This Consumer Health Data Privacy Policy (“Policy”) describes how Exeltis USA, Inc. as part of Exeltis Pharmaceuticals Holding, S.L. and all its subsidiaries located in Spain, EU or third countries (hereinafter, jointly referred to as “Exeltis”, “we,” “us” or “our”) processes “Consumer Health Data,” as that term is defined under applicable state privacy law, about consumers who reside in the states of Nevada, Washington and any other applicable U.S. jurisdiction in connection with the website https://twirla.com (hereinafter, the “Website”), owned by Insud Pharma, S.L.U. Please carefully read this Policy as it contains important information concerning your Consumer Health Data and how we use it.
This Policy relates only to Consumer Health Data. It does not describe how Exeltis processes your personal data. For more information about Exeltis’ information practices with respect to personal data, please refer to our Privacy Policy.
Categories. We collect the following categories of Consumer Health Data:
- Individual health conditions, treatment, diseases, or diagnosis that you share with our nurse professionals;
- Information that could identify your attempt to seek health care services, including our prescription products;
- Use or purchase of prescribed medication, including our prescription products
- Bodily functions, vital signs, symptoms, or measurements that you share with our nurse professionals;
- Reproductive or sexual health information; and
- Any inferences of the above categories of consumer health data derived or extrapolated from non-health information, such as cookies and other tracking technologies on our websites and mobile apps if you provide your express permission for our collection.
Sources of Collection. We collect Consumer Health Data from the following categories of sources:
- Directly from you when you share it with us and from your interactions with our products and services, including our patient savings or similar programs that we may offer and information provided to us via chat or other interactions with our nurse professionals;
- With your permission, we and our third-party providers and business partners may collect your health data over time and across different internet websites or online services when you use any internet website or online service of the regulated entity; and
- From third parties and business partners, including our nurse professionals and those involved with the patient savings or similar programs that we may offer.
Purposes of Collection. We collect, processes, and disclose Consumer Health Data for the following business purposes:
- To provide, operate, maintain and protect our Website;
- To provide our products and services, including the patient savings and related discount, reimbursement, education or support programs;
- To analyze and improve our Website, including developing new products, functionalities or services;
- To communicate with you, respond to your inquiries, fulfil your orders and to send you information by email, postal mail, telephone, text message, notifications or other means about our products and services;
- To promote, conduct or distribute educational or promotional content or events, including events that may be in person and to support our marketing and advertising activities, including delivering personalized advertising;
- To enhance and help us better understand your browsing experience, needs and preferences and provide consistent, personalized services and experiences across our Website;
- To protect the security or integrity of the Website, including to perform security analyses to verify that the Website are working properly and have not been compromised based on our legitimate interests;
- To protect us, our users and the public, and comply with applicable law, regulation or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts and otherwise detect, prevent or stop any activity that may be illegal, unethical or legally actionable; and
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us about Users is among the assets transferred.
- Disclosures. We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:
- To our affiliate and parent companies listed in the beginning of this Policy, primarily due to the use of shared computer systems, which may be located in the European Economic Area (EEA) or in third countries;
- As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law;
- To other companies we collaborate with for research and development activities related to products and services jointly offered or developed by us and that company; and
- To data analytics and advertising and marketing providers.
Your Privacy Rights
Depending on your place of residency, you may have the right to submit some or all of the following requests regarding your Consumer Health Data, subject to applicable law and certain exceptions:
- Right to confirm and access your Consumer Health Data, including a list of all third parties and affiliates with whom we have shared the Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.
- Right to correct your Consumer Health Data. If your Consumer Health Data we maintain is inaccurate and you would like us to rectify it, you may request that we make changes to it.
- Right to withdraw consent from collection or sharing of your Consumer Health Data at any time.
- Right to delete your Consumer Health Data.
- Right to appeal a decision by us regarding your request to exercise any of the above rights.
For the exercise of any of the abovementioned rights, you or your authorized agent, may contact Exeltis by email, addressing the request to dataprotection@insudpharma.com, indicating as reference: “EXERCISE OF RIGHTS” and identifying the right to be exercised. In order to process your request, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as most recent interaction with us, if applicable.
Policy Updates
Exeltis reserves the right, in our sole discretion, to modify or replace this Policy. Your continued use of the Website after any such changes constitutes your acceptance of the new Policy.
Please review this Policy every so often in order to acknowledge any possible modifications. If you do not accept this Policy, partially or as a whole, or any subsequent modification, please discontinue any use of the Website immediately.
Contact
If you have any further questions about the use of your personal data or about our Privacy Policy, you can contact Insud Pharma Group’s Data Protection Officer by email through dataprotection@insudpharma.com.
Effective date of the Policy: July the 22nd, 2025