Privacy Policy

1. Policy Introduction

Neuren Pharmaceuticals Limited together with its affiliates and subsidiaries worldwide (Neuren, we, us or our) are committed to protecting the privacy and security of your personal data and personal information. This Neuren Privacy Policy (Privacy Policy) describes the types of personal information and other information we collect from and about you and also describes your rights with respect to your personal information and how you may exercise your rights.

Neuren is bound by the Privacy Act 1988 (Commonwealth) (Australian Privacy Act) and the Australian Privacy Principles that are contained in that Act.

“Personal information” is defined under the Australian Privacy Act as information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not and whether the information or opinion is recorded in a material form or not.

 This Privacy Policy may contain information not applicable to you because of where you are located or the type(s) of personal information we collect about you.

Our websites, web portals, mobile applications or other digital services (together, our Websites) may contain links to third-party websites that we do not operate, control or endorse. Once you leave our Websites, we are not responsible for the protection and privacy of any information you provide. We recommend that you read the privacy policies of these third-party websites, and if needed, contact the third parties directly for information about their privacy practices. 

2. Collection of Personal Information

What personal information does Neuren collect?

The types of information that we may collect and receive are described in this section and include information that you provide to us, information that we collect automatically, and information that we collect from third party sources.

Examples of personal information that we may collect about you include:

• Contact Data: information such as your name, postal address, telephone number and email address;
• Demographic Data: information including gender, citizenship, date of birth, race, ethnicity, veteran status, disability status;
• Relationship Data: information from enquiries made (including any personal information submitted via our websites or contact forms);
• Geolocation Data: information that may be transmitted to us by your computer, mobile device, or using one of our mobile applications;
• Job Applicant Data: information such as your contact information, résumé or curriculum vitae, work experience, education, academic transcript, date of birth or age, driver’s license information, tax ID number or other government identification necessary to administer an employment relationship and information relating to references;
• Financial Data: information related to amounts invoiced and/or payments made, services provided, travel and expenses, tax-related information, financial disclosures, banking information, W9 information and your billing address;
• Health Data: health information including information that is collected relating to participation in or consideration for Neuren’s clinical trials;
• Clinical Trial Data: information collected in the course of screening for and conducting clinical trials (including the information provided when completing information sheets and forms, such as pre-treatment evaluation forms and patient consent forms);
• Prior Interactions Data: information related to your past collaborations with us, e.g., contact with our medical affairs representatives, clinical trials staff, consulting activities, or clinical trials participation; and
• Shareholder Data: information including shareholder contact details.

Neuren will take reasonable steps to ensure that the personal information that is collected, used or disclosed by it is complete and up to date. Neuren will only collect personal information about an individual from that individual unless it is unreasonable or impractical to do so. Neuren will only adopt, use or disclose government identification if it is required or authorised by law to do so.

Sensitive Information

Certain Personal Information Neuren collects about you may be considered sensitive information under applicable laws (such as your healthcare information, race or ethnic information, genetic information,  political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, or criminal records, etc.).

To protect such Sensitive Personal Information, we will:

• only use the sensitive information for the purposes it was collected for or for a secondary purpose that is directly related to the primary purpose;
• take appropriate security and technical measures to protect and process your sensitive information; and
• provide notices and/or obtain your explicit consent for processing your sensitive personal information where required by applicable laws.

Personal information of children and minors

Neuren recognises that some of its activities, including clinical trials, may involve the collection of personal information about individuals under the age of 18 years.

Neuren will only collect, use or disclose personal information (including sensitive information such as health information) about a child where:

• the collection, use or disclosure is required or authorised by law; or
• a parent, legal guardian or other responsible person has provided consent on behalf of the child; or
• the child is otherwise capable of giving valid consent in accordance with applicable laws.

Where consent is required, Neuren will take reasonable steps to verify that the consent is given by a parent, guardian or other responsible person. Personal information about children will be handled in accordance with this privacy policy.

Personal information provided by third parties

If Neuren collects personal information about an individual from a third party, Neuren will take reasonable steps to ensure that the individual is made aware that Neuren has collected the personal information and of the matters set out in this Privacy Policy, unless an exception applies under the Act.

Where a person provides personal information to Neuren about another individual, that person represents that they are authorised to do so and that the individual has been informed of, or has consented to, the disclosure of their personal information to Neuren, as required by law.

How does Neuren collect personal information?

Neuren may collect personal information about an individual when an individual interacts with Neuren in person or electronically, including:

• when an individual calls or emails Neuren in relation to medical, investor or general enquiries;
• when an individual signs up for email alerts on Neuren’s website; and
• when an individual registers an expression of interest for a clinical trial.

We may also collect information about you from other sources, such as public records, and/or third-party data suppliers who enhance our files, and/or from social media sites such as LinkedIn and X (formerly Twitter).

Personal information may also be collected on Neuren’s behalf by its consultants and service providers in connection with clinical trial pre‑screening, referral and related activities. Neuren may access this personal information to assess and determine your suitability for a trial and for other purposes described in this Privacy Policy. Where Neuren has collected personal information from a third party, such personal information will be held, used and disclosed by Neuren in accordance with this Privacy Policy.

Neuren will collect personal information about an individual where the information is reasonably necessary for one or more of our functions or activities. The kinds of personal information collected and held, how that information is collected and held and the purposes for which that information will be collected, held, used and disclosed will depend on the circumstances.

Server Log Files: Your Internet Protocol (IP) address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit our websites, along with the time(s) of your visit(s) and the page(s) that you visited. We use the IP addresses of all visitors to our websites to calculate our websites’ usage levels, to help diagnose problems with website servers, and to administer the websites. We may also use IP addresses to communicate with or block access by visitors who fail to comply with our terms and conditions for use of our Services. Collecting IP addresses is standard practice on the Internet and is carried out automatically by many websites.

Cookies: We may also collect information based on how you use our website, including through 'cookies', web beacons, pixel tags and other similar technologies.

Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable our systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services. No attempt is made to use Cookie Information to personally identify you.  However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of our website may not function fully for users that disable cookies.

Google Analytics: We may use Google Analytics, a web analysis service provided by Google, to better understand website usage. Google Analytics collects information such as how often users visit websites, what pages they visit and what other websites they used prior to visiting. Google uses the data collected to track and examine the use of the websites, to share such data with other Google services, or to personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. To opt-out of analysis by Google Analytics on our websites, please visit //tools.google.com/dlpage/gaoptout.

Why does Neuren collect personal information?

Neuren collects personal information for the purposes of:

• responding to your requests for information about our services; 
• determining if you are eligible for certain services or programs;
• determining if you are eligible to participate in one of our clinical trials or to be an investigator in our clinical trials;
• permitting your participation in a clinical trial;
• managing or developing our business relationship with you (e.g., to respond to questions, invite you to events, comply with regulatory obligations, or determine eligibility for Neuren programs); 
• recruiting and/or considering you for employment; 
• our research, development, and collaboration efforts; 
• regulatory reporting such as adverse event reporting, to communicate product safety information to you or for pharmaceutical transparency reporting;
• referring you to specific clinical sites;
• administering its shareholder relations activities (where applicable);
• other everyday business purposes, such as payment processing and financial account management, product development, contract management, site administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

Neuren may also use personal information for secondary purposes closely related to the above purposes. If Neuren does not collect personal information, it may not be able to provide you with its services.

3. How We Use and Share Personal Information

Neuren will only use or disclose personal information:

• for the primary purpose for which it was collected;
• for any directly related secondary purpose for which it would reasonably be expected to be used or disclosed;
• where the use or disclosure is required or permitted by law; or
• where the individual has provided consent.

Where the personal information is sensitive information (including health information), Neuren will only use or disclose that information in accordance with the Act, including where the individual has consented or where another exception under the Australian Privacy Act applies.

Direct Marketing

Neuren may also use your personal information to identify and promote products or services that may be of interest to you.

At any time you may opt out of receiving direct marketing communications from Neuren.  To do so, please send us an email at: privacy@neurenpharma.com.  Unless and until you opt out, your consent to receive direct marketing communications from Neuren and to the handling of your personal information for this purpose will continue. 

Third-party disclosure

We may share your personal information with third parties with whom we have contracted, our affiliates, business partners, government agencies and regulatory authorities. This includes disclosure to sites that may be assisting Neuren in undertaking clinical trials, or other service providers. We will take reasonable steps to ensure these recipients use your personal information only for appropriate purposes and take appropriate measures to handle your personal information in accordance with the Australian Privacy Act and this Privacy Policy.

Neuren does not sell, share, or otherwise distribute your personal information or other information we collected about you with third parties for their marketing purposes.

We may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would enable the recipient to contact, locate or identify you.

Change of control and business transactions

In the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a corporate sale, merger, reorganization, dissolution or similar event involving the transfer of ownership or control of Neuren, we may transfer information that we have collected to such third party.  Where personal information is disclosed or transferred in these circumstances, Neuren will take reasonable steps to ensure such a third party handles the personal information in a manner consistent with this Privacy Policy, including by requiring the recipient to use the personal information only for the purposes for which it was originally collected (or a directly related purpose) and to protect it using appropriate safeguards.

Legal Obligations

We may disclose information if we believe it is necessary to:

1. comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process;
2. protect the legitimate rights, privacy, property, interests, or safety of Neuren, our patients, business partners, personnel, or the general public;
3. pursue available remedies or limit damages;
4. enforce our terms and conditions on our products or services;
5. for external auditing purposes, compliance and other corporate governance matters; or
6. respond to an emergency.

We reserve the right to disclose personal information when we believe in good faith that such action is necessary to comply with a legal obligation.

In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.

Links To Other Websites

Our websites may contain links to third party websites, which are not operated or controlled by Neuren and for which Neuren is not responsible. The links from the websites do not imply that Neuren endorses or has reviewed the third party websites. Once you leave one of our websites, we are not responsible for the protection and privacy of any information you provide.  We suggest contacting those third parties directly for information on their privacy practices.

Unsolicited information

If Neuren receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, Neuren will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

4. Global Access and Data Transfers

Neuren operates in many countries and regions around the world such as Australia and North America and your personal information may be accessible to or shared with any of our locations, our affiliates, consultants, contractors, service providers, suppliers and vendors in various countries for the purposes specified in this Privacy Policy.

The laws in certain countries may not provide the same level of protection as the laws in your country or region. When that is the case, and as required by applicable laws, we take steps to protect your information, such as by entering into contracts with recipients of your information or by implementing additional data protection safeguards.

For transfers of personal information from Australia

Before disclosing personal information to an overseas recipient, Neuren takes reasonable steps to ensure that the recipient handles the personal information in a manner that is consistent with the Australian Privacy Principles and this Privacy Policy, including by entering into contractual arrangements that impose privacy and data protection obligations.

In accordance with Australian Privacy Principle 8, where Neuren discloses personal information to an overseas recipient, Neuren may remain accountable for the handling of that personal information by the overseas recipient.

If Neuren does not disclose personal information to overseas recipients, this may affect its ability to conduct clinical trials, engage international service providers or otherwise carry out its activities.

Children's Privacy Protection

Protecting the privacy of children is especially important to us. We take seriously our obligations under applicable laws concerning the collection of personal information from children.  We request that children do not provide any personal information through our websites.  If you are a parent and become aware that your child has provided us with personal information, please contact us at privacy@neurenpharma.com.

However, there are certain activities where Neuren may collect information about children under the age of 18 years, including clinical trials.

Neuren will only collect, use or disclose personal information (including sensitive information such as health information) about a child where:

• the collection, use or disclosure is required or authorised by law; or
• a parent, legal guardian or other responsible person has provided consent on behalf of the child; or
• the child is otherwise capable of giving valid consent in accordance with applicable laws.

Where consent is required, Neuren will take reasonable steps to verify that the consent is given by a parent, guardian or other responsible person.

Personal information about children will be handled in accordance with this privacy policy.

Your Choices and Rights

If you would like your personal information removed from our systems, changed or updated, you can contact us at: privacy@neurenpharma.com. You may also ask Neuren to correct information about you that you may believe is inaccurate, incomplete or out of date.  If requested, we will, within a reasonable time period, verify and delete or correct your details.

If you request your details be deleted, you will no longer receive emails or other communications from Neuren, except for where required by law or applicable regulations. Your removal from the mailing list or our systems will not remove records of past transactions or delete information stored in our data backups and archives where we are required to keep your data for legitimate business or legal requirements. Data on past transactions and data stored in backups and archives will be deleted in the normal course of our business. 

You have the right to access or, if required by applicable laws, receive a copy of your personal information held by us by making a written request by sending an email to: privacy@neurenpharma.com.

Neuren will not provide an individual access to their personal information to the extent that:

• Neuren reasonably believes that giving access would pose a serious threat to life, health or safety of any individual, or to public health or safety;
• giving access would have an unreasonable impact on the privacy of other individuals;
• the request for access is frivolous or vexatious;
• the information relates to legal proceedings between Neuren and the individual, and would not be accessible by the process of discovery in those proceedings;
• giving access would reveal the intentions of Neuren in relation to negotiations with the individual in such a way as to prejudice those negotiations;
• giving access would be unlawful;
• denying access is required or authorised by or under an Australian law or a court/tribunal order;
• Neuren suspects that unlawful activity, or serious misconduct, that relates to the entity’s functions or activities has been, is being or may be engaged in and giving access would likely prejudice the taking of appropriate action in relation to the matter;
• giving access would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
• giving access would reveal evaluative information generated within Neuren in connection with a commercially sensitive decision-making process.

Under certain laws including but not limited to Australia’s Privacy Act, the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) you may have the following rights with respect to your personal information:

• Your right of access. You may have the right to ask us to provide clear, transparent and understandable information on how we process your personal information, as well as for copies of your personal information. There are some exemptions, which means you may not always receive all the information we process.
• Your right to rectification. You may have the right to ask us to rectify information you think is obsolete or inaccurate and the right to ask us to complete information you think is incomplete.
• Your right to deletion of your personal information. You may have the right to ask us to delete your personal information in certain circumstances.
• Your right to restriction of processing. You may have the right to ask us to restrict the processing of your personal information, during a limited period of time, in certain circumstances.
• Your right to object to processing. You may have the right to object to processing, in which case, Neuren will no longer process your personal information unless Neuren demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
• Your right to data portability. You may have the right to ask that we transfer the information you gave us from one organization to another or give it to you.
• Your right to withdraw your consent. If we process your personal information based on your consent, you have the right to withdraw your consent, without this withdrawal affecting the lawfulness of the processing operations previously carried out.
• Your right to close your account. If you receive our services through online accounts, you have the right to close your accounts. We will then delete or anonymize your personal information associated with your accounts, unless otherwise permitted under applicable laws.

The parties we share your personal information with (as described above) may also need to be contacted in order to complete your request. When necessary, we will contact the necessary parties as part of our process to address your request.

We will respond to your requests within the time period prescribed by applicable laws. Under certain circumstances, Neuren may ask you for specific information to confirm your identity and ensure the exercise of your rights. This is a security measure to safeguard personal information. We will notify you when your request is completed, if we deny your request to exercise your rights (because, for example, an exception applies), or if there is a fee associated with processing your request.

You may designate an authorized agent to exercise your rights on your behalf. In such case, we will also need to verify your agent’s identity and obtain proof of your authorization. We may need to deny a request from an agent whose identity or authorization we cannot verify.

If you believe that Neuren has processed information in a manner that is unlawful or breaches your rights, or has infringed applicable laws, you may have the right to complain directly to your local data protection authority. Without limiting any rights to complain directly to an authority, we are committed to protecting personal information, and complaints may be made directly to us.

5. Security of Personal Information

We may store your personal information in locations where we or our service providers maintain servers.  We store personal information in paper-based and electronic records and systems. Personal information collected in paper-based documents may be converted to electronic form for storage (with the original paper-based documents either archived or securely destroyed). Neuren will also take reasonable steps to ensure that personal information it holds that is no longer necessary for the disclosed purpose is destroyed or permanently de-identified, subject to any legal obligation to keep the personal information for any required period of time.

Remaining Anonymous

You are able to use a pseudonym or remain anonymous when interacting with Neuren in most instances. However, in some circumstances you may have to provide certain personal information. Neuren will inform you if you are not able to remain anonymous or use a pseudonym.

Data Security

Neuren stores personal information and other data using reasonable physical, technical and administrative safeguards to secure information and data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification.  Please note, however, that while Neuren has endeavored to create secure and reliable websites for our users, the confidentiality of any communication or material transmitted to or from one of our websites or via e-mail cannot be guaranteed. You should take special care in deciding what information you transmit, upload, send, or otherwise submit to Neuren.

Notifiable data breaches

Where Neuren has reasonable grounds to believe that an eligible data breach has occurred, it will:

• notify affected individuals in accordance with the requirements of the Australian Privacy Act and other applicable laws; and
• notify the Office of the Australian Information Commissioner (OAIC) if applicable.

Notifications will be made as soon as practicable and will include information about the nature of the breach and recommended steps individuals should take to reduce the risk of harm.

Neuren may also take remedial action to prevent or reduce the risk of harm to individuals.

 California Residents

If you are a California resident (“Consumer”) and interact with Neuren, the information about our collection, uses, and disclosures of your personal information and other information we collect about you can be found in the relevant sections of this Privacy Policy. Specifically:

• In the preceding 12 months, we may have collected, and we may have shared the following categories of personal information about you: Contact Data, Health Data, Relationship Data, Transaction Data, Geolocation Data, and Job Applicant Data. Further information describing these categories of personal information is provided above in the ‘What personal information does Neuren collect?’ section of this Privacy Policy;
• The sources of the personal information and other information we collect about you is provided above in the ‘How does Neuren collect personal information?’ section of this Privacy Policy; and
• Further information on how we use or share your personal information and other information we collect about you is described above in the ‘How we use and share personal information’ section of this Privacy Policy.

We do not sell any personal information or other information collected from California Consumers.

If you choose to exercise any of your rights as outlined above in the Your Choices and Rights section of this Privacy Policy, we will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

Additional Information for Individuals in the European Union/European Economic Area, United Kingdom, or Switzerland

We are required to comply with the European Union’s and the United Kingdom’s General Data Protection Regulations (GDPR), Switzerland’s Federal Act on Data Protection (FADP) and similar applicable local laws with regards to certain personal information we collect. The data controllers of your personal information are the Neuren entities referenced when we collect your personal information. Please contact us if you have any questions about the controller or controllers of your personal information.

Sensitive Personal Data. We may process special categories of information (e.g., sensitive personal data that reveals racial or ethnic origin or genetic, biometric and health information etc.) only where you give us your explicit consent, or when our processing is for scientific research purposes, necessary to meet a legal or regulatory obligation, in connection with the establishment, exercise or defense of legal claims, or is otherwise expressly permitted by law. If we need to collect your personal information by law or under the terms of a contract we have with you and you do not provide the requested information, we may not be able to perform the contract we have, or are trying to enter into, with you. 

The servers where your personal data are stored may be located in countries that have not been deemed by the European Commission to provide an adequate level of protection for personal data. In addition, we may share personal data with our affiliates and external service providers and third parties located outside of the EEA. When we transfer personal data out of the EEA to other countries that have not been deemed adequate, we will implement one or more of the safeguards deemed to provide appropriate safeguards by the European Commission, which may include EU Standard Contractual Clauses, transfers to organizations that protect personal data under binding corporate rules, or transfers to organizations that operate under an approved code of conduct or certification mechanism.

If you have any questions about our privacy practices in the EEA, you may write to us at:

Data Protection Officer

Neuren Pharmaceuticals Limited

Suite 1.01, 117 Camberwell Rd

Hawthorn East  VIC  3123  Australia

If you choose to contact us by mail, please be sure to provide us with your name, address, email address, and/or phone number you would like us to respond to. Or you may send us an email at: privacy@neurenpharma.com.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. At a minimum, we will post an updated version on our websites. Neuren encourages you to review this Privacy Policy regularly for any changes. By continuing to engage with Neuren or providing personal information to Neuren after an updated version of this Privacy Policy is published, individuals are taken to have read, understood and consented to the handling of their personal information in accordance with this Privacy Policy as updated from time to time.

Concerns, Queries and Complaints

If a person has any concern, query or complaint about:

• any personal information that may have been collected, used or disclosed by Neuren;
• this Privacy Policy; or
• a breach of the Australian Privacy Principles or other applicable laws,

they are to be referred to the Data Privacy Officer at privacy@neurenpharma.com.

Concerns, queries and complaints should be placed in writing so that Neuren can fully understand and investigate. Neuren takes complaints very seriously and will respond shortly after receiving written notice of the complaint.

If any person is dissatisfied with Neuren’s handling of a complaint or the outcome, they may make an application to their relevant country data protection authority as set out below (if applicable).

Data Privacy Officer

Neuren Pharmaceuticals Limited

​Suite 1.01, 117 Camberwell Rd

Hawthorn East  VIC  3123  Australia

 

Approved 11 March 2026.