Consumer Health Data Privacy Policy
Effective Date: August 21, 2026
Perfero Pharma, Inc. (“Company,” “we,” “us,” or “our”) is committed to protecting the privacy of your consumer health data. This policy (“Consumer Health Data Policy”) applies to consumer health data that we collect from or about you if you are a Nevada consumer, as defined under Nevada law (Nevada Revised Statutes Chapter 603A) (the “Nevada Consumer Health Data Act”), or a Washington consumer, as defined under Washington law (Revised Code of Washington Chapter 19.373) (the “Washington My Health My Data Act,” and together with the Nevada Consumer Health Data Act, the “State Health Data Laws”).
This Consumer Health Data Policy does not apply to information we collect that is exempt from the Nevada Consumer Health Data Act or the Washington My Health My Data Act, which is governed by our general Privacy Policy (the “Site”).
For purposes of this Consumer Health Data Policy, “consumer” means a natural person who has requested a product or service from the Company and who resides in Nevada or whose consumer health data is collected in Nevada, or a natural person who resides in Washington or whose consumer health data is collected in Washington. The term does not include a natural person acting in an employment context or as an agent of a governmental entity.
1. Categories of Consumer Health Data We Collect
Information You Provide Directly
We may collect the following categories of consumer health data through our adverse reaction hotline or when you make a medical inquiry:
- Information relating to any health condition or status, disease or diagnosis, including adverse reactions or side effects that you report in connection with the use of a Perfero Pharma product
- Information relating to bodily functions, vital signs or symptoms
- Information relating to the use or acquisition of medication, including the specific Perfero Pharma product(s) involved
- Information relating to social, psychological, behavioral or medical interventions
- Information relating to surgeries or other health-related procedures
2. Categories of Sources from Which Consumer Health Data Is Collected
We collect consumer health data from the following categories of sources:
- Directly from you, when you contact our adverse reaction hotline or otherwise report a side effect, adverse reaction or product complaint
- Your authorized or legal representatives, family members and caregivers
- From health care providers, pharmacies, insurance companies, or other third parties, where you have directed them to share information with us or where such sharing is required or authorized by law
3. How Consumer Health Data Will Be Used
Consumer health data collected through our adverse reaction hotline is received by trained personnel and processed for the purposes described in Section 6. Access to consumer health data is limited to employees, contractors and agents who need access to perform services on our behalf, and each such person is subject to a duty of confidentiality. We maintain administrative, technical and physical safeguards designed to protect consumer health data from unauthorized access, use or disclosure.
4. Categories of Consumer Health Data We Share
We may share the following categories of consumer health data:
- Information relating to any health condition or status, disease or diagnosis, including adverse reactions or side effects that you report in connection with the use of a Perfero Pharma product
- Information relating to bodily functions, vital signs or symptoms
- Information relating to the use or acquisition of medication, including the specific Perfero Pharma product(s) involved
- Information relating to social, psychological, behavioral or medical interventions
- Information relating to surgeries or other health-related procedures
5. Categories of Third Parties and Affiliates with Whom We Share Consumer Health Data
We may share consumer health data with the following categories of third parties and affiliates:
- Regulators and government authorities, where required by law (for example, the U.S. Food and Drug Administration for adverse event reporting)
- Professional advisors, such as legal, tax and accounting firms
- A successor entity in connection with a merger, financing or sale of assets
- Service providers who perform functions on our behalf (such as hosting, data storage and pharmacovigilance case processing), under contractual obligations consistent with the Nevada Consumer Health Data Act and Washington’s My Health My Data Act. Each such service provider processes consumer health data only pursuant to a written contract that sets forth applicable processing instructions and the specific actions the service provider is authorized to take with regard to consumer health data, and that is consistent with this Consumer Health Data Policy
- Professional advisors, such as legal counsel, in connection with legal compliance or proceedings
- Your authorized or legal representatives, family members and caregivers
- Health care providers, pharmacies, insurance companies, or other third parties, where you have directed us to share information with them or where such sharing is required or authorized by law
- Our product manufacturing partners and licensors
- Prospective acquirers, investors and their professional advisors in connection with due diligence for potential mergers, acquisitions, financings or other corporate transactions, subject to appropriate confidentiality obligations
We do not sell consumer health data. We do not share consumer health data for advertising or marketing purposes.
6. Purposes of Collecting, Using and Sharing Consumer Health Data
The purposes for which we collect, use and share consumer health data are:
- To receive, process, and respond to reports of adverse reactions, side effects and product complaints
- To provide information about our products and to make our products available to you
- To manage our relationship with you, including customer service or to respond to your inquiries about our products
- To comply with legal, regulatory and safety obligations, including pharmacovigilance and adverse event reporting requirements under applicable law (for example, reporting to the U.S. Food and Drug Administration)
- To verify or maintain the quality or safety of our products (including those that are licensed, owned or manufactured by or for us)
- For internal advertising or marketing purposes only, including to measure the effectiveness of our advertising and marketing efforts
- To respond to and follow up on your adverse reaction or product complaint reports
- To conduct internal research to develop, improve or assess the safety of our products
- To communicate any of the foregoing to our product manufacturing partners and licensors
- To comply with our legal obligations, including to respond to subpoenas, orders or other legal process
7. Your Rights Regarding Consumer Health Data
Under the State Health Data laws, Washington and Nevada consumers have the right to:
- Confirm whether we are collecting, sharing or selling your consumer health data
- Obtain a list of all third parties and affiliates with whom we have shared or sold your consumer health data, together with an active email address or other online mechanism you may use to contact those third parties
- Request that we cease collecting, sharing or selling your consumer health data
- Request that we delete your consumer health data
- Withdraw your consent to the collection or sharing of your consumer health data at any time, subject to certain exemptions (See further Section 10 below)
Please note that we may be unable to delete consumer health data that we are legally required to retain under applicable pharmacovigilance or adverse event reporting laws, notwithstanding your deletion request. In such cases, we will inform you of the applicable legal basis for retention. If your consumer health data is stored on archived or backup systems, our response to your deletion request may be delayed to enable restoration of those systems, but such delay will not exceed six months from the date we authenticate your request.
8. How to Submit a Request
To exercise any of the rights described above, you may contact us by:
- Email: privacy@perfero.com
- Phone: (973) 629-0109, x547
- Mail: Perfero Pharma, Inc., Attn: Legal Department, 3 Becker Farm Road, Suite 404, Roseland, New Jersey 07068
We may require additional information to authenticate your request. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to verify your identity.
We will respond to deletion requests within 30 days from when we receive your request and will respond to other requests within 45 days. In some circumstances, we may need additional time to process your request. If we expect your request is going to take us longer than normal to fulfill, we will let you know, together with the reason for the extension.
9. Appeal Process
If your request is denied, you may appeal that decision as specified in our letter of denial. We will process and respond to your appeal within the time permitted by the State Health Data Laws, including, for Washington consumers, within 45 days of receipt of the appeal. If we deny your appeal, we will provide you with an online mechanism or other method through which you may contact the Washington Attorney General to submit a complaint.
10. Consent
Where required by law, we will obtain your consent before (i) collecting your consumer health data and/or (ii) sharing your consumer health data with a third party. Consent to share your consumer health data is separate and distinct from, and will be obtained independently of, any consent to collect your consumer health data.
You may withdraw your consent at any time by contacting us using the information provided in Section 8. Withdrawal of consent will not affect the lawfulness of any processing conducted prior to your withdrawal or any processing conducted on a basis other than consent (for example, processing required by law).
11. Third-Party Collection of Consumer Health Data
We do not permit third parties to collect consumer health data over time and across different websites or online services when you use the Site. Consistent with the Nevada Consumer Health Data Act and Washington’s My Health My Data Act, we do not implement a geofence within 2,000 feet of any medical facility, facility for the dependent, or any other person or entity that provides in-person health care services or products, for the purpose of (i) identifying or tracking consumers seeking health care services or products, (ii) collecting consumer health data, or (iii) sending notifications, messages or advertisements to consumers related to their consumer health data or health care services or products.
12. Data Security
We maintain administrative, technical and physical safeguards designed to protect your consumer health data from unauthorized access, use or disclosure, consistent with the sensitivity of the information involved. Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to consumer health data.
13. Changes to This Consumer Health Data Policy
We may update this Consumer Health Data Policy from time to time. If we make material changes, we will post the updated Consumer Health Data Policy on the Site and update the “Last Updated” date above. We will notify consumers whose consumer health data we collect of any material changes before those changes take effect.
14. Contact Us
If you have questions about this Consumer Health Data Policy or wish to exercise your rights, please contact us at:
Perfero Pharma, Inc.
Attn: Legal Department
3 Becker Farm Road
Suite 404
Roseland, New Jersey 07068
Email: privacy@perfero.com
Phone: (973) 629-0109, x547
