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PRIVACY POLICY

Last updated: March 2026

This privacy notice for Ulysses Neuroscience Ltd (‘Company’, ‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you:

  • Visit our website at https://ulysses-neuro.com, or any website of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Ulysses Neuroscience Ltd (company registration number: 646226, registered address: Pioneer Life Sciences Cherrywood, Building 10, Cherrywood Business Park, Loughlinstown, Co. Dublin, D18 W5P1, Ireland) is the data controller responsible for your personal information processed through this website and our related services. As a company established in Ireland, we are subject to the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and the Irish Data Protection Acts 1988–2018.

We have not appointed a formal Data Protection Officer (DPO) as we do not meet the thresholds requiring mandatory appointment under Article 37 GDPR. For all data protection enquiries, please contact us using the details in Section 13 of this notice.

 

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Ulysses Neuroscience Ltd and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us directly. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • job title and company name

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in Section 5 of this notice.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm

We also process your information for the following purposes:

  • To respond to and manage enquiries submitted through our website contact forms or via email.
  • To manage client and prospect relationships using our CRM platform (HubSpot), including sending service-related communications and scheduling calls or meetings.
  • To deliver, operate, and improve our website, including through analytics tools that help us understand how visitors use our Services. Analytics cookies are only deployed after your consent has been obtained.
  • To identify company-level visitors to our website using the Leadinfo B2B lead generation service. This service processes IP addresses to match them against publicly available company data. No individual personal data beyond IP address is used, and IP addresses are not retained after processing.
  • To communicate with you about our services, scientific capabilities, publications, and events where we have a legitimate interest in doing so, or where you have provided your consent.
  • To fulfil contractual obligations arising from research service agreements or other contracts with clients and partners.
  • To comply with legal and regulatory obligations applicable to Ulysses Neuroscience Ltd, including obligations under Irish law and any applicable sector-specific regulations (e.g., HPRA requirements related to our licensed activities).

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We also rely on the following legal bases:

  • Legitimate Interests. We may process your information when it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include: responding to business enquiries, managing our CRM and prospect relationships, maintaining professional networking activities (e.g. LinkedIn), identifying company-level website visitors (Leadinfo), and improving our website and services. You have the right to object to processing based on legitimate interests — see Section 9.
  • Performance of a Contract. We may process your information where it is necessary to perform a contract we have with you or to take steps at your request prior to entering into a contract, including the delivery of contracted research services.

If you are located in Canada. We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time by contacting us.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Third-Party Data Processors

We engage the following third-party service providers who process personal data on our behalf as data processors. Each processor is bound by a data processing agreement (DPA) and is required to implement appropriate technical and organisational security measures:

Processor / Purpose Location / Safeguard

HubSpot, Inc./ CRM, contact forms, meeting scheduling, email marketing / USA — EU-US Data Privacy Framework

Leadinfo B.V. / B2B website visitor identification (IP-based, company-level only)/ Netherlands -Servers in Ireland (AWS EMEA, Luxembourg) — EEA

WordPress – WP Engine / Website hosting and content management / USA — Standard Contractual Clauses (SCCs)

LinkedIn Ireland Unlimited Co. / Professional networking, LinkedIn pages / Ireland (EEA) — GDPR applies directly

CookieYes Cookie / consent management / Ireland (EEA) — GDPR applies directly

We do not sell your personal information to third parties. We do not share your data with third parties for their own direct marketing purposes without your explicit consent.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Cookie Management & Consent

We use a cookie consent management platform (CookieYes) to manage your cookie preferences. When you first visit our website, you will be presented with a consent banner allowing you to accept, reject, or customise cookie categories. We use the following categories of cookies:

  • Strictly Necessary Cookies: Required for the website to function and cannot be switched off. No consent is required for these.
  • Functional Cookies: Enable enhanced functionality such as embedded scheduling tools (e.g. HubSpot meetings). Only activated with your consent.
  • Analytics Cookies: Allow us to measure and improve the performance of our website. Only deployed after your explicit consent.
  • Marketing/Targeting Cookies: Used to deliver relevant content through platforms such as LinkedIn. Only activated with your consent.

You can change or withdraw your cookie consent at any time by clicking the ‘Cookie Settings’ link in the footer of our website, or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our Services.

Leadinfo Tracking: We use the lead generation service provided by Leadinfo B.V., Rotterdam, The Netherlands, which recognises visits of companies to our website based on IP addresses and shows us related publicly available information, such as company names or addresses. In addition, Leadinfo places two first-party cookies for providing transparency on how our visitors use our website. IP addresses are not retained after processing. For further information, please visit www.leadinfo.com. You may opt out at: www.leadinfo.com/en/opt-out.

 

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our primary website is hosted within the European Economic Area (EEA). However, some of the third-party service providers we use are based outside the EEA, principally in the United States. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), these countries may not have data protection laws as comprehensive as those in your country.

Where personal data is transferred outside the EEA, we ensure appropriate safeguards are in place as required by Chapter V of the GDPR:

  • Standard Contractual Clauses (SCCs): We rely on the European Commission’s approved SCCs where a third-party processor is based in a country without an adequacy decision.
  • EU-US Data Privacy Framework: Certain US-based processors (including HubSpot) participate in the EU-US Data Privacy Framework, which provides an adequacy basis for transfers to the United States.
  • EEA-based processors: Processors such as Leadinfo (servers in Ireland via AWS EMEA Luxembourg), LinkedIn Ireland, and CookieYes are EEA-based and GDPR applies directly.

You may request further information about the specific safeguards in place for any particular transfer by contacting us using the details in Section 13.

 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in Section 13 below.

We will consider and act upon any request in accordance with applicable data protection laws.

Irish Supervisory Authority

As Ulysses Neuroscience Ltd is established in Ireland, our lead supervisory authority for GDPR purposes is the Data Protection Commission of Ireland (DPC). If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the DPC:

  • Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
  • Website: www.dataprotection.ie
  • Online complaint form: https://forms.dataprotection.ie/contact

You also have the right to lodge a complaint with the supervisory authority in your country of residence or place of work if different from Ireland. A list of EU supervisory authorities is available at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. For Switzerland: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us. Please note this will not affect the lawfulness of processing before its withdrawal.

Opting out of marketing communications: You can unsubscribe from our marketing and promotional communications at any time by contacting us using the details in Section 13. You will then be removed from marketing lists. However, we may still send service-related messages necessary for the administration of your relationship with us.

Cookie preferences: Most web browsers are set to accept cookies by default. You can choose to set your browser to remove or reject cookies, or adjust your preferences via the Cookie Settings link in our website footer. This could affect certain features or services.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section 13.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the information provided in Section 13.

CCPA Privacy Notice

Under the California Code of Regulations, a ‘resident’ includes every individual who is in the State of California for other than a temporary or transitory purpose, and every individual domiciled in the State of California who is outside the State for a temporary or transitory purpose. All other individuals are defined as ‘non-residents’.

If this definition of ‘resident’ applies to you, we must adhere to certain rights and obligations regarding your personal information, including the right to request deletion, the right to be informed, the right to non-discrimination for the exercise of privacy rights, and the right to limit use and disclosure of sensitive personal information (we do not process sensitive personal information).

We will not discriminate against you if you exercise your privacy rights. We may verify your identity before fulfilling a request. To exercise these rights, or to appoint an authorised agent to make a request on your behalf, please contact us using the details in Section 13.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Last updated’ date and will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email or by post:

Ulysses Neuroscience Ltd

Pioneer Life Sciences Cherrywood
Building 10, Cherrywood Business Park
Loughlinstown, Co. Dublin
D18 W5P1
Ireland
E: [email protected]
T: +353 (87) 600 4092

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at [email protected] or by post at the address provided in Section 13.

We will respond to your request within 30 days of receipt, in accordance with applicable data protection law. In some cases we may need to extend this period, in which case we will notify you.

Ulysses Neuroscience Ltd  •  Privacy Notice  •  Company Reg. No. 646226  •  March 2026