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Privacy Policy

Last updated: December 19, 2025

Introduction

This Privacy Policy provides information about how Arcturus Therapeutics Holdings Inc. (“Arcturus,” “Company,” or “We”) collects, uses, maintains, protects, and discloses information capable of identifying an individual (“Personal Information”), and information about your rights and choices regarding our processing of your Personal Information.

This Privacy Policy applies to all visitors to one or more of our websites (arcturusrx.com, lunarcf.com, and/or otcmrnastudy.com, each of which is referred to in this Privacy Policy as the “Website”), to online services provided by us that contain a link to this Privacy Policy, and to other forms of communication between you and Arcturus.

This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or otherwise provide us with your Personal Information. By accessing or using this Website, you agree that we may collect, use, share and/or disclose Personal Information in accordance with the terms of this Privacy Policy, subject to your rights and our obligations under applicable law. This Policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of this Website after we make changes is deemed to be an acceptance of those changes, so please check the Policy periodically for updates.

This Privacy Policy does not apply to Personal Information relating to job applicants or our employees, who will be provided a separate privacy notice where required by applicable law.

Information We Collect About You and How We Collect It

We collect several types of Personal Information through registrations, applications, surveys, support or information requests, or other data capturing processes, including:

  • Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and other information by which you may be contacted online or offline, and/or
  • Information about your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you or your agent.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
  • From affiliates or third parties that interact with us; and/or
  • From publicly available information.

We may combine information we have about you with information obtained from public sources.

Personal Information You Provide to Us

The Personal Information we collect may include:

  • Information that you provide by filling in forms on our Website.
  • Records and copies of your correspondence (including email addresses), if you contact or otherwise correspond with us.

If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use that Personal Information in accordance with this Privacy Policy.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and use our Website or interact with our emails, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns as part of the standard operation of the Website, including:

  • Details of your visits to our Website, including traffic data, location data, logs, date/time of access, data transferred, pages visited, amount of time you spend on the Website, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. If you access the Website using a mobile device, the device ID or IP address may be recorded and used for purposes similar to those of cookies. For more information about cookies and how to manage them, please see our Cookie Policy here: https://arcturusrx.com/cookie-policy/.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Your Privacy Choices” below.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some of the cookies and other technologies we use for automatic data collection are provided by third parties to support our analytics, Website improvement and/or marketing efforts. These third party tools include:

Google Analytics may collect information about your use of the Website. Google Analytics uses cookies to provide information about visits to our Website, including number of visitors, the websites from which visitors have navigated to our Website, and the pages on our Website to which visitors navigate. More information on Google Analytics can be found in the “Privacy & Terms” section of the Google website.

We also contract with third party advertising networks that collect IP addresses and other information from pixel tags or web beacons on our Website, in our emails, and/or on third party websites. These networks use cookies and other device and usage data in order to recognize individuals who have previously visited a particular website. This information is used to measure advertising effectiveness and provide advertisements about our products or services tailored to your interests.

When you visit the Website or interact with us in other ways, you can refuse to supply Personal Information. However, this may prevent you from engaging in certain Website-related or other activities.

How We Use Your Personal Information

This section describes the purposes for which we use the Personal Information we collect about you or you provide to us. Please note that there may be other uses, which we would describe to you when we collect the Personal Information.

To contract with you

We may use the Personal Information you provide us to help us fulfill a contract with you, when you use our Website under the applicable Terms of Use, and for other contractual purposes. We may also use this information to enforce our rights arising from such contracts.

Our legitimate business interests

We process your Personal Information to pursue our legitimate business interests, including to:

  • Understand you and your preferences to enhance your experience and enjoyment using our Website;
  • Operate, maintain, and improve the content, design and navigation of our Website;
  • respond to comments and questions, provide requested services and information, and otherwise communicate with you;
  • Develop and deliver our products and services;
  • Fulfill any other purpose for which you provide Personal Information;
  • Comply with regulatory monitoring and reporting obligations;
  • Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
  • Study website traffic patterns, detect and correct technical errors, and
  • Protect against, identify, investigate and respond to fraudulent, unauthorized, or illegal activity (such as incidents of hacking or misuse of our Website) and claims and other liabilities.

To the extent permitted by applicable law, we may combine the various types of data we collect. We use this combined information to identify, update, expand, and analyze business opportunities. Such analysis may be conducted through third party services, using anonymous data and aggregate statistics generated by our information collection. We may use aggregate and/or de-identified data about visitors to our Website for various business purposes, including development and improvement activities.

Consent

We may use your Personal Information when we have your consent to do so, where required or permitted under applicable law. If we are using your Personal Information on the basis of consent, you may withdraw your consent at any time (which will not affect the lawfulness of the processing before consent was withdrawn, or as otherwise agreed in writing) by contacting us at [email protected].

Compliance with Legal Obligations

We reserve the right to use your Personal Information (i) as required by law, court order, legal process or government or regulatory requirement; (ii) to respond to a request from public or government authorities; or (iii) to protect the safety, rights, or property of the public or our company.

Disclosure of Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business or to perform functions on our behalf. Third party service providers may use Personal Information we provide to them only as instructed by us.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Arcturus’ assets pursuant to the terms of the transaction, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Arcturus is among the assets transferred.
  • To fulfill the purpose for which you provide the Personal Information.
  • For any other purpose disclosed by us when you provide the Personal Information.
  • Upon your request, or with your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Arcturus, our business partners, or the public.

We do not rent or sell your Personal Information to a third party for monetary consideration.

When you attend a conference, trade show, or event (either sponsored by us or one where we are a participating vendor) and register or have your badge scanned, your Personal Information will be shared with us, as well as with any partner or third party participating in that event. If you do not want your Personal Information shared with us, any partner or third party in this manner, do not have your badge scanned. If your badge is scanned by a partner or third party at an event your information will be governed by that party’s privacy policy.

Your Privacy Choices

We strive to provide you with choices regarding the Personal Information you provide to us. You may update your Personal Information and your preferences, or request that we delete your Personal Information, by contacting us at [email protected]. Our response to such requests will be limited to information under our direct control, consistent with applicable law. Please note that we may need to retain certain Personal Information for recordkeeping purposes and/or to fulfill any pending request.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Security

Please note that any information you send to Arcturus via email, in a sign-up form on the Website or via the Internet is not completely secure. We take reasonable steps to protect Personal Information provided via our Website from loss, misuse and unauthorized access or disclosure, however, no Internet or e-mail transmission is ever fully secure or error free. Due to the nature of the Internet, there is a possibility that unsecured (unencrypted) email or Internet transmissions could be intercepted and read by third parties. Arcturus assumes no responsibility for interception of confidential information or Personal Information (including in a resume or CV or a sign-up form) that you send in an unsecured (unencrypted) email message or other Internet transmission to and from this Website. Therefore, you should take special care in deciding what information you send to us via e-mail, in a sign-up form or via other Internet transmission. DO NOT SEND INFORMATION RELATING TO YOUR MEDICAL CONDITIONS OR THOSE OF A FAMILY MEMBER OR ANY OTHER PERSONAL HEALTH INFORMATION VIA OUR WEBSITE, AS OTHER PERSONAL HEALTH INFORMATION VIA OUR WEBSITE, AS ARCTURUS CANNOT BE RESPONSIBLE FOR PERSONAL HEALTH INFORMATION SENT THROUGH OUR WEBSITE. Please keep this in mind when disclosing any Personal Information to Arcturus via the Internet.

Data Retention and Access

We retain Personal Information or as long as needed or permitted in light of the purpose(s) for which it was obtained and as described in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is an applicable legal obligation; and/or (iii) whether retention is advisable to enforce our agreements, satisfy applicable statutes of limitations, resolve disputes, or manage litigation or regulatory investigations.

Links to Third Party Websites

This Privacy Policy applies only to websites owned or controlled by Arcturus. Our Website may contain links to other sites that are owned or controlled by third parties. Please be aware that we are not responsible for the privacy policies of such other sites or how these sites operate or treat your Personal Information. We encourage you to be aware of this when you leave our website and to read the privacy policies and terms of use associated with each of these third party websites that collect personally identifiable information.

International Data Transfers and Processing

Any Personal Information you provide to Arcturus and that Arcturus shares with affiliates, agents, vendors and service providers, may be stored and processed, transferred between and accessed from the United States and other countries, which may not guarantee the same level of protection of Personal Information as the country in which you reside. However, Arcturus will handle Personal Information in accordance with this Privacy Policy, and in compliance with applicable law.

Children’s Privacy

Our Website is not directed to children (individuals under the age of 18). We do not knowingly collect, maintain or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the Personal Information.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy from time to time without prior notice to reflect technological developments, legal and regulatory changes, and our business practices, subject to applicable laws. If we change our Privacy Policy, we will post the revised policy on our Website, and we will update the date at the top of this Privacy Policy. Any revisions to the Privacy Policy will become effective when posted. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you.

Information for European, United Kingdom, and Switzerland Residents

Arcturus Therapeutics, Inc., 10285 Science Center Drive, San Diego, CA, 92121, USA, is the controller of your Personal Information (also commonly referred to as “personal data”) as described in this Privacy Policy, unless specified otherwise.

If you are in the European Economic Area, United Kingdom, or Switzerland, your Personal Information may be protected by the European Union General Data Protection Regulation, United Kingdom Data Protection Act, or the Swiss Federal Act on Data Protection (collectively, “European Privacy Laws”). If your Personal Information is protected by the European Privacy Laws, you are entitled to certain rights related to your Personal Information. You have the right to access the Personal Information we have collected about you, the right to correct any inaccurate Personal Information we may have collected about you, and the right to supplement any incomplete Personal Information we may have collected from you. In certain circumstances, you have the right to the deletion or removal of your Personal Information, the right to restrict the processing of your Personal Information, the right to obtain and transmit your Personal Information to a third party, and the right to object to the way your Personal Information is being used (including when your Personal Information is processed for direct marketing purposes, or when your Personal Information is processed based upon our legitimate interests).

If you wish to exercise these data privacy rights, or if you have questions or concerns about how we use your Personal Information, please contact us at [email protected] and we will make efforts to respond to your questions and/or resolve any issues consistent with applicable law. For your protection, when you seek to exercise the rights described above, it will be necessary for us to verify your identity or authority to make the request and confirm that the Personal Information relates to you.

If we are using your Personal Information based on your consent, you may withdraw this consent at any time. Your withdrawal of consent does not impact the lawfulness of our processing up to the point of consent withdrawal, or as otherwise agreed in writing.

Please note that there are exceptions to the various rights listed above. As an example, in the context of a deletion request, in certain circumstances we may have a legal obligation to retain some of your Personal Information.

Our Data Protection Representative for purposes of compliance with the European Privacy Laws is MyData-TRUST. If you want to raise a question or concern relating to data privacy involving Arcturus, or otherwise exercise your rights with respect to your Personal Information, you may contact them as follows:
MyData-TRUST SA
Avenue Lavoisier 18B – 1300 Wavre (BELGIUM)
[email protected]

If you have a data privacy or data use concern that you feel has not been fully addressed, you also have the right to lodge a complaint regarding use of your Personal Information with the applicable data protection authority. A list of the European Union data protection regulatory authorities can be accessed here: https://edpb.europa.eu/about-edpb/board/members_en. The data protection authority for the United Kingdom can be reached via the following link: https://ico.org.uk. The Swiss data protection authority can be reached at: https://www.edoeb.admin.ch/edoeb/en/home.html

Information for Residents of California, Other U.S. States (where applicable):

This section describes how we collect, use and share your Personal Information where it is subject to the California Consumer Privacy Act 2018, as amended (“CCPA”), and, where applicable, data privacy laws similar in scope and content to the CCPA in effect in other US states (“State Data Privacy Laws”). This section also describes your rights with respect to your Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA and/or applicable State Data Privacy Laws, and generally means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to a consumer or device.

Please note that this section does not apply to information exempted from the scope of the CCPA or other applicable State Data Privacy Laws. This section does not apply to Personal Information relating to our employees, job applicants, and contractors, who will receive a separate privacy notice from us where required by law.

We collect the following categories of Personal Information: (i) identifiers such as name, address, IP address, and other similar identifiers; (ii) Personal Information described in subdivision (e) of Section 1798.80 (California customer records statute) such as a name, address, telephone number, credit card number; (iv) internet/electronic activity such as browsing history and search history; (v) professional information such as job title and expertise; (vii) professional or employment-related information; and (viii) audio, video, electronic or other similar information.

We have disclosed these categories of Personal Information for a business purpose within the last 12 months (see “Disclosure of Your Personal Information” above for the categories of third parties with which Personal Information is shared, and “How We Use Your Personal Information” for a description of the business purposes for which Personal Information is collected and used).

We obtain the Personal Information collected from the following categories of sources: directly from you or your agent; directly and indirectly from the Website; from affiliates or third parties that interact with us; and/or from publicly available information. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice and/or obtaining your consent where required by law.

See the section entitled “Data Retention and Access” above for a description of the criteria used to determine how long we retain Personal Information. We do not use or disclose sensitive Personal Information (as defined in and subject to the CCPA) for purposes other than those specified in CCPA Regulations Section 7207(m).

Where provided for under applicable law, you are entitled to certain rights relating to your Personal Information, subject to certain exceptions, including the right to:

  1. Obtain a copy of your Personal Information in our possession, or to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, sharing or selling the Personal Information (where applicable), the categories of third parties with whom we have shared or sold your Personal Information and the purpose for which we shared or sold your Personal Information (where applicable), and information about the specific pieces of Personal Information we have collected about you.
  2. Request that we correct in our records any Personal Information about you that is inaccurate.
  3. Request the deletion of Personal Information that we collected about you and retained, subject to certain exceptions.
  4. Opt out of the sale or sharing of your Personal Information with third parties for targeted advertising purposes, where such a “sale” or “sharing” is occurring (as such terms are defined by applicable law).
  5. Limit the use or disclosure of your sensitive Personal Information (as defined in and subject to the CCPA) where collected and as permitted under applicable law.

You can exercise these rights up to twice within a 12 month period. To do so, contact us at [email protected] or call (858) 900-2660. For your protection, when you seek to exercise the rights described above, it will be necessary for us to verify your identity or authority to make the request and confirm that the Personal Information relates to you. We will verify your identity by asking you to provide identifying information that we will match to information in our records. Only you or a person that you authorize in writing to act on your behalf may make a verifiable consumer request related to your Personal Information. You (or your authorized agent) must provide documentation signed by you demonstrating that the agent is authorized to submit a verifiable Personal Information request on your behalf.

We will endeavor to respond to a verifiable consumer request in the timeframe prescribed by applicable State Data Privacy Laws, typically within 45 days of receipt. Please note that your right to deletion of Personal Information is subject to certain exceptions by law. If you submit a request for deletion and we retain any Personal Information under one or more of these exceptions, we will explain this to you in our response. In accordance with your rights under State Data Privacy Laws, we will not discriminate against you for exercising your privacy rights. We do not charge a different price or rate or provide a different level of product or service quality based on you exercising your privacy rights.

In US states other than California (and other jurisdictions) with similar data privacy regulations, where applicable, we may collect from you the categories of Personal Information described above. We collect and manage (including disclose) Personal Information in compliance with applicable local laws and regulations. We do not use your Personal Information for automated decision making or profiling.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at [email protected] or as follows:

Arcturus Therapeutics, Inc.
Attn: Chief Legal Officer
10285 Science Center Drive
San Diego, CA 92121
(858) 900-2660