Privacy

This privacy policy describes how Tevogen Bio, Inc., located at 15 Independence Boulevard, Warren, NJ, USA (“Tevogen,” “we,” “our,” “us”) collects and processes personal data about you through our interactions with you, such as through our website, https://www.tevogen.com/, when you communicate with us, and all other Tevogen websites or media that link to this policy(the “Services”).This policy explains how we use, store, transfer, and protect personal data, and your right you may have in relation to personal data.

Personal data is information about you through which you can be identified (including where you can be identified by combining the information with other information).

This policy will inform you of:

• Personal data we collect and use;
• How we use your personal data and the basis on which we use it;
• Who has access to your personal data;
• How to exercise your rights;
• How your personal data is protected and stored;
• International transfer of your data;
• How to contact us; and
• Changes to the privacy policy.

1. PERSONAL DATA WE COLLECT AND USE

When you use the Services (including visiting our websites), Tevogen collects and uses certain personal data about you. We collect personal data about you from a variety of sources, including from you directly (e.g., when you contact us by email or request information through our website), data we generate about you in the course of our relationship with you (e.g., data collected from cookies and other similar technologies as described below), and data we collect about you from other sources, including commercially available sources, such as public databases or social media platforms (where permitted by law).

Note that we may be required by law to collect certain personal data about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

1.1 Personal data we collect directly from you

The categories of personal data that we collect directly from you include the following:

1. Personal details (e.g., name, IP address);
2. Contact details (e.g., phone number, email address, postal address);
3. Account details (e.g., username);
4. Transaction details (e.g., when you invest with us);
5. Communications (e.g., when you contact us with a question, comment, or request);
6. Information about your preferences (e.g., those related to your connection to Tevogen or the industry).

1.2 Personal data generated by us

In addition, we may generate the following categories of personal data about you in the context of your use of the Services:

1. Records of our interactions with you; and
2. Internal notes, including notes about your inquiry into our corporate presentation, product development, and other services.

1.3 Personal data we automatically collect about your use of the Services

The following are examples of other categories of data that we automatically collect from you over time and across different websites when you use the Services, including through the use of “cookies”, which are small text files that the Services save on your computer using your web browser and access when you return:

1. Technical data collected from your computer or mobile device (e.g., your IP address, browser type, operating system);
2. Information about your usage of our Services (e.g., the pages you visit when using the Services, the search terms you enter on the Services, how often you use the Services, and the pages you access before and after accessing the Services); and
3. Data that we generate about you as a result of your use of the Services (e.g., our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services).

For more information about cookies and how we use them on our website, please refer to our Cookies Policy.

1.4 Personal data we obtain from other sources

The following are examples of the categories of personal data we collect from other sources, such as your employer or investment group and social media platforms, including without limitation YouTube, Google, LinkedIn, and X (formerly Twitter):

1. Personal details (e.g., name, date of birth);
2. Contact details (e.g., phone number, email address, postal address); and
3. Details about advertising preferences (e.g., products purchased or interaction with advertisements online).

2. HOW WE USE YOUR PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We use your personal data for the following purposes:

• Identification and authentication: We use your identification information to verify your identity when you access and use our Services and to ensure the security of your personal data. This is so we can comply with our contractual obligations to you.
• Operating the Services: We process your personal data to provide the Services you have requested. This is so we can comply with our contractual obligations to you.
• Improving our Services: We analyze information about how you use our Services to provide an improved experience for our investors and other users, including via site analytics. It is in our legitimate business interests to use the data provided to us for this purpose, so we can understand any issues with our Services and improve them.
• Communicating with you: We use your personal data when we communicate with you, for example, if we are providing information about changes to the terms and conditions; if you request a copy of our corporate presentation; if you contact us with questions throughout our products or research; or for sending you Tevogen newsletters and publications. It is in our legitimate interests that we are able to provide you with appropriate responses and information about our Services. Where required by law we will obtain your consent before sending you marketing communications.
• Marketing: We use your personal data to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you.  It is in our legitimate interest to provide more relevant and interesting advertising messages. Where necessary, we will obtain your consent before sending such marketing messages.
• Exercising our rights: We use your personal data to exercise our legal rights where it is necessary to do so, for example, to detect, prevent and respond to claims of fraud, intellectual property infringement claims or violations of law or our standards of conduct, company policies, or our terms of use.
• Complying with our obligations: We process your personal data to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, as required by law.
• Customizing your experience: We use your personal data to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. It is in our legitimate interests to provide you with a customized experience.
• For purposes of planning and development. This processing is necessary to serve our legitimate interests in the efficient management and administration of our business development activities and product development and research.
• Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration.

We may also anonymize your personal data in such a way that you may not reasonably be re-identified by us or any other party, and we may use this anonymized information for any purpose.

3. WHO HAS ACCESS TO YOUR DATA

We share your personal data under the following circumstances:

• Service providers and business partners: We share your personal data with our service providers and business partners that perform business operations for us for the purposes set forth above. For example, we partner with companies to send newsletters and marketing messages, support email and messaging services, secure our website, and analyze information. These service providers and business partners include advertising agencies and fraud prevention agencies that will use your personal data only in the ways described in this policy.
• Within Tevogen: We share personal data within Tevogen, including in the US and elsewhere for the purposes set out above. To the extent we collect information in-person in Europe, we may share personal data about you with other Tevogen personnel located at our facilities in the United States or elsewhere.
• Law enforcement agencies, courts, regulators, government authorities or other third parties. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

4. HOW TO EXERCISE YOUR RIGHTS

Where applicable under local law, you may have the following rights regarding your personal data: the right to access personal data Tevogen holds, and in some situations, the right to have that personal data corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how Tevogen uses your personal data if the legal basis for processing that information is our legitimate interest.

Where you have provided consent and where applicable under local law, you have the right to withdraw any consent you have given at any time. You also have the right to register a complaint to the appropriate data protection authority, where applicable.

Please note that we may require additional information from you in order to honor your requests.

If you wish to exercise these rights, notify us to update your personal data, or ask questions about the this policy, please contact us at privacy@tevogen.com.

We do not currently respond to web browser “do not track” signals. For more information about these signals, visit www.allaboutdnt.org.

5. HOW YOUR PERSONAL DATA IS PROTECTED AND STORED

We implement technical and organizational measures designed to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity, availability, and confidentiality of personal data.

We will retain your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to:

• Maintain our records (including investment records, if applicable);
• Comply with record retentions requirements under applicable law;
• Defend or bring any existing or potential legal claims; or
• Resolve or otherwise address any complaints or queries relating to our Services.

We will delete your personal data when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the data.

6. INTERNATIONAL TRANSFER OF YOUR DATA

Tevogen is based in, and operates out of, the United States. As a result, your personal data may be transferred to, and stored and processed in, a country (such as the United States) that may not be regarded as ensuring an adequate level of protection for personal data under the laws of your country.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.  

7. HOW TO CONTACT US

If you have questions or concerns regarding the way in which your personal data has been used, please contact us at privacy@tevogen.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right (where applicable) to make a complaint to the appropriate data protection authority. Contact information for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

8. CHANGES TO THE PRIVACY POLICY

You may request a copy of this privacy policy from us using the contact details set out above. We may modify or update this privacy policy from time to time.

If we change this privacy policy, the current version will be published on our website. Where changes to this policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).