with the full range of the Website or respond effectively to your requests. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of contents: 

1. What personal information we collect, why we collect it, and how it is used
2. How we protect and retain your personal information
3. How we share your personal information
4. Your privacy rights 
5. International transfers of personal information
6. Use by children
7. Interaction with third party products
8. Cookies and tracking technologies
9. Contact us

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Canopy is a biotechnology company developing a “reverse immunization” approach to therapies for autoimmune diseases. The Website is intended to provide general information about Canopy’s technology, research initiatives and therapeutic pipeline to business development professionals, investors, industry professionals, journalists, prospective partners and other interested parties, and is not intended for use by patients. We do not collect patient data, clinical trial data or health information through the Website. 

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This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

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1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

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1. We Process the Following Personal Information: 

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1. Personal information provided through the Website. If you choose to subscribe to our mailing list, we collect your full name and email address. Subscribing to our mailing list is voluntary and not mandatory. If you contact us, we will also collect your contact details and any other information you choose to include in your communication. Please do not provide us with any health or medical information through the Website.
2. Personal information automatically collected. When you visit the Website, our website hosting provider may automatically collect certain technical information, such as your Internet protocol (IP) address, browser type, device type, operating system and the date and time of your visit, to the extent necessary to operate, maintain and secure the Website. We do not use cookies, pixels or similar tracking technologies on the Website. 
3. Device and Browser Data. To operate and secure the Website, our website hosting provider may collect limited technical data about the device and browser you use to access the Website, such as device type, operating system, browser type and version, browser language and display settings. We do not collect advertising identifiers, device IDs or MAC addresses, and we do not use location-based technologies or collect precise location data through the Website.
4. Log Files. Our website hosting provider may maintain standard server log files, which may include your IP address, browser type, date and time stamps, the requested URL and referring/exit pages. We use this data only to operate, maintain, secure and improve the Website, including detecting and preventing technical issues and misuse, and not to profile visitors or collect demographic data.

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2. We process personal information for the following purposes:

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1. To allow you to make use of our Website. We will use your personal information to allow you to make use of our Website, including (i) to add you to our mailing list, at your request; (ii) to answer your questions and to allow you to communicate with us; and (iii) to operate, maintain, secure and improve our Website.
2. For Administrative Purposes. Canopy uses your personal information (i) to respond to your questions, comments and other requests for information; (ii) for internal quality control purposes; (iii) to establish a business relationship; and (iv) to generally administer our business and the Website.
3. To Send You Updates. Where you have requested to join our mailing list, Canopy uses your name and email address to send you news, updates and other information about Canopy, its technology and its pipeline. You may opt out of receiving such communications at any time as described below.
4. Security purposes. Some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
5. De-identified and Aggregated Information Use. We may create and use de-identified and/or aggregated information to operate, analyze, improve, and develop our Website. We may share such de-identified and/or aggregated information with third parties for lawful purposes.

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3. The lawful bases we rely on for processing personal information are (if and when applicable):

1. The data subject has given consent to the processing of his or her personal information;
2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; 
3. processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
4. Processing is necessary for the purposes of  legitimate interest.

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2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

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1. Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us, please make sure to take appropriate measures to protect this information.
2. Retention of your personal information. We retain your mailing list information until you unsubscribe or send a valid deletion request, and other personal information for as long as necessary for the purposes described in this Privacy Policy. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

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3.  HOW WE SHARE YOUR PERSONAL INFORMATION 

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We may share your personal information as follows: 

1. The personal information Canopy gathers may be shared with our partners and other third parties, as described in this section.
2. We also share personal information about you with our affiliated companies . 
3. We use third party service providers to process your personal information for the purposes outlined above, including, without limitation: 
   
   1. With Webflow, Inc., our website hosting and content management platform, in order to host and manage our Website; and
   2. With [contact-us@canopy-biotech.com], our email provider, in order to manage our mailing list and send you communications you requested.
4. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Canopy, our Website, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
5. We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
6. We may use or disclose the personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
7. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.
8. Where you have otherwise provided your consent to us for sharing or transferring your personal information.

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4. YOUR PRIVACY RIGHTS

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1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

1. You have the right to withdraw consent to the processing, where consent is the basis of processing. 
2. You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
3. You have the right to object to unlawful data processing under certain conditions.
4. You have the right to the erasure of past personal information about you (your “right to be forgotten”) under certain conditions.
5. You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
6. You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
7. The personal information we collect is not used for automated decision-making or profiling. As described in Section 4.3 below, you can opt out of our mailing list by sending us a “BLOCK” email or by following the unsubscribe instructions in our email messages. 

2. You can exercise your rights by contacting us at contact-us@canopy-biotech.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you (where this is permitted by applicable law). To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
3. Mailing list – opt-out: You may choose not to receive our mailing list emails by sending a single email with the subject “BLOCK” to contact-us@canopy-biotech.com. Please note that the email must come from the email account you wish to block. Alternatively, you can use the unsubscribe link found at the bottom of any email you receive from us to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

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1. In order to run our business and provide our Website to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by using Standard Contractual Clauses or other lawful mechanisms:

1. making sure the destination country has been deemed by the European Commission to provide an adequate level of protection for personal information; and/or
2. by executing data onward transfer instruments such as data processing and protection agreements.

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According to the Israeli law, by providing your consent to this Privacy Policy, you acknowledge and agree that personal information relating to you may be transferred to and stored outside the borders of Israel, in accordance with applicable law and for the purposes described herein.

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6. USE BY CHILDREN. The Website is not intended for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of 18. If you are under the age of 18, please do not use the Website or provide any personal information to us. In the event that we become aware that you provided personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at contact-us@canopy-biotech.com. 

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7. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

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8. COOKIES AND TRACKING TECHNOLOGIES. We do not use cookies, pixels, web beacons, analytic tools or other similar tracking technologies on the Website. If we decide to use such technologies in the future, we will update this Privacy Policy and, where required by applicable law, obtain your consent before doing so.

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9. CONTACT US. For any questions, concerns, or to exercise your privacy rights, please contact us at: contact-us@canopy-biotech.com.

Data controller: Canopy Immuno-Therapeutics Ltd., Company Number: 516091204, Registered Address: HaGalim 5, Megadim, 3087500, Israel.

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Last Updated: October 14, 2026

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