PRIVACY POLICY

SCORPION THERAPEUTICS – PRIVACY POLICY

Scorpion Therapeutics, Inc. (“Company” of “Scorpion Therapeutics”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined under applicable law) we collect from users of our website, located at www.scorpiontx.com and our widgets (collectively, the “Site”) and online services (“Services”).

We will only process your Personal Data in accordance with applicable data protection and privacy laws.

1 Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address:

Scorpion Therapeutics
One Winthrop Square
Suite 400
Boston, MA 02110

2 User Consent. By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

3 A Note About Sensitive Personal Data. We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.

4 A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at info@scorpiontx.com.

5 A Note to Users Outside of the United States. If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Scorpion Therapeutics is in the process of self-certifying under the EU-US Privacy Shield framework and Swiss-US Privacy Shield framework. Scorpion Therapeutics will adhere to the required privacy principles under these frameworks in order to protect your Personal Data. Once certified, we will update this Privacy Policy accordingly.

6 Types of Data We Collect. “Personal Data” includes data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Information You Provide to Us.

We may collect Personal Data from you, such as your first name, last name and e-mail address when you apply for a role advertised on our Site or access the “Investor” portion of our site.

Our Site lets you store preferences like how your content is displayed, your location, safe search settings, and favorite widgets. We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.

When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.

If you provide us feedback or contact us via e-mail, we may collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

We may also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.

We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.

Information Collected via Technology.

Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp,

and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example,

some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire

once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

Cookies we Use. We use the following types of cookies for the purposes set out below:

Targeted and advertising cookies

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages that they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Targeted and Advertising Cookies	These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. If you don’t want to take advantage of these services, you may be able to opt-out by visiting https://youradchoices.com/ or http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on our Site or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our site.

7 Use of Your Personal Data

General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

identify you as a user in our system;

communicate with you about a role for which you have applied;

provide improved administration of our Site and Services;

provide the Services you request;

improve the quality of experience when you interact with our Site and Services;

send you administrative e-mail notifications, such as security or support and maintenance advisories;

respond to your inquiries related to employment opportunities or other requests; and

make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback.

Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.

8 Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy. indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you

before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any

questions about how to disable or modify Cookies, please let us know at the contact information provided below.

De-Linking SNS. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust

our permissions and manage the interactivity between the Services and your social media account or mobile device.

Changing or Deleting Your Personal Data. All users may request that their Personal Data is reviewed, updated, corrected or deleted. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

9 Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from

you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your

Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

10 Your Choices Regarding Information. You have several choices regarding the use of information on our Service:

Email Communications. With your consent, we will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services, including via the Investor portion of our Site. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

questions about how to disable or modify Cookies, please let us know at the contact information provided below.

our permissions and manage the interactivity between the Services and your social media account or mobile device.

11 Retention. We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

12 Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you

the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Scorpion Therapeutics
888 Boylston Street
Suite 1111
Boston, MA 02199
info@scorpiontx.com