Effective Date: January 1, 2026

Eirvera LLC (“we,” “us,” or “our”) is committed to protecting the privacy and security of our website visitors and clinical trial applicants. This Privacy Policy outlines how we collect, use, and protect your personal information in accordance with applicable laws, including the Health Insurance Portability and Accountability Act (HIPAA), the Florida Digital Bill of Rights (FDBR), and other relevant state and federal privacy regulations.

1. Information We Collect When you interact with our website or apply for a clinical trial, we collect information strictly necessary to determine your eligibility and facilitate recruitment. This may include:

• Personal Identifiable Information (PII): Name, email address, phone number, and date of birth.
• Health Information: Self-reported medical conditions, diagnoses, or demographic data provided voluntarily through our secure intake forms.
• Automatically Collected Data: IP addresses, browser types, device information, and website interaction data.

2. How We Use Your Information We use the information collected solely to:

• Determine your preliminary eligibility for current and future clinical trials in the Tampa/St. Petersburg area.
• Contact you regarding trial opportunities, scheduling, and study details.
• Improve our website experience and securely optimize our digital recruitment campaigns.

3. Data Sharing and Advanced Secure Tracking We do not sell your personal data or health information to third parties. To effectively reach patients who may benefit from our trials, we run digital advertising campaigns. To protect your privacy during this process, we employ the following strict protocols:

• No Third-Party Browser Pixels: Unlike standard websites, we do not use invasive third-party tracking “pixels” (such as standard Meta or Google tags) that monitor your browsing behavior across the internet.
• Secure Server-Side APIs: We utilize secure, intermediary server-side technology. Before any data regarding ad performance is routed to our advertising partners, it passes through our private servers.
• Data Encryption (Hashing): Before any personal identifier (such as your Name, Email, or Phone Number) is shared with advertising platforms (like Meta or Google) for attribution purposes, it is strictly one-way encrypted using SHA-256 hashing. This ensures that raw personal health information is never readable or accessible by these platforms.
• Business Associates: We partner with secure third-party vendors who process data on our behalf. These partners are bound by strict confidentiality agreements, including HIPAA Business Associate Agreements (BAAs).

4. Substance Use Disorder (SUD) Records & Additional Legal Protections In compliance with 2026 HIPAA Privacy Rule updates and 42 CFR Part 2, any records or information we maintain regarding Substance Use Disorder (SUD) treatment are subject to heightened confidentiality protections. Such records will not be used or disclosed in civil, criminal, administrative, or legislative proceedings against a patient without written consent or a specific court order. If applicable, you have the right to opt-out of any fundraising communications related to Part 2 records.

5. Cookies and Consent Our website uses secure, functional cookies to facilitate matching with relevant clinical trials and improve site functionality. By using our site and acknowledging our cookie banner, you consent to our use of these tools. You can choose to disable cookies through your individual browser settings.

6. Data Security and Retention We implement robust physical, technical, and administrative safeguards to protect your data, including encrypted data transmission and restricted access limited only to authorized Eirvera LLC clinical staff. We retain your personal data only for as long as necessary to fulfill the recruitment and operational purposes outlined in this policy, or as legally required by trial sponsors and Institutional Review Boards (IRBs).

7. Children’s Privacy Our website and clinical trials are generally directed to individuals 18 years of age and older. We do not knowingly collect personal data from children under the age of 18 without explicit, verified parental consent. If we become aware that we have collected data from a minor without such consent, we will delete the information immediately.

8. Your Privacy Rights (Including Florida Residents) Depending on your jurisdiction, including rights granted under HIPAA and the Florida Digital Bill of Rights, you have the right to:

• Request access to the personal data we hold about you.
• Request corrections to any inaccurate information.
• Request the deletion of your personal data from our active marketing and recruitment systems.
• Opt-out of future marketing or recruitment communications, as well as opt-out of the processing of personal data for targeted advertising.

9. Contact Us If you have questions about this Privacy Policy, our data practices, or wish to exercise your data rights, please contact our privacy officer at:

• Email: info@eirvera.com
• Mailing Address: 10221 Grand Oak Cir, Madeira Beach, FL 33708