Privacy Notice for Healthcare Professionals
Effective as of: January 2026
Introduction
Elion Therapeutics, Inc. (“Elion”, “we”, “us”, “our”) sponsors ethically approved human clinical trials. This Privacy Notice (the “Notice”) addresses the collection, use and disclosure of the personal data of health care professionals, including clinical trial personnel, principal investigators and site staff (“Personnel”, “you”, “your”, “data subjects”) in connection with the clinical trials we sponsor. This Notice also describes how we protect your personal data, and how you can exercise your privacy rights.
This Notice does not apply to personal data collected by any other means, such as through our public website. This Notice also does not apply to personal data of other individuals including our employees or contractors.
Our Role with Respect to Your Personal Data
Elion generally acts as an independent data controller for the personal data described in this Notice when processed in the context of the clinical trials we sponsor. This means that we alone determine the purpose and means of the processing of your personal data.
Personal Data We Process
Health care professionals
Including clinical trial personnel, principal investigators and site staff
Types of Personal Data Collected
- Personal details (name, contact details, NPI number if applicable)
- Professional details (place of practice, job title, medical field, qualifications, scientific activities, publications, memberships)
- Financial information (declarations of financial interests, payment and reporting data)
- Interaction details (meetings held, topics discussed, feedback provided)
- Location information (study site location)
- Other information provided as part of qualifications or responsibilities (CVs, resumes)
Purpose of the Processing
- Evaluating participation in a clinical trial
- Establishing and managing our relationship with you (planning, organizing, reviewing collaboration; analysis and/or communication)
- Ensuring we provide information relevant to your expertise, interests and preferences
- Complying with applicable laws and regulations
Legal Basis for Processing
- Consent
- Performance of a contract
- Legitimate interests (after balancing your privacy rights and our interests)
- Compliance with a legal obligation
Sources of Personal Data
- Directly from you (CVs/resumes via email or questionnaires)
- Your institution
- Public sources (licensed practitioner registers, databases, websites)
- Third parties (e.g., CROs). Where a CRO collected data as its own controller, its processing is governed by its own privacy notice.
- Other documents/forms you provide (clinical R&D activities, webinars, educational events, services, updates)
Sharing Personal Data with Third Parties
We may share your personal data with others, from time to time, in connection with the purposes described in this Notice. In particular, we may make your personal data available to:
- regulatory bodies and authorities, for example in respect of clinical trials and in the context of applying for product registrations;
- our trusted third party service providers that supply goods or services to us such as legal counsel, auditors and IT service suppliers;
- our trusted third party service providers who supply services on behalf of us to conduct the clinical trial, such as contract/clinical research organization services, data storage and data analytics services;
- law enforcement agencies or other governmental authorities pursuant to a court order, to protect our interests, or where otherwise required by law or legal process;
- actual or prospective purchasers of our businesses in the event of a sale, merger or acquisition;
- the public in a limited way through websites such as www.ClinicalTrials.gov and other websites and databases that serve a comparable purpose and enhancing clinical trial transparency;
The personal data you provide will become part of the clinical trial databases and paper files as needed for the implementation, performance, and record-keeping (archiving) of the clinical trial.
International Data Transfers
Sharing your personal data in connection with any of the above purposes and in relation to the conduct of the clinical trials may involve transferring it to countries, including countries outside of your own, whose data protection and privacy laws may not be equivalent to, or as protective as, those that exist in your country of residence. Many of these third parties are located in the United States of America.
Any transfers of personal data outside the European Economic Area (EEA) or United Kingdom (UK) will be done in compliance with the international data transfer restrictions that apply under applicable data protection laws, including, where appropriate, through the use of standard contractual clauses adopted by the European Union (EU) Commission, with necessary adjustments for transfers from the UK, a copy of which is available to you on request to any of the contact methods under the “Contact Us” section below.
Data Integrity and Security
We will take appropriate technical and organizational security measures to protect your personal data consistent with applicable privacy and data security laws. When we retain a third-party service provider, that provider will be carefully selected and required to use appropriate measures in accordance with applicable laws to protect the confidentiality and security of personal data. That provider will only be permitted to process your personal data in accordance with our instructions and as described in this Notice.
How Long We Keep Your Personal Data
We retain your personal data for as long as necessary to fulfil the purposes we collected it for and only for as long as we continue to have a relationship with you, unless a longer retention period is required or permitted by law. Your personal data associated with the conduct of the clinical trial and as contained in the clinical trial master file will be stored for a period of at least 25 years after completion of the clinical trial in accordance with Article 58 of the Clinical Trial Regulation 536/2014.
Your Rights
Your Privacy Choices
Where provided for under applicable law, you have specific rights regarding your personal data that we collect and process. In this section, we first describe those rights and then we explain how you can exercise them. Please note that applicable law may permit us to deny a request from you regarding the exercise of your privacy rights, in which case we will inform you of our reason for denying your request.
- The right to access – You have the right to request copies of your personal data or a description of the personal data categories we process or a description of the processing.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data that are based on legitimate interests, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The right related to automated decision making, to the extent automated decision making is occurring.
- The right to withdraw consent – Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. If you withdraw your consent, our use of your personal data before you withdraw it is still lawful.
- The right to lodge a complaint with a supervisory authority – Under local law you are entitled to lodge a complaint with your local data protection authority if you are not satisfied with how we process your personal data. Specifically, you can lodge a complaint in the Member State of the EU of your habitual residence (or UK where relevant), place of work, or the alleged violation of the GDPR.
How to Exercise Your Rights
To exercise any of your privacy rights or raise any other questions, please contact us by using any of the information in the “Contact Us” section below. In order to correctly respond to your privacy rights requests, we will need to confirm that you made the request. Consequently, we may require additional information to confirm your identity and process your request.
Contact Us
Trial Sponsor
Elion Therapeutics, Inc.
1 Lincoln Street
Suite 30-120
Boston MA 02111
USA
Email: [email protected]
Data Protection Officer
We have appointed VeraSafe as our Data Protection Officer. While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of personal data. VeraSafe’s contact details are:
VeraSafe
100 M Street S.E., Suite 600
Washington, D.C. 20003 USA
Email: [email protected]
Web: https://www.verasafe.com/about-verasafe/contact-us/
Toll-free: 1-888-376-1079
European Union Representative
We have appointed VeraSafe as our representative in the EU for data protection matters. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contact-data-protection-representative.
Alternatively, VeraSafe can be contacted at:
VeraSafe
Plaza de la Solidaridad 12, Floor 5
29006 Malaga
Spain
United Kingdom Representative
VeraSafe has also been appointed as our representative in the United Kingdom for data protection matters. To make an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
Changes to This Privacy Notice
We reserve the right, at any time, to modify, alter, or update this Notice, and any such modifications, alterations, or updates will be effective upon posting on our website.