Privacy Statement

Last updated May, 29 2025

Wilcrest Pharmaceuticals, Inc. (“WILCREST”, “we”, or “us”) is committed to respecting and protecting your privacy. This Privacy Statement describes the personal information WILCREST may collect and process about you, how we use it, to whom we disclose it, how we protect it, and the rights and choices you may have with respect to your personal information.

This Privacy Statement applies to all individuals and entities who access www. wilcrestpharma.com (“WILCREST Website”) or otherwise engage with WILCREST online offerings (collectively, “WILCREST Services”). This Privacy Statement is incorporated into and made a part of our Terms of Use. It is also meant to be read in conjunction with our Cookie Notice. Your use of the WILCREST Website or other Services means that you accept, and agree to abide by, all the terms in this Privacy Statement, and, by continued use of the WILCREST Website or our Services, you consent to the practices described herein.

Residents of certain states and countries have privacy rights regarding their personal information. Please refer to the Additional Information for Residents of Certain Jurisdictions section below for more information about these rights and how to exercise them.

Collection and Disclosure of Your Personal Information

The table below identifies, generally, the categories of personal information we may collect, the sources from which we may collect that personal information, and the categories of third parties to whom we may disclose it.

Categories of Personal Information	Sources of Personal Information	Third Parties to Whom We May Disclose
Identifiers. Such as your name, alias, email, phone number, mailing address, online identifier, IP address, government identifiers (e.g., state identification number), or other similar identifiers.	Directly from you Your devices Service providers Business partners	Service providers Business partners Advertising networks Social networks Data brokers
Commercial Information. Such as Services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	Directly from you Service providers	Service providers Business partners Advertising networks
Financial Information. Such as bank account information, payment card information, billing address, or payment history.	Directly from you Service providers	Service providers
Internet or Other Electronic Network Activity Information. Such as IP address, browser type, referring link domains, browsing history, clickstream data, search history, and information regarding your interactions with our websites, advertisements, or emails.	Directly from you Your devices Service providers Business partners	Service providers Advertising networks
Location Data. Such as general location information or approximate or specific geolocation data about you or your device.	Directly from you Your devices	Service providers Business partners Advertising networks Social networks
Audio, Electronic, Visual, or Similar Information. Such as recordings of calls, meetings, webinars, videos, and photographs.	Directly from you WILCREST systems and devices	Service providers
Inferences. Such as consumer preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.	Service providers Business partners WILCREST systems and devices	Service providers Business partners Advertising networks

We may de-identify certain of your personal information to support our Services and before sharing such de-identified information with third parties. Personal information does not include de-identified information. Thus, to the extent we maintain and use information in its de-identified form, and do not re-identify it, such de-identified information is no longer considered personal information and is not subject to this Privacy Statement. Personal information also does not include information that is publicly available. Thus, if you decide to directly disclose personal information through any public forum, it is no longer considered personal information and is not subject to this Privacy Statement.

WILCREST may disclose your personal information to other third parties not listed above with your prior consent or at your direction.

We may also disclose your personal information without prior consent or notice to you if required to do so by law or if we in good faith believe that such disclosure is necessary to: (a) conform with WILCREST’s legal obligations; (b) comply with legal process; (c) protect the rights or property of WILCREST; or (d) protect the personal safety of our employees, members, users, agents, or the public.

Lastly, WILCREST may disclose your personal information to a third party in the event of a merger, sale, assignment, or other transfer of the business to which the information relates. In this case, we will request that any such third party treat personal information in accordance with this Privacy Statement.

To the extent you provide us personal information related to another individual, you warrant that you have the right to provide such personal information and you will be fully responsible for and indemnify WILCREST against any liability arising from collection, use, processing, storage, disclosure, or deletion of such personal information.

Use of Your Personal Information

WILCREST may process personal information for the following purposes:

Providing and improving our current Products and Services;
Developing potential new Products and Services;
Maintaining and improving the WILCREST Website;
Conducting business and market research;
Contracting, business planning, financial, and tax activities;
Communicating information about our products and Services;
Ensuring compliance with our legal or regulatory obligations;
Conducting data analytics regarding use of the WILCREST Website;
Ensuring the security of WILCREST networks, systems, information, assets, and premises;
Detecting or preventing illegal or unlawful activity;
Marketing and advertising WILCREST, our Services, and our products;
Fulfilling product orders or requests for samples;
Providing customer service;
Responding to requests for information;
Conducting and supporting medical studies and research;
Activities to support public health and interest;
Other legal and business processes that are in WILCREST’s legitimate interest, inclusive of company record retention, maintaining our systems and records (e.g., testing, validation, fixing software errors), and general business management.

Sale and Sharing of Personal Information

Certain privacy laws define “sale” as disclosing personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” as disclosing personal information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, our use of third-party analytics and advertising cookies and disclosure of personal information to third-party advertising networks, social networks, and data brokers for purposes of improving our marketing and advertising efforts may be considered “selling” and “sharing” in certain jurisdictions. Depending on your jurisdiction of residence, you may have the right to opt out of the sale or sharing of your personal information, see the Additional Information for Residents of Certain Jurisdictions section below for more information. We do not sell or share personal information about individuals that we know are under age 18.

International Data Transfers

WILCREST may process your personal information outside of your country or state of residence for the purpose(s) described in this Privacy Statement. These jurisdictions may have data protection and data privacy laws that are different from or less stringent than the laws of your jurisdiction of residency.

By using the WILCREST Website or the Services, you acknowledge and agree that your personal information may be transferred to these other jurisdictions for processing and storage. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information. We also require any support provider that processes personal information on our behalf to provide at least the same level of protection for such personal information as required by legal and regulatory requirements.

Legal Bases for Processing

We collect and process your personal information only when one of the following legal bases applies:

Where you have given your consent for such processing. If this is the legal basis on which we rely, you may withdraw your consent at any time by contacting us. Note that withdrawal will not affect the lawfulness of any processing that occurred prior to withdrawal, and it will not affect processing based on a legal basis other than consent (such as the ones below).
Where processing of the personal information is necessary to perform a contract with you (e.g., fulfill obligations in the membership agreement, process payments).
Where processing of the personal information is necessary to comply with a legal obligation, or where we have a legal obligation to process the personal information.
Where processing of the personal information is necessary to fulfill a legitimate interest of ours or of a third party (e.g., providing the Services, operating or improving the WILCREST Website, responding to your queries, ensuring data security, conducting marketing, detecting or preventing illegal activities), and that legitimate interest is not overridden by your rights.
Where processing of the personal information is necessary to protect the vital interests of a natural person.
Where processing of the personal information is necessary for a public interest.

How Long We Keep Personal Information

We retain personal information for as long as necessary to fulfill our legitimate business purposes, comply with legal obligations, and adhere to our internal retention policies. Where appropriate, personal information may be de-identified or aggregated for compliant uses. Retention periods vary based on legal, regulatory, contractual, and business requirements. Upon request, we will securely delete personal information, unless retention is required to meet legal or regulatory obligations.

Security of Your Personal Information

WILCREST employs reasonable security measures to protect your personal information from unauthorized access, use or disclosure, including reasonable physical, electronic, and procedural safeguards to protect personal information we process and maintain. We limit access to personal information to authorized employees and third parties who need access to perform legitimate business activities consistent with this Privacy Statement.

Although we strive to protect the personal information we process and maintain, no security system can prevent all potential security breaches. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

External Links

The WILCREST Website may contain external links to third-party websites, plug ins, and applications. Clicking on these links may allow third parties to collect or process personal information about you. We do not control these third-party websites, and this Privacy Statement does not apply to their collection or processing practices. Collection and processing of your personal information by such third-party websites is governed by their own privacy statements. When you click on one of these links (and thereby leave the WILCREST Website), we encourage you to read the privacy statement of that third-party website and contact them directly for more information about their data collection and processing practices. An external link on the WILCREST Website does not constitute an endorsement of that third-party website, or any good or services they provide, and you assume all risk with respect to its use.

The WILCREST Website uses “cookies” and other web technologies to help you personalize your online experience. For more information about our use of cookies and similar technologies, and how you can manage them, please refer to our Cookie Notice.

Minors

The WILCREST Website and our Services are not directed at minors (i.e., individuals under 18 years old), and such minors should not use either or otherwise provide us with their personal information. If we become aware that personal information has been collected from a minor, we will terminate the minor’s account (if applicable) and delete the personal information.

Additional Information for Residents of Certain Jurisdictions

Certain individuals may have additional rights under applicable privacy laws, as described in this section, subject to certain exceptions.

Depending on your state or country of residence, you may have the right to:

Request confirmation of whether we process your personal information, and, if so, which personal information categories, the source of that personal information, and the purpose for the processing;
Access or obtain a copy of your personal information;
Receive an electronic copy of your personal information, or ask us to send that personal information to another organization;
Object to or restrict our processing of your personal information in certain circumstances;
Seek correction of inaccurate, untrue, or incomplete personal information;
Request erasure of certain personal information held about you by the Company, subject to certain legal exceptions;
Know whether we have shared your personal information with any third parties, and if so, which personal information, which third parties, and for what purpose;
Opt out of the automated profiling of your personal information in furtherance of a decision that produces a legal or similarly significant effect concerning you;
Withdraw your consent to the processing of your personal information, where the processing is based on your consent; and
Not be discriminated against for exercises any rights applicable to you regarding your personal information.

If you would like to exercise any of these rights, please contact us as set forth in the Contact Us section below. To protect your privacy, the Company will take steps to verify your identity before fulfilling your request, which may include asking you to verify or provide certain personal information. If we are unable to verify your identity after a good faith attempt, we may deny the request. To the extent permitted under applicable privacy laws, you may also designate someone as an authorized agent to submit requests and act on your behalf with respect to your personal information.

We will respond to a valid request in accordance with our legal obligations. However, WILCREST reserves the right to decline your request as permitted by law. If we decline your request, you may have the right to appeal our decision depending on your state or country of residence. To appeal, you may respond to our communication stating your intent to appeal and we will provide further instructions.

Changes to this Statement

We may occasionally update this Privacy Statement. When we do, we will revise the “last updated” date at the top of the Privacy Statement. If there are material changes to this Privacy Statement or in how WILCREST will use your personal information, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Privacy Statement to learn how WILCREST collects and processes your personal information.

If you have questions, comments, or concerns about this Privacy Statement, you may contact us using the information below.

Wilcrest Pharmaceuticals, Inc

1111 S. Wilcrest Drive, Suite 3000

Houston, TX 77099

(866) 494-5273 [866 4WILCREST]

info@wilcrest.com