Terms of Use

Welcome to the SQ Innovation website (“Website”). Our Website is a copyrighted website intended only for users residing in the United States of America and those 18 years of age or older. IF YOU CONTINUE TO BROWSE AND USE THIS WEBSITE YOU ARE AGREEING (ON BEHALF OF YOURSELF OR THE LEGAL ENTITY YOU REPRESENT) THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO COMPLY WITH AND BE BOUND BY THE FOLLOWING TERMS AND CONDITIONS OF USE, WHICH TOGETHER WITH OUR PRIVACY NOTICE, GOVERN SQ INNOVATION’ RELATIONSHIP WITH YOU IN RELATION TO THIS WEBSITE. Please read the following terms carefully. If you disagree with these terms and conditions, please do not access or use the Website. You furthermore agree to be bound to the requirement of the use of arbitration (hereinbelow) on an individual basis to resolve disputes, rather than a jury trial or class action, and you also agree to the limitation of remedies available to you in the event of a dispute.

The term “SQ Innovation, Inc.”, “SQ Innovation” or “us”, “our”, or “we” refers to the owner of the Website, whose registered offices are SQ Innovation, Inc., 20 Burlington Mall Road, Suite 220, Burlington, Massachusetts 01803. The term “you” refers to the user or viewer of our Website.

The use of this Website is subject to the following terms and conditions of use:

• The content, materials, and other information (“Content”) of the pages of this Website is for your general information and use only. It is subject to change without notice. Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness, or suitability of the information and materials found or offered on this website for any particular purpose. Further, SQ Innovation does not undertake any obligation to update any information that may change after posting. Unless it is indicated otherwise, all future releases of the Website are subject to these terms and conditions. You acknowledge that such information and materials may contain inaccuracies or errors, and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law. You further acknowledge and agree that SQ Innovation has no obligation to provide any support or maintenance to you in connection with your access or use of the Website.

• SQ Innovation reserves the right, at any time, to change, modify, suspend, or discontinue the Website or any part of the Website at any time and without notice to you. By accessing and using the Website, you agree that SQ Innovation waives all liability, to the fullest extent permitted by law, to you or any third party for any changes, modifications, suspensions, or discontinuation of the Website or any part of the Website. You are bound by any such revision. Please visit the Website regularly for the most up-to-date version of the Website.

• Your use of any information or materials on this Website is entirely at your own risk, for which we shall not be liable. It shall be your responsibility to ensure that any products, services, or information available through this Website meet your specific requirements. This Website contains material which may be owned by, or licensed to, us. This material includes, but is not limited to, the design, layout, look, appearance, and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions. Any medical information contained on the Website is intended for informational purposes only. The Website and the information contained on the Website is not a substitute for professional medical advice, diagnosis, or actual medical care. You should contact your local healthcare provider if you have health-related questions or require a diagnosis or treatment. You should NOT rely on the information and materials on the Website when deciding on a treatment plan, therapy, or any other medical decision. PLEASE refer to your doctor as the best resource for medical advice and information.
• The information on the Website is not intended and should not be construed as an offer to sell securities.

 

Use of Content

• The Website is owned and operated by SQ Innovation. The Content maintained on the Website, including but not limited to images, photographs, videos, logos, graphics, icons, software, and other content, are the exclusive property of SQ Innovation and its licensors. All Content is protected under copyright, trademark, and other laws. Subject to these Terms, SQ Innovation grants you a non-transferable, non-exclusive, revocable, limited license to access and use the Website for your own personal, non-commercial usage, provided you keep intact all copyright and other proprietary notices. You assume all responsibility for such use. Use of the Content for any other purpose is a violation of SQ Innovation’s copyright and other proprietary rights and a breach of the terms and conditions.
• You warrant and represent that your use of the Website is for lawful purposes only and that your access or use of the Website complies with applicable laws and regulations. SQ Innovation prohibits the use of the Website for, and you warrant and represent that you will not: (i) use any device, software, or other interface to interfere or attempt to interfere with the functionality, security, and Content of the Website; (ii) license, rent, lease, transfer, assign, distribute, host or otherwise commercially exploit the Website; (iii) cause or impose an unreasonably large load on the Website’s infrastructure; (iv) modify, make derivative works of, disassemble, decipher, decompile, reverse engineer or reverse compile any part of the Website, the Content, or any of the software comprising or in any way making up any part of the Website, or attempt to do the same; (v) post, upload, or distribute any Content or other information that is defamatory, libelous, unlawful, or that a reasonable person could deem embarrassing, harassing, hateful, indecent, objectionable, pornographic, profane, threatening, or otherwise inappropriate; (vi) access the Website to build a similar or competitive website, product, or service; (vii) conduct any fraudulent activities, including but not limited to impersonating any person or entity, claiming a false affiliation, or falsifying your age or date of birth; and (viii) except as stated herein, no part of the Website may be copied, reproduced, distributed, republished, modified, uploaded, posted, transmitted, or distributed in any way without prior written authorization of SQ Innovation. All copyright and other proprietary notices on the Website, including those related to the Content, must be retained on all copies.
• By accessing and using the Website, you agree that all intellectual property rights, including copyrights, patents, trademarks, and trade secrets, in and on the Website and the Content are owned by SQ Innovation and its licensors or third-party partners. Nothing in these terms and conditions, on the Website, or in the Content confers onto you or any third party any rights, titles, or interest in or to such intellectual property rights, except as otherwise stated herein these Terms. SQ Innovation, its Licensors, and third-party partners reserve all rights not granted in these terms and conditions. There are no implied licenses granted under these terms and conditions.
• The Website and the Content may be subject to U.S. export control laws and may be subject to export or import regulations in other countries. You agree not to export, re-export, or transfer, directly or indirectly, any U.S. technical data acquired from SQ Innovation, or any products utilizing such data, in violation of the United States export laws or regulations.

• All trademarks reproduced on this Website that are not the property of, or licensed to, the operator are acknowledged on the Website. Unauthorized use of this website may give rise to a claim for damages and/or be a criminal offence.

• For these terms and conditions, the access or use of the Website and the Content, or any changes or modifications to the Website or the Content, is prohibited without express written permission from SQ Innovation. You may not copy or adapt any Content to generate any other website, document, or other materials without SQ Innovation’s express, written consent. The code utilized on the Website is also protected by copyright and other laws.
• We comply with the Digital Millennium Copyright Act (“DMCA”), as applicable to Internet service providers (17 U.S.C. §512, as amended). If you believe that your intellectual property rights have been violated or have an intellectual property right-related complaint about Content posted on the Website, you may contact us at the following address with a notice in accordance with 17 U.S.C. §512, as amended:

  SQ Innovation
  ATTN: Legal
  20 Burlington Mall Road, Suite 220

• Burlington, Massachusetts 01803
  Email: info@sqinnovation.com

SQ Innovation reserves the right to reject any notice that does not contain all requirements of 17 U.S.C. §512.

 

Submissions

The Website is not intended to and does not enable users to post or share information on the Website. We are happy to hear from you and welcome your comments regarding SQ Innovation’s work or the Content. We can be contacted by emailing us at any of the email addresses provided on the Website, including but not limited to info@sqinnovation.com. It is against SQ Innovation’s company policy, however, to accept or consider confidential or creative ideas, suggestions, input, inventions, notes, drawings, concepts, materials, or other information (collectively “Information”) unless specifically requested in writing by an authorized officer, employee, or agent of SQ Innovation. If you independently send us any Information, it will be treated as deemed and will remain the sole and exclusive property of SQ Innovation. By sharing Information with SQ Innovation, you hereby grant SQ Innovation an unrestricted, perpetual, irrevocable, non-exclusive, fully paid, royalty-free, sublicensable, and worldwide license to use, exploit, sublicense, and sell the Information in any manner and for any purpose, including to improve the Website, developing our products, and creating services. By sharing Information, you agree that none of the Information is subject to any obligation of confidence on the part of SQ Innovation and SQ Innovation is not and will not be liable for any use or disclosure of any Information. Without limiting the foregoing, SQ Innovation has exclusive ownership of all now known or existing rights to the Information and is entitled to unrestricted use of the Information for any purpose whatsoever, including but not limited to commercial or otherwise, without any compensation to you or any other provider of the Information.

Investors

The Website may contain “forward-looking” statements within the meaning of the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. Forward-looking statements can be identified by words such as: “anticipate,” “intend,” “plan,” “goal,” “seek,” “believe,” “project,” “estimate,” “expect,” “strategy,” “future,” “likely,” “may,” “should,” “will” and similar references to future periods. These statements are subject to numerous risks and uncertainties that could cause actual results to differ materially from what we expect. Examples of forward-looking statements include, among others, timing or outcomes of communications with the FDA, our expectations about safety and efficacy of our product candidates and timing of clinical trials and its results, our ability to commence clinical studies or complete ongoing clinical studies, and to obtain regulatory approvals for Lasix® ONYU and other candidates in development, and the success of any efforts to commercialize Lasix® ONYU. We undertake no obligation to publicly update any forward-looking statement, whether written or oral (including any forward-looking statements on the Website) that may be made from time to time, whether as a result of new information, future developments, or otherwise.

Links/Third Party Content

From time to time, this Website may also include links to other websites, including unaffiliated third-party websites. These third-party websites are not under SQ Innovation’s control, and any links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no liability or responsibility for your use of the links or for the content of the linked website(s), nor do we represent, warrant, or endorse such websites. Your use of these links is at your own risk. All third-party trademarks used on our Website are the property of their respective owners and are used for reference purposes only. You may not create a link to this Website from another website or document without SQ Innovation’s prior written consent.

Indemnification

You agree to indemnify and hold harmless SQ Innovation (its affiliates, directors, officers, employees, licensors, licensees, collaborators, representatives, agents, and successors) from and against any claims, losses, liabilities, damages, demands, and expenses (including reasonable costs, attorneys’ fees and witness fees and costs) made by any third party arising out of, resulting from or connected with: (a) your access or use of the Website or the Content; (b) your violation of any portion of these terms and conditions or any applicable law or regulation; (c) your violation of any third-party right, including any intellectual property, confidentiality, or privacy, in connection with your access or use of the Website; or (d) any dispute or issue between you and any third party in connection with your access or use of the Website. SQ Innovation reserves all and any rights, at your expense, to assume the exclusive defense and control of any matter in which you are required to indemnify SQ Innovation, and you agree to use your best efforts to cooperate with our defense of these claims. You agree not to settle any matter without the prior written consent of SQ Innovation.

Disclaimer

SQ Innovation disclaims all and makes no warranties or representations as to the accuracy of any Content or information on the Website. SQ Innovation disclaims all and assumes no liability or responsibility for any errors or omissions in the Content or information on the Website. SQ Innovation has not reviewed all the Content on the Website, including any third-party websites that may be linked to the Website, and is not responsible for the content of any other websites, webpages, or any other sites linked to the Website. ANY USE OF OR RELIANCE ON THE CONTENT IS AT YOUR SOLE RISK. THE CONTENT ON THE WEBSITE IS PROVIDED “AS IS” AND WITHOUT WARRANTIES OR REPRESENTATIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, SQ INNOVATION DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. SQ INNOVATION DOES NOT WARRANT THAT THE FUNCTIONS CONTAINED ON THE WEBSITE OR AVAILABLE IN THE CONTENT WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THIS SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. SQ INNOVATION DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE CONTENT ON THE WEBSITE IN TERMS OF THEIR CORRECTNESS, ACCURACY, OR RELIABILITY. IN NO EVENT WILL SQ INNOVATION BE LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH THESE TERMS, YOUR ABILITY OR INABILITY TO USE THE WEBSITE OR ANY INFORMATION CONTAINED THEREIN. IF YOU ARE A CALIFORNIA RESIDENT, YOU HEREBY WAIVE CALIFORNIA CIVIL CODE SECTION 1542 IN CONNECTION WITH THE FOREGOING, WHICH STATES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.”

Arbitration and Dispute Resolution

By accessing and using the Website, you and SQ Innovation agree that all disputes that cannot be resolved informally or through small-claims court in connection with these terms and conditions will be resolved by binding arbitration, which is a less formal legal proceeding than a lawsuit in court. Arbitration procedures are typically more limited, more efficient, and less costly than rules applicable in a court and are subject to extremely limited review by a court. This agreement to arbitrate (“Arbitration Agreement”) disputes includes all claims arising out of or relating to any aspect of these terms and conditions, whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory, and regardless of whether a claim arises during or after the termination of these terms and conditions. Unless otherwise agreed to, all Arbitration proceedings will be held in English. YOU UNDERSTAND AND AGREE THAT, BY ENTERING INTO THESE TERMS, SQ INNOVATION AND YOU ARE EACH WAIVING THE CONSTITUTIONAL AND STATUTORY RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION, AND THAT THIS AGREEMENT WILL BE SUBJECT TO AND GOVERNED BY THE FEDERAL ARBITRATION ACT. In the event any litigation should arise between SQ Innovation and you in any state or federal court in a suit to vacate or enforce an arbitration award or otherwise, SQ INNOVATION AND YOU WAIVE ALL RIGHTS TO A JURY TRIAL, instead electing that the dispute be resolved by a judge.

SQ INNOVATION AND YOU AGREE THAT ALL CLAIMS AND DISPUTES WITHIN THE SCOPE OF THIS ARBITRATION AGREEMENT MUST BE ARBITRATED OR LITIGATED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS BASIS, AND CLAIMS OF MORE THAN ONE CUSTOMER OR USER CANNOT BE ARBITRATED OR LITIGATED JOINTLY OR CONSOLIDATED WITH THOSE OF ANY OTHER CUSTOMER OR USER. Further, unless both SQ Innovation and you agree otherwise, the arbitrator may not consolidate more than one person’s claims, and the arbitrator may not otherwise preside over any form of a representative or class proceeding.

Before either party may seek arbitration, the party must first send to the other party a written notice of dispute (“Notice”) that describes the basis and the nature of the claim or dispute, as well as the requested relief. After the Notice is received, SQ Innovation and you may attempt to resolve the claim or dispute informally. Notwithstanding the above, nothing in these terms and conditions will be deemed to waive, restrict, preclude, or otherwise limit the right of either party to: (a) bring an individual action in small claims court; (b) pursue an enforcement action through the applicable federal, state, or local agency if that action is available; (c) seek injunctive relief to aid arbitration from a court of competent jurisdiction; or (d) to file suit in a court of law to address an intellectual property infringement claim. If SQ Innovation and you cannot resolve the claim or dispute within thirty (30) days after the Notice is received or a period mutually agreed upon by the parties, either party may begin arbitration proceedings. If SQ Innovation or you pursue arbitration, the arbitration action must be initiated and/or demanded within the statute of limitations (i.e., the legal deadline for filing a claim) and within any deadline imposed under the AAA Rules (defined hereinbelow) for the pertinent claim. The amount of any settlement offer made by any party may not be disclosed to the arbitrator until after the arbitrator has determined the amount of the award, if any, to which either party is entitled.

Any arbitration between SQ Innovation and you will be initiated and settled under the Federal Arbitration Act and governed by the Commercial Dispute Resolution Procedures and the Supplementary Procedures for Consumer Related Disputes (collectively, “AAA Rules”) of the American Arbitration Association (“AAA”), as modified by these Terms, and will be administered by an established alternative dispute resolution provider (“ADR Provider”) that offers arbitration as outlined in these Terms. If AAA is not available to arbitrate, the parties will agree to select an alternative ADR Provider. The arbitrator has exclusive authority to resolve any dispute relating to the interpretation, applicability, or enforceability of this binding arbitration agreement. The rules of the ADR Provider will govern all aspects of arbitration, including the method of initiating and/or demanding arbitration, except to the extent such rules conflict with the Terms. The AAA Rules and filing forms are available online at www.adr.org or by calling the AAA at (800) 778-7879. The arbitration will be conducted by a single, neutral arbitrator. Any claims or disputes in which the total award amount sought is less than Ten Thousand U.S. Dollars (US$ $10,000.00) may be resolved through binding non-appearance-based arbitration, at the option of the party seeking relief. For claims or disputes where the total award amount sought is over Ten Thousand U.S. Dollars (US$ $10,000.00), the right to a hearing will be determined by the AAA Rules. Any arbitration will be held in a location within 100 miles, SQ Innovation’s principal place of business, unless the parties agree otherwise. If you reside outside of the U.S., the arbitrator will give the parties reasonable notice of the date, time, and place of any hearings or proceedings. Any judgment or award rendered by the arbitrator may be entered in any court of competent jurisdiction. If the dispute is finally resolved through arbitration in your favor, SQ Innovation will pay you the highest of the following: (i) the amount awarded by the arbitrator, if any; or (ii) $2,500.00.

Each party will bear its costs (including attorney’s fees) and disbursements arising out of the arbitration and will pay an equal share of the fees and costs of the ADR Provider.

Any Notice to SQ Innovation can be sent to:

SQ Innovation
ATTN: Legal
20 Burlington Mall Road, Suite 220

Burlington, Massachusetts 01803
Email: info@sqinnovation.com

 

If the arbitrator finds that either the substance of your claim or the relief sought in the Demand is frivolous or brought for an improper purpose (as measured by the standards outlined in Federal Rule of Civil Procedure 11(b)), then the payment of all fees will be governed by the AAA Rules. In that case, you agree to reimburse SQ Innovation for all costs that are otherwise your obligation to pay under the AAA Rules. The arbitrator must render a reasoned, written decision sufficient to explain the essential findings and conclusions on which any decision and/or award, if any, are based. The arbitrator may make rulings and resolve disputes as to the payment, reimbursement of fees or expenses or grant of non-monetary remedy or relief under applicable law, the AAA Rules, and the terms and conditions at any time during the proceeding or, upon request from either party, within ten (10) business days of the arbitrator’s ruling on the merits. The arbitrator has the same authority to award relief individually as a judge in a court of law would have. The award of the arbitrator is final and binding upon SQ Innovation and you. All aspects of the arbitration proceedings, including but not limited to the award of the arbitrator and compliance therewith, will be strictly confidential. The parties agree to maintain confidentiality unless otherwise required by law. This paragraph will not prevent a party from submitting to a court of law any information necessary to enforce this Agreement, to enforce an arbitration award, or to seek injunctive or equitable relief.

If any part or parts of this Arbitration Agreement are found under the law to be invalid or unenforceable by a court of competent jurisdiction, then such specific part or parts will be of no force and effect and will be severed, and the remainder of the Agreement will continue in full force and effect. Either party may waive any or all of the rights and limitations outlined in this Arbitration Agreement. Such a waiver will not waive or affect any other portion of this Arbitration Agreement. This Arbitration Agreement will survive the termination of your relationship with SQ Innovation.

Jurisdictional issues

The Website and its Content are intended for users in the United States and the European Union and are intended to comply with the laws and regulations in the United States and European Union, without regard to the conflict of law provisions thereof. SQ Innovation makes no representation that the Content is appropriate or available for use in other locations. By continuing use of the Website in the United States, you are affirmatively consenting that your access and use hereof will be governed construed in accordance with the applicable laws of the Commonwealth of Massachusetts and the United States, excluding their conflict of law provisions. Those who choose to access the Website from other locations do so on their initiative and are responsible for compliance with local or national laws, if and to the extent local or national laws are applicable. SQ Innovation reserves the right to limit the provision of any product or service to any person, geographic region, or jurisdiction and to limit the products or services that we provide.

Termination

These terms and conditions are effective until terminated by SQ Innovation or you in accordance with this section. You may terminate your agreement at any time by destroying all Content obtained from the Website and all related documentation and all copies and installations thereof, whether made under these terms and conditions or otherwise. These terms and conditions will terminate immediately without notice from SQ Innovation if we, at our sole discretion, suspect or determine that you failed to comply with any part or portion of the terms and conditions. Upon termination, you must destroy all Content obtained from the Website and all copies thereof, whether made in accordance with the terms and conditions or not. The terms and conditions set forth for the Website will survive such termination, including without limitation the paragraphs headed “Use of Content,” “Restrictions on Use of Materials,” “Investors,” “Submissions,” “Arbitration and Dispute Resolution,” “Indemnification,” “Jurisdictional Issues,” “Termination,” and “Disclaimer.”

Severability

If any of these terms and conditions is held invalid or unenforceable by any court of competent jurisdiction, the other provisions of these terms and conditions will remain in full force and effect. If any provision of these terms and conditions is held invalid or unenforceable only in part or degree, the remainder will continue in full force and effect to the extent not held invalid or unenforceable.

Assignment

You may not assign, delegate, or transfer these terms and conditions or your rights or obligations hereunder, in any way (by operation of law or otherwise). We may transfer, assign, or delegate these terms and conditions and our rights and obligations without consent.

©Copyright 2025 SQ Innovation. This SQ Innovation Website is protected by copyright, including images, layout, and text. All rights reserved.

The use or misuse of these trademarks, copyrights, or other materials is expressly prohibited and may violate copyright law, trademark law, communications regulations and statutes, and other laws, statutes, and/or regulations.

 

SQ Innovation Privacy Notice

We are committed to protecting and securing your personal data. This privacy notice (“Notice”) sets out how SQ Innovation, Inc. (“SQ Innovation”, “us”, “we’, “our”) uses and protects any information that SQ Innovation accesses, collects, maintains, stores, or otherwise processes about you (“personal data”). This Notice explains how we process personal data and describes our customary practices regarding how SQ Innovation, with its registered offices at 20 Burlington Mall Road, Suite 220, Burlington, Massachusetts 01803 collects, discloses, retains, uses, and otherwise processes (“Process”) personal data in its capacity as a business or controller. SQ Innovation’s Authorized Representative in the European Union is A.R. Experts B.V. with its office at Amerlandseweg 7, 3621 ZC Breukelen, The Netherlands.  Personal data does not include, and this Notice does not apply to, aggregate information or information that has been de-identified or anonymized per applicable law. Any specific privacy notice will be delivered to the data subjects for that specific purpose(s).  This is a notice of our privacy practices; it does not create any agreement between the parties.

SQI complies with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 also known as the “GDPR” and applicable local data protection laws.

1. What is personal data?

Personal data is any information that relates to an identified or identifiable living individual. Examples include name, address, email address, phone number, IP address, location data, or cookies.

2. What are the types of personal data that we Process?

During the last 12 months, we may use the following personal data about you (below is not a full accounting of the data related to any category):

• Contact information: name, address, email address, phone number, date of birth, and other similar contact information.
• Education history: degrees, level of education attained, institutions attended, majors and areas of study, and grades.
• Employment information: employer, job title, specialty, employment history, awards and honors, membership in professional organizations, speaking engagements, and affiliations with patient advocacy organizations.
• Financial information: bank account information, credit card number, and bank accounts.
• Health information: health statistics, tests, results, diseases, symptoms, therapies, medications, patient or research study ID, outcomes, barriers to access, insurance information, and dates of service.
• Inferences: notes about preferences and aptitudes.
• Internet or other electronic network activity information: IP address, country or geographic region location, browser type, device type, operating system, dates, and times you access our services, browsing history, and other information about your interactions with our online services. We collect such information through cookies and other tracking technologies. Please see our “Cookies and Other Tracking Technologies” section below.
• Job candidates and recruitment-related information: social security number; government-issued identification number; interview information and notes; employment information; employee termination information; race or ethnic origin; credit history; criminal history; immigration status, work permit status; and other appropriate information.
• Mental and physical characteristics: eye color, height, weight, attitude, and emotions.
• Opinions or statements: publicly available social media posts and opinions.
• Photograph, audio, video information, and public comments, including but not limited to publicly available social media posts and opinions.
• Publicly available information: license information, discipline, information about programs/studies and other activities in which you have participated, prior litigation or regulatory proceedings, and other due diligence information.
• System Account information: username and password.
• Any other information: any other information relevant to any inquiries, comments, market research, responses, or interactions that you have or share with us or our service providers/business partners.

Please note that SQ Innovation does not intend to process your sensitive information. Unless required under applicable law or in accordance with certain services, we will not request any sensitive information, including health information about any patients or yourself, from you, and we request that you do not provide this personal data to us. In the event we do receive your sensitive information, we will process it only to the extent necessary to comply with your direction and as required under applicable law.

 

3. How do we collect your personal data?

We may collect or obtain personal data:

• Directly from you or someone acting directly on your behalf, such as a caregiver, when you interact with SQ Innovation
• From healthcare providers (“HCPs”), healthcare organizations (“HCOs”), including hospitals, clinics, physician practices, or other similar third parties
• From contract research organizations (“CROs”) or clinical research investigators (“PIs”)
• From industry groups, events, programs, and patient advocacy organizations (“PAOs”)
• From third-party service providers, data brokers, business partners, and data aggregators
• From individuals who report adverse events and quality issues
• From government authorities or public sources
• Through our Website or social media
• Automatically through cookies, or other technologies (explained more below)

4. The purposes for which we process your personal data

We process your personal data for the following business, commercial, and operational purposes (If applicable laws require a “legal basis” to Process personal data, we indicate our legal bases applicable only for those jurisdictions. The legal bases provided herein do not apply in any jurisdictions not requiring such.):

From time to time, SQ Innovation may provide a privacy notice or a just-in-time privacy notice specific to a Processing. If such notice conflicts in any way with the information provided herein, including any legal bases, that notice will govern that processing activity.

With your consent/explicit consent, or if you are a Minor (explained more below), with your or your parent’s or legal guardian’s consent, to:

• As part of your participation in our clinical research (when consent and explicit consent are the applicable legal bases only, otherwise, for more clarity, please refer to your applicable informed consent document for more information about applicable legal bases), patient support programs, or other Processing related to patients. In addition to the information contained in this Notice, this Processing will be in accordance with any information forms available from your investigator, and the privacy notice provided for this activity, which is available here.
• Send communication, promotional, and other materials (where consent is required under applicable law). You have the right to opt out of communications at any time. We use your contact information, your employment and professional information, publicly available information, inferences, and other Personal Data collected through our interactions with you and from third-party sources.
• Evaluate job candidates, including receiving and reviewing any job applications, obtaining information from external recruiters or websites, talking to references, and performing legally permissible background checks. We use your contact information, employment-related information, education history, demographic information, and medical certificate, if required by local applicable employment law.
• Collect information from or about you (where consent is required under applicable law) for internal and external use. We use your contact information, photographs, audio, video, and sensitive information, such as health and medical information, and mental and physical characteristics. SQ Innovation requests that you do not share any sensitive or health information with us unless we request it under obligations under law.

Related to the contract (including pre-entering a contract) between us:

• Hiring you to provide services or partner with you. We may use your contact information and financial information.
• Interacting with you and compensating you (if applicable) as a key opinion leader, advisor, investigator, researcher, event or meeting attendee or speaker (including but not limited to advisory boards, medical events, conferences, etc.). We may use your contact information, your employment and professional information, inferences, photo/video, financial information, or any other Personal Data you share with us. In addition, we may use your information in contemplation of a contract related to any invitation.
• Collect certain information from or about you for internal and external use. We use your contact information, photographs/video, or other Personal Data that may indicate race, ethnic origin, or other physical characteristics.
• Giving donations, grants, and access to products through compassionate use. We may use your contact information, health information, mental and physical characteristics, employment-related information, education history, and demographic information. For access to products through compassionate use, SQ Innovation uses reasonable efforts to maintain your confidentiality, even from us. As such, we rely on your HCP to provide you with any Notice and provide us with the appropriate limited Personal data on your behalf.
• Other contractual interactions.

Failure to provide requested data may prevent the execution of a contract between us.

Required in accordance with our legitimate interests:

• Communicate with you and provide you with information about our activities or tailored information about a program that you have expressed interest in. We may use your contact information, your employment and professional information, inferences, publicly available information, and other personal data collected through our interactions with you.
• De-identification of your personal data. In accordance with applicable legal requirements, we may de-identify or anonymize personal data from and about you so that it can no longer be linked to you. Information that has been de-identified/anonymized (as applicable by law) in such a way is no longer subject to this Notice and can be used and shared by SQ Innovation at our discretion.
• Establishment, exercise, or defense of legal claims. We may use your contact information, your employment and professional information, publicly available information, financial information, and other personal data collected through our interactions with you and from third-party sources.
• Identifying potential candidates for recruitment via online or public sources. We may use your contact information, professional or employment-related information, education history, and demographic information.
• Interacting with you and maintaining records related to any interactions. We may use your contact information or any other personal data you share with us. SQ Innovation requests that you do not share any sensitive or health information with us unless we request it under obligations under law.
• Invite you and pre-contract with you to be a key opinion leader/advisor, to invite you to event, SQ Innovation’s organized meetings or meetings sponsored by SQ Innovation (including but not limited to advisory boards, medical events, conferences, etc.) or to invite you to participate in research, including but not limited to market research. We may use your contact information, your employment and professional information, inferences, financial information, or any other personal data you share with us. In addition, we may use your information in contemplation of a contract related to any invitation.
• Manage our relationship with you. We may use your contact information, your employment and professional information, publicly available information, inferences, and other personal data collected through our interactions with you and from third-party sources.
• Operating and administration of SQ Innovation’s business, including but not limited to supporting safe, responsible, compliant, and ethical business and commercial operations; facilitating quality and safety of our products and research; conducting audits and investigations; managing our financial and other accounts; developing and improving our products, etc. We may use any of the categories of personal data, including but not limited to contact information, background information, education history, photographs, video, and audio information.
• Operating the SQ Innovation Website and any other digital technologies. We may use Internet and other electronic network activity information, including but not limited to IP (Internet Protocol) address, country or geographic region location, browser type, device type, operating system, dates/times you access our services, browser history, and other information about your interactions with the Sites. We can collect such information through cookies and other tracking technologies. For more information, please see our “Cookies and Other Tracking Technologies” section below.
• Processing and responding to any unsolicited requests for information. Depending on the nature of your request, the type of Personal Data Processed may vary, including but not limited to your contact information and any other personal data that you may provide. SQ Innovation requests that you do not provide any sensitive or health information.
• Protecting rights and interests, including but not limited to protecting the health, safety, and security of SQ Innovation, its employees, patients, caregivers, HCPs, and the general public; enforcing our legal rights; and pursuing remedies or otherwise taking steps to limit losses and liabilities. We may use your contact information to investigate violations of our contracts or health and medical information in an emergency.
• To seek your views and/or improve our products, services, and SQ Innovation materials (including but not limited to promotional, scientific, and educational information). We may use your contact information, your employment and professional information, inferences, or any other personal data you share with us. We may also use your personal data to analyze and improve our interactions, events, and activities with you and other HCPs, which may include any information you provide about diagnosis or treatment approaches.
• Training and quality assurance purposes. We may use your contact information, your employment and professional information, publicly available information, and other personal data collected through our interactions with you and from third-party sources.

When required by law, for example, by:

• Monitoring and reporting pharmacovigilance and the safety, quality, and complaints related to our products and any clinical research. We may use your contact information, health information, and mental and physical characteristics. We process this personal data only when required by law and as necessary for reasons of public interest in the area of public health.
• Complying with transparency requirements. We may use your contact information, employment-related information, and financial information.
• Ensuring compliance with applicable laws and regulations. We may use your contact information and financial information.
• Verify your eligibility to access certain products, services, or data that may be provided only to licensed HCPs or others conducting background checks to ensure that it is permissible for SQ Innovation to work with you. The types of personal data Processed may vary.
• Responding to legal inquiries, requests, and summons. We may use your contact information, employment-related information, financial information, contractual information, and other information.

Due to the nature of our business, SQ Innovation may be subject to several legal requirements, thus requiring SQ Innovation to process personal data and sensitive information (including health information and mental and physical characteristics) to meet these requirements. If you fail to provide requested data for the purposes described above, SQ Innovation’s request(s) for data and your failure to provide the requested data may be communicated to relevant authorities.  When permissible under the law, we will attempt to limit and protect the Processing of your personal data to the extent possible, for example, by pseudonymizing information, while still complying with our legal obligations. To the extent applicable, SQ Innovation will reasonably rely on the authority of HCPs and any other individuals to act on your behalf. The Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 C.F.R. §164.512(b) allows health professionals to release information concerning adverse events/side effects to pharmaceutical companies.

If SQ Innovation intends to further process your personal data for a purpose other than that for that which it was collected, we will provide you with information on that other purpose and the details outlined in Section 7 and 9 of this notice as it applies to the other purpose for which the data will be used.

5. Who do we share your personal data with?

SQ Innovation may share your personal data:

• with people within the company who have a “need to know” that data for business or legal reasons (e.g., to direct a query that you have submitted to the relevant person within SQ Innovation);
• with third parties, vendors and service providers, including SQ Innovation’s advisors, suppliers of IT services and third parties engaged by SQ Innovation, under the legal bases set out above;
• with business partners, including but not limited to research collaborators, co-developers, co-promotors, and co-licensors;
• with a third-party related to a business transfer, including not limited to, as part of a sale, assignment, or transfer of a SQ Innovation business or asset, or an acquisition of or merger with another entity. We may also share your personal data in contemplation of such transactions, such as due diligence.
• with government or law enforcement agencies (where required or permitted by applicable laws, court orders, or government relations);
• with third parties to protect rights and interests, including when needed for audits, investigations, or to respond to inquiries/complaints, etc., and
• with your consent or as directed by you.

6. Transfers of personal data

Some of our affiliates, subsidiaries and third parties to whom we transfer personal data are located outside the European Union. To ensure your personal data will still be processed in compliance with our standard of data protection and applicable law, SQ Innovation has implemented EU Standard Contractual Clauses between its entities as well as with third parties and has taken additional safeguards such as encryption of the data in transfer. You can ask for more information on the safeguards implemented by SQI by email to info@sqinnovation.com. 7. How long do we retain your personal data?

Your personal data is not kept for longer than is necessary for the purposes for which it is collected, unless a longer period is required to comply with applicable laws and regulations. To determine appropriate retention periods, we assess the personal data type and nature, the Processing involved, our interaction with you, and any other legal obligations. Data and records (including personal data) are deleted from our systems when no longer required. Please contact us at info@sqinnovation.com if you would like more information on applicable retention periods.

8. How do we secure your personal data?

Securing your personal data is very important to SQ Innovation, which is why we maintain privacy and security measures and controls designed to help protect your personal data. No security measure, however, is 100% effective, and we cannot guarantee total security of your personal data. Please take steps to protect yourself, including using and protecting your unique login credentials and passwords, utilizing encryption, personal firewalls, and anti-virus solutions.

9. Your rights

Many jurisdictions, including the European Union and certain U.S. States, afford data subject rights. You may exercise the rights applicable to you by emailing us at info@sqinnovation.com (this email reaches SQ Innovation’s Data Protection Officer). At this time, SQ Innovation does not reach the threshold compliance levels for any applicable U.S. State Consumer Privacy laws. If any U.S. State Consumer Privacy Law becomes applicable to SQ Innovation, we will comply permitting consumer privacy rights and honor requests according to applicable laws. Depending on your jurisdiction, your rights may include the following:

• You may opt out of communications from us at any time by following any UnsuSQIribe or opt-out instructions in the communication, including selecting the unsuSQIribe link. We may still need to send you important administrative messages even if you opt out of receiving communications.
• To the extent provided for under applicable law, you may request a copy of the personal data that we hold about you, access to, rectification of, opt-out of, deletion of, restrict, object to, or limit the processing of your personal data;
• You may also request to obtain a portable copy of your personal data;
• In addition, you may at any time withdraw your consent without any legal effect impacting you at any time.
• You have the right to lodge a complaint regarding data privacy with a supervisory authority. In the European Union, this authority is the European Data Protection Supervisor (EDPS).
• We do not sell Personal data as the term “sell” is traditionally understood or defined as a “sale” or “sharing” under applicable California Privacy law. We do not knowingly sell the Personal data of consumers under 16 years of age.
• Automated decision making: SQ Innovation does not engage in any Automated Decision making.

You have a right to obtain confirmation as to whether or not your personal data is being processed and, if so, information regarding the data as outlined in Sections 2, 3, 5, 7, and 9 of this notice and the identity of any individuals or organizations to whom the data was transferred.

Please submit your written request to info@sqinnovation.com; however, we cannot guarantee that we will be able to provide every right or continue certain activities after respecting your request.

Verification: When you make a request, please provide your full name (first and last name), email address, city, and state of residence, and which of the rights (s) described above that you are requesting. We will verify your request against our records. We cannot fulfill any unverified or incomplete requests.

We do not and will not discriminate against you for exercising your data subject rights, however, we cannot guarantee that all services and features will be available and will not be impacted because of your request.

You may designate an authorized agent to request data subject rights on your behalf by providing a signed and authenticated letter that identifies (i) your agent and (ii) the purposes for and nature of your appointment of an agent. If you are an authorized agent, you must provide the information described in “Verification” hereinabove about the consumer for which you are acting as an agent, as well as your full name (first and last name), email address, and a letter, signed by the consumer, that appoints you as their agent. In some instances, we may decline to honor your request if an exception applies under applicable law, however, we will respond to your request in compliance with applicable law.

 

10. Questions and complaints

If you have a concern or complaint about how SQ Innovation has used your personal data, as a first step, you should raise this in writing with SQ Innovation. Please see the Contact page on our Website or contact us at

SQ Innovation
ATTN: Legal
20 Burlington Mall Road, Suite 220

Burlington, Massachusetts 01803
Email: info@sqinnovation.com

If you are not satisfied with the handling of your concern or complaint by SQ Innovation, you can escalate this to your national Supervisory Authority, if applicable – available here.

11. Cookies

Cookies and other tracking technologies can be used for the following purposes:

• A cookie is a small data file that a website may write to and sometimes store on your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited. A cookie cannot read data from your hard disk or read cookie files created by other websites. Your browsers may be set up to automatically accept cookies, however, you can change your browser settings at any time to deny all cookies or specific types of cookies. Please note that if you deny certain cookies, the websites that you visit might not be fully functional.
• A web beacon allows website providers to see what you have accessed on the website.

The SQ Innovation Website leverages IPAnalytics to help measure, collect, analyze, and report on the Website’s usage to better optimize and enhance the Website or to understand user preferences. We use IPAnalytics to track user traffic patterns and to provide a better service for users when they visit the website.

Users can set their browsers to provide notification when a cookie is received, and the opportunity to accept or reject the cookie. Users can also refuse all cookies by turning the function off in their browsers. However, to ensure the full functionality of the SQ Innovation Website, the use of cookies is required.

Do Not Track Signals: At this time, we do not respond to browser ‘do not track’ signals. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit the Website. To learn more about how to exercise your choice regarding the collection of information about your online activities over time and across third-party websites or online services by visiting http://www.aboutads.info/ and http://www.networkadvertising.org/ack’ signals.

12. Links to Other Websites

Our Website may contain links to other websites of interest. However, once you have used these links, you will have left our Website. Please note that we do not have any control over that other website, their privacy policies, or practices. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites, and such sites are not governed by this Notice. You should exercise caution and look at the privacy statement applicable to the website in question.

13. Personal data related to Minors

It is not SQ Innovation’s intent to Process personal data related to individuals under 18 (“Minors”). If we determine that we have or are Process personal data related to Minors, we will seek the consent of their parent or guardian or will take reasonable steps to delete the personal data, as permitted by applicable laws.

14. Updates

We may change this Notice at any time and without notice. Please check back regularly to stay up to date with the most recent version.

Last updated: June 2025