Privacy policy

Effective date: Nov 2, 2026

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1. Who We Are and Scope of this Privacy Policy

Sensible Biotechnologies, Inc. (“Sensible Bio”, “we”, “us” or “our”) is a company incorporated under the laws of the State of Delaware, United States, with its registered address at Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801, United States.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws, Sensible Biotechnologies, Inc. acts as the controller of personal data processed in connection with the activities described in this Privacy Policy.

This Privacy Policy explains how and why we collect, use, disclose and otherwise process personal data, in particular in connection with:

our Website at www.sensible.bio (the “Website”) and communications addressed to us through the Website;
our relationships with individual contractors and representatives of our service providers and business partners; and
our patent and other intellectual property-related activities.

This Privacy Policy applies specifically to processing activities for which Sensible Biotechnologies, Inc. acts as a controller. Certain activities within the Sensible Bio group may involve other Sensible Bio group companies. Where another group company processes personal data for its own purposes or together with us, additional or separate privacy notices may apply. Where applicable, those notices should be read together with this Privacy Policy.

The use of cookies and similar technologies on the Website is described separately in our Cookie Policy.

If you apply for a position through a recruitment platform linked from our Website, the processing of your personal data in connection with your application is governed by the privacy information provided through that recruitment platform and is not covered in detail by this Privacy Policy.

If you have any questions about this Privacy Policy or our processing of personal data, you can contact us at gdpr@sensible.bio.
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2. How We Obtain Personal Data

Depending on our relationship with you, we may process personal data relating to:

individuals who contact or communicate with us;
individual contractors;
employees, representatives and other contact persons of our service providers, contractors and business partners; and
inventors and other individuals involved in our patent and intellectual property-related activities.

Our Website is not intended for children, and we do not knowingly collect or process personal data relating to children.

We generally obtain personal data directly from you, for example when you contact us, communicate with us or enter into a contractual relationship with us.

In some cases, we may also receive personal data from other Sensible Bio group companies or from third parties involved in the relevant business relationship or patent and intellectual property matter, where necessary for the purposes described in this Privacy Policy.
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3. Personal Data We Process, Purposes and Legal Bases

We process personal data only where necessary for the purposes described below and where we have a valid legal basis under applicable data protection laws.

Enquiries and communications

When you contact us, for example by email, we may process your name, email address, company or professional details you choose to provide, the content of your message and any subsequent correspondence.

We use this information to respond to your enquiry, communicate with you and manage our business correspondence. We process this data on the basis of our legitimate interests in communicating with individuals who contact us and conducting our business activities (Article 6(1)(f) GDPR). Where your communication relates to entering into or performing a contract with you, we may instead process the data as necessary for the performance of a contract or to take steps at your request before entering into a contract (Article 6(1)(b) GDPR).

Contractors and business contacts

Where we engage or work with individual contractors, we may process their identification and contact details, professional information, information relating to the contractual relationship and the services provided, and related business communications.

Where we communicate with representatives, employees or other contact persons of our service providers, contractors or business partners, we may process their name, business contact details, position or role, and information contained in related business communications.

We process personal data of individual contractors where necessary to enter into or perform a contract with them (Article 6(1)(b) GDPR). Personal data of representatives and other business contacts are processed on the basis of our legitimate interests in managing our business, supplier and contractual relationships (Article 6(1)(f) GDPR).

Patent and intellectual property activities

In connection with our patent and other intellectual property activities, we may process personal data relating to inventors and other individuals involved in patent or intellectual property matters. This may include names, contact and professional details, information concerning inventorship, and other information relevant to patent applications, proceedings or the management of our intellectual property rights.

We process this information where necessary for our legitimate interests in obtaining, managing, protecting and enforcing our intellectual property rights (Article 6(1)(f) GDPR).

Cookies and similar technologies

We may also process personal data through cookies and similar technologies used on our Website. Where such processing requires your consent, it is based on Article 6(1)(a) GDPR. Detailed information about the technologies we use, the data involved, their purposes, providers and retention periods is available in our Cookie Policy.
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4. How We Share Personal Data

We may share personal data with third parties where this is necessary for the purposes described in this Privacy Policy, including with the following categories of recipients:

other Sensible Bio group companies, where necessary to support our business activities, communications, contractual relationships or patent and intellectual property matters;
service providers, including providers of website hosting, IT, email, communications, security and other technical services that support our operations;
providers of website technologies, including providers involved in cookies and similar technologies, as further described in our Cookie Policy;
professional advisers, including patent attorneys and patent agents, legal advisers, accountants and other professional consultants;
patent offices and other competent authorities, where necessary in connection with patent applications, proceedings or the protection of our intellectual property rights; and
courts, regulators, governmental or other public authorities, where disclosure is required or permitted by applicable law.

We disclose personal data only to the extent necessary for the relevant purpose and require service providers processing personal data on our behalf to protect such data in accordance with applicable data protection requirements.
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5. International Data Transfers

Sensible Biotechnologies, Inc. is based in the United States. In connection with the purposes described in this Privacy Policy, personal data may be transferred to or accessed from countries outside the European Economic Area (“EEA”), including the United States, for example by other Sensible Bio group companies, service providers or professional advisers.

Where the GDPR applies, we ensure that such transfers are made in accordance with applicable data protection requirements. Depending on the circumstances, we may rely on:

an adequacy decision of the European Commission, including, where applicable, the EU-U.S. Data Privacy Framework for participating U.S. organizations;
Standard Contractual Clauses approved by the European Commission, together with additional safeguards where necessary; or
another lawful transfer mechanism permitted under the GDPR.

You may contact us at gdpr@sensible.bio if you would like further information about the safeguards applicable to international transfers of your personal data.
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6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, as described in this Privacy Policy.

When determining the appropriate retention period, we take into account the nature and purpose of the processing, the amount and sensitivity of the personal data, the duration of our relationship with the individual concerned, applicable legal and regulatory requirements, and the need to establish, exercise or defend legal claims.

In particular:

personal data contained in enquiries and business communications is retained for as long as necessary to respond to the enquiry, manage the relevant communication or business relationship, and, where appropriate, maintain records of that correspondence;
personal data relating to contractors and other business contacts is retained for the duration of the relevant contractual or business relationship and, where necessary, afterwards for legal, accounting, compliance or dispute-resolution purposes; and
personal data processed in connection with patents and other intellectual property matters may be retained for as long as necessary to file, prosecute, maintain, protect or enforce the relevant intellectual property rights and to comply with applicable legal or regulatory requirements.

Where personal data is no longer required for the relevant purpose and there is no legal or other legitimate reason to retain it, we delete or anonymize it in accordance with our applicable retention practices.
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7. Your Rights under the GDPR

If the GDPR applies to the processing of your personal data, you may have the following rights:

the right to access your personal data and obtain information about how we process it;
the right to request correction of inaccurate or incomplete personal data;
the right to request deletion of your personal data in certain circumstances;
the right to request restriction of processing in certain circumstances;
the right to receive certain personal data in a structured, commonly used and machine-readable format and, where applicable, to have it transferred to another controller;
the right to object to processing based on our legitimate interests;
where processing is based on your consent, the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and
the right to lodge a complaint with the competent data protection supervisory authority.

To exercise your rights, you can contact us at gdpr@sensible.bio. We may need to verify your identity before responding to your request.
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8. Automated Decision-Making

We do not use personal data to make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect individuals.
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9. Data Security

We implement appropriate technical and organizational measures designed to ensure a level of security appropriate to the risks associated with the processing of personal data and to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

When determining appropriate security measures, we take into account the nature, scope, context and purposes of the processing, as well as the risks to the rights and freedoms of individuals. Access to personal data is limited to persons who require such access for legitimate business purposes and who are subject to appropriate confidentiality obligations.

We review and update our security measures as appropriate, taking into account technological developments and changes in the nature or risks of our processing activities.
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10. U.S. Privacy Rights and Disclosures

Residents of certain U.S. states may have additional rights regarding their personal data where the applicable state privacy law applies to Sensible Bio. Depending on the applicable law, these rights may include the right to access, correct or delete personal data, obtain a copy of personal data, and opt out of certain types of processing.

You may submit a request relating to your privacy rights by contacting us at gdpr@sensible.bio. We will verify and respond to eligible requests in accordance with applicable law. If applicable law provides a right to appeal a decision regarding your request, you may submit an appeal using the same contact details. We will not discriminate against you for exercising your applicable privacy rights.

We do not sell personal data or use personal data for targeted advertising.

Based on our current Website practices, we do not use the Website to track individuals’ online activities over time and across third-party websites for behavioral advertising purposes. We do not permit third parties to engage in such collection through our Website. Accordingly, browser “Do Not Track” signals do not change our current Website practices. Where applicable law requires us to recognize an opt-out preference signal or similar mechanism, we will process such signals as required by law.

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11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our processing activities, legal requirements or business practices.

If we make material changes, we will provide appropriate notice, for example by publishing the updated Privacy Policy on our Website and updating the effective date. Where required by applicable law, we will provide additional notice or obtain consent before the changes take effect.