PRAXIS PRECISION MEDICINES INC.
PRIVACY POLICY

Last Updated: July 2026

This Privacy Policy (“Privacy Policy”) describes the data protection practices of Praxis Precision Medicines Inc. and any affiliates (collectively, “Praxis,” “we,” “our,” or “us”), including when you visit a Praxis website that links to this Privacy Policy, such as including, but not limited to, www.praxismedicines.com (our “Sites”), participate in one of our clinical research studies (the “Studies”), or otherwise provide personal information to Praxis. We refer to the Sites, Studies, and other services provided by Praxis together in this Privacy Policy collectively as the “Services.” Please note that our Sites, Studies, and other Services may provide privacy policies, informed consent forms, and other types of just-in-time notices that supplement this Privacy Policy and describe the processing of your personal information in relation to the Services.

This Privacy Policy does not apply to our processing of information about employees or job applicants. This Privacy Policy also does not apply to the processing of data by our clinical research organization (“CRO”) partners during the course of our Studies.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information. Praxis is not a healthcare provider and communications sent to our Site cannot replace the relationship you have with a physician or another healthcare practitioner.

We do not sell your personal information.

The date this Privacy Policy was last updated is listed above. This Privacy Policy may change from time to time, so please check it periodically for updates.

REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide additional disclosures relating to the processing of personal information in certain countries, regions, or states. Please refer to the disclosures below that may be applicable to you.

• European Economic Area, United Kingdom, or Switzerland. If you are based in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), please see our European Privacy Notice and Swiss Privacy Notice below.
• US State Residents. If you are a resident of California, Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Maryland, Indiana, Kentucky, Rhode Island, or another state with a comprehensive consumer privacy law, please see the “US State Privacy Rights” section below for additional rights that may be available to you.
• Washington State. If you are a Washington State resident, please see the “Washington Consumer Health Data” section below for important disclosures regarding the collection and use of your consumer health data under the Washington My Health My Data Act.
• Nevada. If you are a Nevada resident, please see the “Nevada Residents” section below for your rights under Nevada’s consumer health data privacy law.

INFORMED CONSENT

To participate in our Studies, you must first review and sign an informed consent and authorization form (“Informed Consent”) for the Study. By completing the form, you consent to the collection, use, and sharing of your information as described in this Privacy Policy and as outlined in the Informed Consent. To the extent anything in this Privacy Policy conflicts with the Informed Consent, the terms of the Informed Consent will control.

THE INFORMATION WE COLLECT AND THE SOURCES OF SUCH INFORMATION

We collect information about you when you voluntarily provide it to us, when you access the Site, participate in our Studies, and use our Services, or if other sources provide it to us, as further described below. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

1. Information You Provide to Us

We collect a variety of information that you provide directly to us. The specific types of information we collect will depend upon the Services you use, how you use the Sites or Services, and the information you choose to provide. The types of data we collect directly from you include, without limitation:

• Contact information, including first name, last name, date of birth, email address, postal address, or telephone number;
• Demographic information, including your gender, age, ethnic origin, and race;
• Physical and mental health history and information, such as your height, weight, heart rate, and BMI; current and previous physical and mental health diagnosis and testing; current and previous use of certain medications; certain family history; information about your pain; mobility, diet and exercise information; disability information; and health habits. This information may be collected through health questionnaires, logged through wearable devices, or by other means;
• Inquiry information, including information about your customer service and maintenance interactions with us; and/or
• Other information, if any, as described in the Informed Consent or any additional information that you choose to directly provide to us.

2. Information We Collect Through Automated Means

Our Sites

When you use our Sites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, error logs, and other similar information.

Our Studies

When you participate in our Studies, we may collect certain data about you automatically, including sensor information, technical data (e.g., information about your app usage, app version and installation ID, device identifier, and technical data about your device), and any other information described in the Informed Consent.

Location Information

When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and/or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user’s general location.

Our Use of Cookies and Similar Online Tools

To collect the information discussed in this section, we and our service providers use web server logs, cookies, tags, beacons, SDKs, tracking pixels, and other similar tracking technologies (collectively, “cookies”). For example, we use Google Analytics to collect information about the use of our Site, what pages you access, when they are accessed, and what other websites were accessed prior to using the Site. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page at https://tools.google.com/dlpage/gaoptout. To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of our Site.

3. Information We Collect From Social Media and Other Content Platforms

When you “like” or “follow” us on LinkedIn or other social media sites, as applicable, we may receive limited information that the platform makes available to us, which may include your name, email address, and any comments or content you post that relate to us. We may also receive information you choose to provide if you sign up for one of our promotions or submit information to us through social media sites. The data we receive is dependent upon an individual’s privacy settings with the network. We encourage you to review your privacy settings on third-party websites and networks, and adjust them as you see fit, before sharing information with us or through the social media platform.

4. Information We Receive From Other Sources

We work closely with third parties (including, but not limited to, third-party intermediaries such as vendors, physicians, medical professionals, research organizations, or pharmacies with whom we partner to provide you with the Services, as well as their respective health care service providers, sub-contractors in technical services, advertising networks, analytics providers, and search information providers). Such third parties will sometimes provide us with additional information about you.

SENSITIVE PERSONAL INFORMATION ON OUR SITES

Certain categories of personal information – including health information, genetic data, biometric data, and other information defined as “sensitive” or “special category” data under applicable law – receive heightened protection under the laws of various US states and other jurisdictions.

Our Sites are not designed to solicit sensitive personal information from general visitors. However, to the extent you voluntarily provide sensitive personal information to us through our Sites outside of a Study context, your voluntary and affirmative act of providing such information constitutes your consent to our collection and processing of that information as described in this Privacy Policy. You may withdraw your consent at any time by contacting us at the address below, though withdrawal will not affect the lawfulness of processing conducted prior to withdrawal.

Sensitive personal information collected in connection with our Studies is governed by the applicable Informed Consent, which controls to the extent of any conflict with this Privacy Policy. Study-related websites collect opt-in consent for the processing of sensitive information prior to collection.

HOW WE USE YOUR INFORMATION

In connection with providing the Services to you, we may use your information for our business purposes, including to:

• Carry out, improve, and manage the Services.
• Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.
• Carry out the Studies, including: (i) recruiting and enrolling you into a Study; (ii) conducting the Study; (iii) seeking authorization from regulatory agencies to apply for approval of the Study drug or other drug candidates and diagnostics; (iv) developing new tests, procedures, and commercial products; and (v) for any other uses described in the Informed Consent.
• Communicate with you about the Services, your use of the Services, or your inquiries related to the Services or Praxis and send you communications to meet your needs.
• Communicate with you about Praxis, inquiries related to the Praxis team, opportunities with the Praxis team or careers with Praxis, and respond to your communications.
• Ensure that content from our Services is presented in the most effective manner for you and for your computer or device, allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Services safe and secure.
• Measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.
• Help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Services.
• Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy.

Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device(s) (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We do not sell your personal information. We may share your information for our business purposes in the following ways:

• Affiliates and Subsidiaries. We may share information we collect within any Praxis member or group (i.e., our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.
• Service Providers. We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services to us, including billing, consulting, analytics, research, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services. These entities may also include health care organizations, pharmacies, and other third parties we use to support our business or in connection with the administration and support of the Services. These third parties are contractually obligated to maintain the confidentiality of your personal information and to comply with applicable data protection laws.
• Study Team. If you participate in a Study, we share your personal information with the study team that conducts the Study, as well as the organizations that support the study team.
• Institutional Review Boards. If you participate in a Study, we may share personal information with the ethics committee or institutional review board that approved the Study.
• Government and Regulatory Authorities. We may share personal information with government and regulatory authorities, as required by law, including the U.S. Department of Health and Human Services, the Food and Drug Administration, the European Medicines Agency, and other federal or state government agencies.
• Other Approved Study Researchers. If you participate in a Study and it is permitted by the Informed Consent, we may share personal information with certain third-party researchers who are approved to access limited information. The categories of approved study researchers, the type of information they may have access to, and the purposes for which they may use it will be described in the Informed Consent.
• Protection of Praxis and Others. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property, or personal safety of Praxis, its agents and affiliates, its users, and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
• Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
• Consent. We may also disclose your information in other ways you direct us to and when we have your consent.
• Aggregate/De-Identified Information. We reserve the right to share Aggregate/De-Identified Information at our discretion.
• Other. We may also use your data in other ways consistent with this Privacy Policy, as described in the Informed Consent, and as otherwise permitted or required by applicable laws.

AUTOMATED DECISION-MAKING AND PROFILING

We may use automated processing tools to analyze information collected through our Sites and Services, including to personalize content, improve the relevance of information we present, and support our research activities. Residents of certain US states (including Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, and Maryland) may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. To submit such a request, please contact us using the contact information in the “Contacting Us” section below.

YOUR MARKETING CHOICES

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding our Services by contacting us at [email protected] or at the address listed below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as permitted or required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

US STATE PRIVACY RIGHTS

Residents of certain US states have additional privacy rights with respect to their personal information under applicable state law. This section applies to residents of California, Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Maryland, Indiana, Kentucky, Rhode Island, and other states that have enacted comprehensive consumer privacy legislation. The specific rights available to you may vary depending on your state of residence.

Rights Available to You

Depending on your state of residence, you may have some or all of the following rights:

• Right to Know / Access: You may request to know what personal information we have collected about you, including the categories of personal information, the purposes for which it is processed, and the categories of third parties to whom it is disclosed.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions under applicable law.
• Right to Data Portability: You may request a copy of the personal information you have provided to us in a portable and, to the extent technically feasible, readily usable format.
• Right to Opt Out of Targeted Advertising: You may opt out of the processing of your personal information for purposes of targeted advertising (i.e., the display of advertisements to you based on personal information obtained or inferred from your activities across businesses or services). Note: we do not sell your personal information.
• Right to Opt Out of Profiling: You may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Opt In to Sensitive Data Processing: To the extent any applicable state law requires opt-in consent for the processing of sensitive personal information (including health, genetic, or biometric data), the consent mechanisms described in this Privacy Policy and in any applicable Informed Consent satisfy that requirement. For general website visitors who voluntarily provide sensitive personal information, your affirmative act of providing such information constitutes consent as described above.
• Right to Appeal: If we deny a rights request, you may appeal our decision by contacting us using the information in the “Contacting Us” section below. We will respond to your appeal within the timeframe required by applicable law.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Sale of Personal Information

We do not sell your personal information, and therefore we do not offer an opt-out of sale. We do not share your personal information with third parties for cross-context behavioral advertising in a manner that constitutes a “sale” under applicable law. If you believe a particular data practice may constitute a sale under the laws of your state, please contact us at [email protected].

How to Submit a Request

To exercise any of the rights described above, please contact us by email at [email protected]. We will respond to your request within the timeframe required by applicable law (generally 45 days, with an extension of up to an additional 45 days where reasonably necessary). We may need to verify your identity before processing your request. We will not charge a fee for processing your request unless it is excessive or unfounded.

NEVADA RESIDENTS – CONSUMER HEALTH DATA

This section applies to residents of Nevada and governs our collection and use of consumer health data as defined under Nevada’s Consumer Health Data Privacy Act (Senate Bill 370, effective March 31, 2024) (“Nevada CHDPA”).

Consumer Health Data We Collect

To the extent we collect consumer health data from Nevada residents through our Sites or Services (outside of HIPAA-governed activities), we collect the categories of health-related information described in the “Information You Provide to Us” section above, including physical and mental health information and related data.

Consent

Consistent with the Nevada CHDPA, we obtain your affirmative consent before collecting your consumer health data and, separately, before sharing your consumer health data with third parties. For Study participants, these consents are obtained through the applicable study-site consent process. For general website visitors who voluntarily provide consumer health data, your affirmative act of providing that information constitutes your consent to collection and, to the extent the information is shared as described in this Privacy Policy, your consent to sharing.

We do not sell consumer health data.

Your Rights Under the Nevada CHDPA

As a Nevada resident, you have the following rights with respect to your consumer health data:

• Right to confirm whether we are collecting, sharing, or selling your consumer health data (note: we do not sell);
• Right to receive a list of third parties with whom we have shared your consumer health data;
• Right to request deletion of your consumer health data;
• Right to withdraw your consent and request that we cease collecting or sharing your consumer health data.

How to Submit a Request

To exercise your rights under the Nevada CHDPA, please contact us at [email protected]. We will respond within the timeframe required by the Nevada CHDPA and may need to verify your identity before processing your request.

WASHINGTON STATE RESIDENTS – CONSUMER HEALTH DATA PRIVACY POLICY

Notice to Washington Residents: This section constitutes Praxis’s Consumer Health Data Privacy Policy for purposes of the Washington My Health My Data Act, RCW Chapter 19.373 (“MHMDA”), effective March 31, 2024.

Praxis is committed to protecting the consumer health data of Washington State residents. This section describes how we collect, use, and share consumer health data as defined under the MHMDA.

Categories of Consumer Health Data Collected

To the extent we collect consumer health data from Washington residents through our Sites or Services (outside of HIPAA-covered or MHMDA-exempt research activities), we may collect the following categories:

• Physical health conditions, diagnoses, and treatment information;
• Mental health conditions and treatment information;
• Medication use and history;
• Health-related biometric data (e.g., heart rate, BMI) collected through wearable devices or similar technology;
• Genetic data, where voluntarily provided;
• Other health-related information voluntarily provided by you through our Sites or Services.

Purposes for Collection

We collect consumer health data for the purposes described in the “How We Use Your Information” section of this Privacy Policy, including to: carry out and improve the Services; conduct and support our Studies; communicate with you; comply with legal obligations; and for any other purposes described in the Informed Consent or otherwise disclosed at the time of collection.

Sources of Consumer Health Data

We collect consumer health data directly from you (through forms, questionnaires, wearable devices, and communications), from our Studies, and from third parties such as physicians, medical professionals, research organizations, and other partners involved in the Services.

Categories of Third Parties With Whom Consumer Health Data Is Shared

We may share consumer health data with the following categories of third parties, as described in the “How We Share and Disclose Your Information” section of this Privacy Policy:

• Study teams, CRO partners, and other organizations supporting the conduct of our Studies;
• Institutional review boards and ethics committees;
• Government and regulatory authorities (e.g., FDA, HHS, EMA);
• Service providers performing functions on our behalf (e.g., data storage, analytics, IT security);
• Approved study researchers, as permitted by the Informed Consent;
• Successors in connection with business transfers or transactions.

Consent

Consistent with the MHMDA, we obtain your affirmative consent – a clear affirmative act – before collecting your consumer health data and, separately, before sharing your consumer health data with third parties. These consents are obtained: (i) through the study-site enrollment and consent process for Study participants; and (ii) through your voluntary and affirmative act of providing health information for general website visitors who provide consumer health data through our Sites outside of a Study context.

We do not sell consumer health data.

Your Rights Under the MHMDA

As a Washington State resident, you have the following rights with respect to your consumer health data under the MHMDA:

• Right to confirm whether Praxis is collecting, sharing, or selling your consumer health data (note: we do not sell);
• Right to withdraw your consent and request that we cease collecting and/or sharing your consumer health data;
• Right to request deletion of your consumer health data. We will respond to deletion requests within 45 days of receipt. If we need additional time (up to an additional 45 days), we will notify you and explain the reason.

How to Submit a Request

To exercise your MHMDA rights, please contact us at [email protected]. We may need to verify your identity before processing your request. We will not discriminate against you for exercising your rights.

Geofencing

Praxis does not implement geofences around healthcare facilities for the purpose of identifying or tracking individuals seeking healthcare services, collecting consumer health data, or delivering health-related notifications or advertisements.

SECURITY BREACH NOTIFICATION

In the event of a breach of security involving your personal information that triggers notification obligations under applicable federal or state law, we will notify affected individuals and the relevant authorities as required. Depending on the nature and scope of the breach, notification may also be provided to applicable state attorneys general, federal agencies (including the Federal Trade Commission, where applicable), and media outlets, as required by law. We will provide notice within the timeframes required by applicable law.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any unaffiliated third parties using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third-party mobile application, website, or service to which our Services may contain a link. The collection, use, and disclosure of your information will be subject to the privacy policies of those third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties prior to sharing any information with them.

HOW WE PROTECT YOUR INFORMATION

Praxis takes a variety of technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Sites or Services after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes.

CONTACTING US

Praxis is committed to resolving questions or concerns about your privacy and our collection or use of your information. If you have a specific question or concern about your privacy rights, you can contact us at:

Praxis Precision Medicines Inc.
99 High Street, 30th Floor
Boston, MA 02110
[email protected]

EUROPEAN PRIVACY NOTICE

(Applies to residents of the European Economic Area and the United Kingdom)

SCOPE

While we are based in the United States, our Services may be accessed by residents of the European Economic Area (“EEA”) and the United Kingdom (“UK”). This European Privacy Notice applies to our processing of personal data of residents of the EEA and the UK. Switzerland has its own separate data protection framework, described in the Swiss Privacy Notice below.

Praxis is the controller of the personal data we hold about you in connection with your use of the Services.

This European Privacy Notice does not apply to personal data processed by our CRO partners during our Studies. Such processing is governed by the privacy notices of our CRO partners.

PERSONAL DATA WE COLLECT AND HOW WE USE IT

We collect, use, and otherwise process personal data as set out in the “The Information We Collect” and “How We Use Your Information” sections of this Privacy Policy. If you choose not to provide such personal data, you may not be able to use the Sites, participate in the Studies, or otherwise engage in the Services.

LEGAL BASIS OF PROCESSING

We will generally use and process your information on the basis of your explicit consent, our legitimate interests or legal obligations, and for scientific research purposes or for reasons in the public interest in conducting clinical trials and performing valuable scientific and medical research pursuant to Articles 6 and 9 of the General Data Protection Regulation (“GDPR”) and/or the UK GDPR.

RETENTION OF YOUR PERSONAL DATA

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required by applicable law.

Legal Basis	Retention Period
Legitimate Interests	A reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.
Consent	The period of time necessary to fulfill the underlying agreement with you, subject to your right to erasure under applicable circumstances.
Contract	The duration of the contract plus a limited additional period necessary to comply with law or representing the applicable limitation period for legal claims.
Legal Obligation	The period of time necessary to fulfil the legal obligation.
Legal Claim / Hold	Until the hold is removed, which typically means the claim or threat of claim has been resolved.

DATA STORAGE AND INTERNATIONAL TRANSFERS

Your personal information may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including the United States. In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses (“SCCs”) adopted by the European Commission; or (iii) the transfer is to a US organization certified under the EU–US Data Privacy Framework (“EU-US DPF”), adopted by the European Commission on July 10, 2023. If you wish to enquire further about the safeguards used for international transfers, please contact us using the details set out at the end of this Notice.

YOUR PRIVACY RIGHTS (EEA AND UK)

You have the following rights with respect to the personal data that we hold:

• Right to access your personal data;
• Right to delete, or request deletion or erasure of, your personal data without delay if the continued processing of that personal information is not justified;
• Right to object to or restrict processing of your personal data;
• Right to request portability of your personal data;
• Right to object to automated decision-making;
• Right to correct or update your personal data that is inaccurate or incomplete.

Right to Withdraw Consent

Where we rely on your consent for processing of your personal data, you have the right to withdraw your consent at any time, subject to certain limitations at law. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to your withdrawal. To withdraw consent, please contact us at [email protected].

Submitting Requests

VeraSafe Ireland Ltd. is our designated representative in the European Union and United Kingdom. All communications, inquiries, or requests surrounding your information rights or complaints under GDPR may be addressed to VeraSafe with a copy to [email protected].

To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031.

If you are located within the United Kingdom, VeraSafe United Kingdom Ltd. can be contacted on matters related to the processing of personal data of UK data subjects:

VeraSafe United Kingdom Ltd. | 37 Albert Embankment | London SE1 7TL | United Kingdom

Contact form: https://verasafe.com/public-resources/contact-data-protection-representative | Tel: +44 (20) 4532 2003

Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are based in the UK, your local authority is the UK Information Commissioner’s Office at https://ico.org.uk/global/contact-us/.

SWISS PRIVACY NOTICE

(Applies to residents of Switzerland under the Swiss Federal Act on Data Protection)

SCOPE

Switzerland’s revised Federal Act on Data Protection (“nFADP”) entered into force on September 1, 2023, and is distinct from the EU GDPR. This Swiss Privacy Notice applies to our processing of personal data of natural persons residing in Switzerland. Praxis is the controller of personal data we hold about you in connection with your use of our Services.

This Swiss Privacy Notice does not apply to personal data processed by our CRO partners during our Studies. Such processing is governed by the privacy notices of our CRO partners.

PERSONAL DATA WE COLLECT AND HOW WE USE IT

We collect, use, and otherwise process personal data as described in the “Information We Collect” and “How We Use Your Information” sections of this Privacy Policy. Under the nFADP, certain categories of personal data are classified as sensitive, including health data, genetic data, biometric data used to identify a natural person, and data on administrative or criminal proceedings and sanctions. We take appropriate technical and organizational measures to protect such data.

LEGAL BASIS OF PROCESSING

We process your personal data based on your consent, our legitimate interests, contractual necessity, or legal obligation, consistent with the nFADP. Where we rely on consent, we obtain it in a manner consistent with the nFADP’s requirements.

DATA PROTECTION IMPACT ASSESSMENTS

Where our processing activities are likely to result in a high risk to the personality or fundamental rights of data subjects, we carry out a Data Protection Impact Assessment (DPIA) as required by the nFADP prior to commencing such processing.

SECURITY BREACH NOTIFICATION

In the event of a data security breach that is likely to result in a high risk to the personality or fundamental rights of data subjects, we will notify the Swiss Federal Data Protection and Information Commissioner (FDPIC) as required by the nFADP.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred from Switzerland to the United States and other countries. Such transfers are made: (i) pursuant to Swiss standard contractual clauses or EU SCCs as recognized under the nFADP; or (ii) to US organizations certified under the Swiss–US Data Privacy Framework (“Swiss-US DPF”), which became effective on September 15, 2024, as a recognized transfer mechanism under the nFADP. If you wish to enquire further about the safeguards used for international transfers from Switzerland, please contact us using the details below.

YOUR PRIVACY RIGHTS (SWITZERLAND)

As a data subject under the nFADP, you have the following rights:

• Right to information about the personal data we hold about you;
• Right to request correction of inaccurate personal data;
• Right to request deletion or restriction of processing of your personal data;
• Right to data portability;
• Right to object to certain processing activities.

To exercise these rights, please contact us at [email protected].

RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC). Contact information for the FDPIC is available at: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html.

CONTACTING US (EUROPEAN AND SWISS MATTERS)

Praxis Precision Medicines Inc.
99 High Street, 30th Floor
Boston, MA 02110
[email protected]

EU/UK Representative: VeraSafe Ireland Ltd. – contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative