Renalytix AI plc respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data, tell you about your privacy rights and how the law protects you. This Policy is intended to address the use of Personal Data in relation to our website and related communications, as opposed to specific treatment of patient information. If you are a patient seeking information regarding our privacy practices with respect to patients, please consult our HIPAA Notice of Privacy Practices, located here.

Under the EU’s General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. This Privacy Notice utilizes the GDPR’s definition of Personal Data.

1.0 Purpose of this Privacy Notice

• This Privacy Notice aims to give you information on how Renalytix AI plc collects and processes your Personal Data.

1.2 It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.

2.0 Contact details

2.1 Our full details are:

Full name of legal entity: Renalytix plc

Name of Data Privacy Manager (DPM): Salim Hamir

Email address: shamir@renalytix.com

Postal address: Finsgate, 5-7 Cranwood Street, London EC1V 9EE United Kingdom

Telephone number: +44 (0) 7748 960970

3.0 Changes to the Privacy Notice and your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

4.0 The data we collect about you

4.1 We collect, use, store and transfer different categories of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment card details, and payroll data.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or we have purchased from you. It also includes details of your shareholding or option holding, if you are a shareholder or option holder.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or intranet.
• Profile Data includes your username and password on our website, our intranet, purchases or orders made by you, or by us, your preferences, and feedback and survey responses.
• Usage Data includes information about how you use our website, intranet, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

4.2 We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from Personal Data but is combined with other data to the extent that the Aggregated Data may not be correlated with an identifiable natural person, and is thus not treated as Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. In the event that Aggregated Data may come to be associated with an identifiable person, we will treat such data as Personal Data and not as Aggregated Data.

4.3 Special Categories of Personal Data (these include details such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not normally collect any special categories of data nor do we collect any information about criminal convictions and offences other than for our employees or applicants for employment. However if we do need to process such data we will ask for your explicit consent to do so.

5.0 If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or employee benefits). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6.0 We use different methods to collect data from and about you including through:

6.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes Personal Data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a promotion or survey;
• give us some feedback;
• provide unsolicited information to us;
• apply for employment with us or when you become an employee.

6.2 Automated interactions. As you interact with our website or intranet, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies.

6.3 Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties and public sources as set out below:

• Technical Data from analytics providers such as Google; advertising networks and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, or from our registrars or nominated advisers.
• Identity and Contact Data from data brokers, aggregators or recruitment agencies.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
• Web based contact management software such as ‘Email Subscribers & Newsletters for WP’

7.0 How we use your Personal Data

7.1 We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

7.2 We may also use your Personal Data in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.

7.3 Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by utilizing links within the messages themselves.

8.0 Purposes for which we will use your Personal Data

8.1 We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

8.2 Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need additional details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

9.0 Marketing

9.1 We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:

• Promotional material from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
• You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have opted-in to receiving that marketing.
• Third-party marketing. We will get your express opt-in consent before we share your Personal Data with any company outside the Renalytix AI plc group for marketing purposes.
• Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
• Where you opt-out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty, product/service experience or other transactions.
• Cookies. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit aboutcookies.org or www.allaboutcookies.org.Note that if you choose not to utilize cookies, then certain website features may not work as intended.
• To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

10.0 Change of purpose

10.1 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

10.2 If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

10.3 Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11.0 Disclosures of your Personal Data

11.1 We may have to share your Personal Data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties: other companies or departments in the Renalytix AI plc group acting as processors or joint controllers and provide IT and system administration services and undertake leadership reporting
• External Third Parties: service providers acting as processors who provide IT and system administration services
• Other Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.
• Professional advisers: acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting and payroll services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

11.2 We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

12.0 International transfers

12.1 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.

12.2 Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
• Where we use certain service providers, we may use specific contractual clauses promulgated by the European Commission which give Personal Data adequate protection as determined by the European Commission.
• If we are required to transfer data to countries which may not comply with the safeguards laid out above, for example if you are an employee and the country is your main residence, we will ask for explicit consent after informing you of any potential risks.

13.0 Data security

13.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

13.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14.0 Data retention

14.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

14.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

14.3 In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

15.0 Your legal rights

15.1 Under certain circumstances, you have rights under data protection laws in relation to your Personal Data to request the following:

• access to your Personal Data.
• correction of your Personal Data.
• erasure of your Personal Data.
• object to processing of your Personal Data.
• restrict processing your Personal Data.
• transfer of your Personal Data.
• withdraw any consent that you have previously given.

15.2 If you wish to exercise any of the rights set out above, please contact us. You can also contact the Information Commissioner’s Office via https://ico.org.uk/ for information, advice or to make a complaint. If you are a resident of the European Union and have a complaint about our use or processing of your Personal Information, you have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

15.3 You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

16.0 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

17.0 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.