Last Updated: June 5, 2026

Ethyreal Bio, Inc. (“Ethyreal,” “Company,” “we,” “us,” or “our”) recognizes and respects the privacy rights of individuals regarding their personal data and is committed to complying with all applicable data privacy laws. This Privacy Statement explains what types of personal data we may collect from you; how and why that data is collected, used, processed and protected; as well as how to exercise any privacy rights you may have with respect to the management of your personal data.

This Privacy Statement applies to personal data we collect about you through our interactions with you, including when you visit our website(s) or other digital properties, participate in our clinical trials, interact with our digital resources, or otherwise engage with us.

We may update this Privacy Statement from time to time. Please check this Statement periodically for any changes. When we materially update our Privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.

Ethyreal may collect, use, store, process and/or share the following categories of personal data:

Identity Data: Including, for example, name, marital status, title, social security or similar national identification number, date of birth, and gender.

Contact Data: Including, for example, physical address, billing address, email address, telephone number(s) and social media account identifiers.

Financial Data: Including, for example, household income, bank account, payment card details, insurance information, and payroll data.

Transaction Data: Including, for example, details related to payments and other details regarding services you have received or requested from Ethyreal.

Technical Data: Including, for example, internet protocol (IP) address, login data, browser type and version, time zone and location settings, location, browser plug-in types and versions, operating system, platform, device identifiers, mobile advertising identifiers, and other technology on the devices you use to access Ethyreal’s website(s) or digital properties.

Profile Data: Including, for example, your username and password to access any authenticated area of our website(s), your preferences, and feedback and survey responses.

Usage Data: Including, for example, information about how you use our website, products, and services, including pages visited, searches performed, and links clicked.

Marketing and Communications Data: Including, for example, your preferences in receiving materials regarding our products and services, communications from Ethyreal and our third parties, and your communication preferences.

Professional Data: Including, for example, information about healthcare professionals such as medical specialty, National Provider Identifier (NPI), institutional affiliations, prescribing history, and professional credentials.

Employment Data: Including, for example, information contained in CVs, cover letters, resumes, references, and other employment-related documentation.

Special Categories of Personal Data: Including information that most people may consider sensitive, for example, details about your race, ethnicity or citizenship status, sexual orientation, information about your physical health, mental health, physiological, genetic, and biometric data. We collect such information chiefly in connection with our clinical trials and research programs focused on medicines and interventions for Graves’ Disease and Thyroid Eye Disease and in connection with some of our services and products in those regards.

Information That You Provide to Us Directly and Voluntarily

You may choose to interact with us directly by completing forms or corresponding with us by electronic or written means, or by speaking to us over the phone or in person. For example:

Information That We Collect Automatically

When you visit and interact with our website(s) or digital properties, we may collect certain information automatically from you and about you, such as Technical Data, which may include information from your device like your IP address, device type, unique device identification numbers, browser-type, preference settings, broad geographic location (e.g., country or city-level location), and other technical information.

Some of this information is collected using cookies and similar tracking technologies. Collecting some of this information may enable us to better understand the visitors who come to our website(s) or properties, where they come from, and what content on our website(s) is of interest to them. We may use this information for our internal analytics and marketing purposes, to improve the quality and relevance of our website(s) or digital properties to our visitors, to track and respond to concerns, and to comply with regulatory monitoring and reporting obligations.

You can find more information about our use of cookies and other tracking technologies in our “Cookies and Other Tracking Technologies” section below.

Information We Receive from Third Parties or Publicly Available Sources

We may receive categories of personal data about you from various third parties and public sources, such as:

Ethyreal and/or our affiliates or service providers may use your personal data for various relevant purposes including, for example, to:

Ethyreal strives to provide you with choices regarding certain uses of personal data, particularly around communications related to Ethyreal, our products and services.

We may use your Identity Data, Contact Data, Technical Data, Usage Data, 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 services and materials may be relevant for you.

We have established the following personal data control mechanisms:

Opting In. You will receive certain communications from us if you have requested information from us and opted-in to receive such communications.

Consent to Third-Party Marketing. We will not share your personal data for marketing purposes with any company outside of Ethyreal and its service provider network unless you provide your express opt-in consent to do so.

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. Remember, however, that even if you opt-out of receiving these marketing communications, Ethyreal will still communicate with you to provide an offering that you request.

Online Analytics. Ethyreal may use third-party industry-recognized web analytics services (such as, for example, Google Analytics) on our website(s) to collect and analyze the information discussed in this Statement, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies will be disclosed to or collected directly by these service providers, who evaluate information, including by noting the third-party website(s) from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by visiting http://tools.google.com/dlpage/gaoptout.

We do not sell your personal data. However, we may share your personal data for targeted advertising purposes as described in this Privacy Statement and in our jurisdiction-specific notices below.

We may share your personal data with the following categories of parties for the purposes described in this Statement:

Internal and Affiliated Parties: Individuals or groups within our Company or within our family of companies, like subsidiaries, parents, or related corporate entities.

Partners: Entities, service providers, consultancies, or academic institutions with whom we have formalized professional relationships.

External Third Parties: Entities or individuals whose services we have formally retained to perform services on our behalf and help further our business requirements, including without limitation, for professional services, research, communications, technological maintenance, data storage, system administration, and data analysis and processing.

Clinical Research Organizations and Trial Sites: Contract Research Organizations (“CROs”), clinical trial sites, or other service partners who assist in conducting and managing clinical trials that we sponsor or engage with.

Healthcare Providers and Healthcare Professionals: We may share your personal data with healthcare providers and healthcare professionals in connection with our patient support programs, clinical trials, and other healthcare-related activities.

Third-Party Advertising Partners: Where applicable, to improve the effectiveness of our communication with you and our marketing campaigns, we may share your personal data with our third-party advertising partners, including social media platforms and publishers.

Parties as Part of a Business Transaction: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 Statement.

Government Authorities: Government agencies, regulators, and authorities as may be advisable under or required by 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.

Ethyreal will only collect, process, and use the personal data described above where applicable laws allow us to do so. That means, we will do so only when we have your consent and/or when we have a legitimate business interest to do so. In some instances, we may also have a legal or regulatory obligation to collect personal information from you, such as if there is a requirement to report an adverse event related to our products.

We may process your personal data based upon more than one lawful basis and legitimate interest depending upon the specific purpose(s) for which we are using the personal data. Ethyreal’s primary legitimate interests include the research, development, and advancing targeted therapies for autoimmune conditions.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How To Contact Us” section of this Statement.

Ethyreal may use new tools and technologies, including artificial intelligence (AI), in connection with our products, services and operations. Where personal data is processed by these technologies, such processing is limited to the purposes described in this Privacy Statement and/or any supplemental privacy notices provided at the time of data collection.

Ethyreal will not use AI or other automated technologies to make decisions that may produce legal or similarly significant effects concerning you, except in limited circumstances where:

We deploy reasonable technical, organizational, administrative and physical security measures to prevent your personal data from being accidentally lost, impermissibly altered, disclosed, used, or accessed in an unauthorized way while it is under our control. We purposefully limit access to your personal data to those employees, agents, designees, and other third parties who have a business need to do so. Those parties are instructed to only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have implemented reasonable procedures to guard against and address data breaches. In the unlikely event of a breach implicating your personal data that requires notification, we will do so and fulfill all our related legal obligations.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us using the contact information provided in the “How to Contact Us” section.

Ethyreal may automatically collect some personal data when you visit and engage with our website(s) or digital properties using cookies, beacons, server logs and/or other tracking technologies.

Cookies are small files that are automatically stored on your computer when you visit a website. Cookies are generally used to: (a) recognize your device; (b) store your preferences and settings; (c) understand the web pages of the website you have visited; (d) perform searches and analytics; and (e) assist with security functions. Cookies may perform many functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience.

Beacons (also known as “tracking pixels” or “pixel tags”) are small strings of code that are placed in websites, email messages, and/or online ads. Beacons are most often used in conjunction with cookies to track activity on websites. Since beacons are typically used in combination with cookies, if you disable cookies, the beacons will only detect an anonymous website visit..

Web Server Logs are documents that contain a record of activity related to a specific we server over a defined period of time. Such documents contained detailed information which may include IP addresses, i.e. the number assigned to your device whenever you access a network. We may collect IP addresses to conduct system administration and report aggregate information to affiliates, business partners, and/or service providers to conduct website and application analysis and performance reviews.

Ethyreal’s uses of such technologies fall into the following general categories:

Advertising or Targeting Related: Technologies used to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.

Managing Your Cookie Preferences: If you do not wish to have cookies on your system, you can set your browser preferences to refuse them or to alert you when cookies are being sent. You are able to change our setting to notify you when a cookie is being placed or to block cookies altogether. For additional information, consult your browser’s “Help” section because controls and settings vary by browser. If you choose to decline all cookies, you may not be able to fully experience all the features intended for use of our website(s).

Do Not Track: Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Websites linked to this Privacy Statement do not currently respond to these “do-not-track” signals.

Global Privacy Control: Websites linked to this Privacy Statement will recognize and honor the Global Privacy Control and similar browser-based opt-out preference signals, as may be required by applicable law.

Ethyreal will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

Ethyreal acts in conformity with its internal retention practices . To determine the appropriate retention period for certain personal data, we consider various factors including: the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the nature and status of your relationship with us; the purposes for which we process your personal data and whether we can achieve those purposes through other means and any applicable legal requirements.

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 such circumstances, we may use this anonymized information indefinitely without further notice to you.

Your personal data may be stored and processed in any location where we have facilities or service providers. By the use of our services or by providing consent to us (where required by law), your information may be transferred to other locations.

For transfers to locations not deemed adequate by a relevant supervisory authority, we have ensured that appropriate measures are in place to protect your personal data, including by ensuring that the recipient is bound specified obligations, like for example, published Standard Contractual Clauses, if relevant and applicable to regions where you or your personal data is located.

Ethyreal may have additional privacy statements or notices that are directed to the specific context in which your personal data is collected. For example, applicants for employment may be provided with a separate privacy statement or notice.

If you receive a privacy statement or data privacy-related notice provided to you for a specific purpose, the terms of that more specific statement or notice will control to the extent that other statements or notices may differ from this Privacy Statement.

Ethyreal website(s) or digital properties may contain links to other sites that we believe may be of interest to visitors. When you click on one of these links, you will be transferred away from a Ethyreal property and be connected to the site of the organization or company that you selected. At such point, this Privacy Statement will not apply to your activity on the non-Ethyreal website(s) because each of these linked sites maintains its own independent privacy statements and practices.

The inclusion of any such third party link on Ethyreal website(s) or digital properties does not imply our endorsement of the linked site or service. Ethyreal is not responsible for content that exists on third-party websites. Ethyreal does not control the use of cookies or other tracking technologies by any such third-party websites.

Ethyreal does not intend for our website(s) or online services to be used by anyone under the age of 18 and we do not design any website features to be intentionally appealing to a minor audience. In some limited instances, we may collect personal data about children in connection with our clinical trials or other programs, but we will do so only with the proper consent of a parent or guardian and in compliance with applicable laws.

We do not otherwise knowingly collect or solicit data about or from minors and children under the age of 13 on our website or digital properties without the express consent of a parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with personal data without proper adult consent, he or she should contact us as described in the “How to Contact Us” section of this Statement. In such an event, we will take reasonable steps to delete such data.

In accordance with certain laws which may be dependent upon your state of residency and other factors, you may have certain rights including, for example, the right to:

If you would like to inquire about and exercise any of these rights, please contact us as set forth in the “How to Contact Us” section. We will process such requests in accordance with applicable laws. To protect your privacy and as permitted by applicable law, Ethyreal may take steps to verify your identity before processing or fulfilling certain requests.

You have the right to be free from unlawful discrimination for exercising your rights.

California’s Shine the Light Law (California Civil Code Section 1798.83) permits California residents who are individual customers to request certain information regarding disclosure of “personal information” to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes without your consent.

Section 603A of the Nevada Revised Statutes permits certain Nevada residents who are “consumers” to submit a request at any time to an “operator” of a website in Nevada directing the operator not to make any sale of any “covered information” the operator has collected or will collect about the consumer. Ethyreal does not currently “sell” or plan to sell covered information as defined in the Nevada law.

If you are a Nevada resident, you may submit a verified request by contacting us using the information provided in the “How to Contact Us” section of this Statement.

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If you are resident within the European Union (“EU”), European Economic Area, or United Kingdom, please read this section carefully as it supplements the other provisions of this Privacy Statement.

The Legal Basis for Processing Your Personal Data

We will use your personal data only when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

Generally, you will have the right to withdraw your consent at any time by contacting us using the contact information listed in the “How to Contact Us” section above.

Purposes of Processing and Legal Basis

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we need to use it for another reason and that reason is compatible with the original purpose. 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.

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.

Clinical Trials

To the extent that Ethyreal may undertake clinical trial studies within the EEA or UK, we may also use information from clinical trial participants’ medical records and other health data in order to conduct clinical or scientific research to improve healthcare.

Ethyreal may contract with specialized service providers, such as Contract Research Organizations (“CROs”), clinical trial sites, or other service partners, typically as data processors, to collect the personal data of the participants of the clinical trial and to manage the clinical trials that we sponsor. We may then process key-coded or pseudonymized personal data of clinical trial participants, which means that we do not have direct or immediate access to their identifiable personal data (except, for example, to comply with legal requirements such as those related to our pharmacovigilance obligations).

We would have a legitimate interest in using information related to your health for research studies when you agree to take part in a research study by providing your informed consent to participate. Our exception to the general provision at Article 9(1) of the GDPR not to process special categories of data is that processing is necessary for scientific research purposes in accordance with Article 89 of the GDPR.

This means that we will use your personal data collected in the course of a research study when we act as the data controller for such studies in the ways needed to conduct and analyze the research study. Your rights to access, change, or move your personal data may be limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the information about you that we have already obtained. To safeguard your rights, we will use only the minimum personal data needed for these purposes.

In addition, the personal data of potential and actual site investigators, employees, or contractors may also be collected directly by Ethyreal or through the CRO that we may work with and is typically used, for example, to verify the individual’s qualifications, satisfy documentation requirements for the purpose of the clinical trial, verify financial disclosures to avoid any conflict of interest, and to otherwise conduct and analyze the research study.

International Transfers of Personal Data

Ethyreal is based outside the EEA and the UK, so the processing of your personal data may involve a transfer of data outside the EEA or the UK.

Whenever we transfer your personal data out of the EEA or UK, we ensure an adequate and similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

You may obtain a copy of the Standard Contractual Clauses or other transfer mechanisms by contacting us in accordance with the “How to Contact Us” section of this Statement.

Your Data Protection Rights Under GDPR

Under certain circumstances, individuals located in the EEA or UK have the following data protection rights:

To exercise any of the rights described above, please send a message to info@ethyrealbio.com. Please be aware that your rights in relation to clinical research data may be limited.

Supervisory Authority

For advice or to make a complaint, you can also contact the applicable Supervisory Authority within the EEA at https://edpb.europa.eu/about-edpb/board/members_en or the Information Commissioner’s Office within the UK at https://ico.org.uk/make-a-complaint/.

Fees and Response Time

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 or refuse to comply with your request if it is clearly unfounded, repetitive, or excessive.

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 try to respond to all legitimate requests in a timely fashion and as may be required by applicable law. Occasionally, it may take us longer than usual 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.

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For questions about this Privacy Statement or to exercise your privacy rights, please contact us at:

Ethyreal Bio, Inc. 700 Technology Square, FLR3, Cambridge, MA 02139

Email: info@ethyrealbio.com