HIPAA NOTICE OF PRIVACY PRACTICES

Effective Date: July 30, 2018

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

In this Notice of Privacy Practices, we at Adaptive Biotechnologies Corporation, its subsidiaries and affiliates (“Adaptive,” “we” or “us”), explain our practices regarding the use and disclosure of medical and other personal information about you that we collect in conjunction with our clinical laboratory businesses, such as our clonoSEQ® service, and your rights relating to that information.

 

OVERVIEW

Your Rights
You have the right to:

• Get a copy of your medical record
• Correct your medical record
• Request confidential communications
• Ask us to limit the information we use or share
• Get a list of those with whom we’ve shared your information for certain purposes
• Get a copy of this privacy notice
• Choose someone to act for you
• Ask questions
• File a complaint if you believe your privacy rights have been violated

Your Choices
You have some choices in the way that we use and share information, such as how or whether we:

• Tell family and friends about your condition
• Provide information so that you may be located or rescued
• Engage in sales and marketing activities

Our Uses and Disclosures
We may use and share your information for various reasons, such as when we:

• Provide clinical laboratory services for you
• Run our organization
• Bill for testing services
• Help with public health and safety issues
• Do research under certain conditions
• Work with a coroner, medical examiner, or funeral director
• Comply with the law
• Address workers’ compensation, law enforcement, and other government or judicial requests
• Respond to lawsuits and legal actions

Each of the topics above is discussed in greater detail below.

YOUR RIGHTS
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you. In each case, if you have questions about how to exercise your rights, please email us at privacy@adaptivebiotech.com.

Get an electronic or paper copy of your medical record
• You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you.
• We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee for any copy or summary.

Ask us to correct your medical record
• You can ask us to correct health information about you that you think is incorrect or incomplete.
• We may say “no” to your request, but if we do, we’ll tell you why in writing within 60 days.

Request confidential communications
• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
• We will say “yes” to all reasonable requests.

Ask us to limit what we use or share
• You can ask us not to use or share certain of your health information. Except as noted just below, we are not required to agree to your request, and we may say “no” if it would affect your care or for other justifiable reasons.
• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share with your health insurer any information about your receipt of that service or health care item. We will say “yes” unless a law requires us to do otherwise.

Get a list of those with whom we’ve shared information
• You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include in that list all disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting per year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice
• You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you
• If you have given someone medical power of attorney or if someone is your legal representative or guardian (or, in some cases, if someone is an administrator, executor, or other authorized person responsible for your estate), that person can exercise your rights and make choices about our uses and disclosures of your health information.
• If you are an unemancipated minor, your parent or legal guardian may exercise your rights and make choices about our uses and disclosures of your health information on your behalf.
• We will do what we can to make sure that any person who purports to be your legal representative has this authority before we take any action as directed or authorized by that person.

Ask questions
• You can ask questions about this notice and your rights at any time. Please contact our Customer Service Department or email us at privacy@adaptivebiotech.com.

File a complaint if you feel your rights are violated
• You can complain if you feel we have violated your rights by contacting us either by mail at Adaptive Biotechnologies Corporation, Attn: Privacy Officer, 1551 Eastlake Avenue East Suite 200, Seattle, Washington 98102, or by email at privacy@adaptivebiotech.com.

• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting http://www.hhs.gov/ocr/privacy/hipaa/complaints

• We will not retaliate against you for complaining to us or filing a complaint.

 

YOUR CHOICES
In certain circumstances, you have the right to choose when and how much of your health information we may share. If you have a clear preference for how we share your information in any of the situations described below, please email us at privacy@adaptivebiotech.com. Tell us what you want us to do, and we will follow your instructions regarding the choices described below.

You have the right to tell us to:

• Share information with your family, close friends, or others involved in your care or payment for your care
• Share information with a disaster relief organization or others in order to help notify a person involved in your care about your location, condition, or vital status
• Share information with organ procurement organizations or related entities for the purpose of facilitating organ or tissue donation and transplantation

If you are not able to tell us your preference, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In the cases below, we are prohibited from sharing your personal health information unless you give us written permission:

• Disclosure to third parties for marketing purposes
• Sale of your information, although as we continue to develop our business, we might sell or acquire subsidiaries, affiliates or business units. In such transactions, health records information generally is one of the transferred business assets. Also, in the unlikely event that Adaptive or substantially all of its assets are acquired, health records will of course be one of the transferred assets.

 

OUR USES AND DISCLOSURES
In accordance with applicable federal and state law, we typically use or share your health information in the following ways.

Providing clinical laboratory services for you
We can use your health information and share it with other professionals who are treating you.

Example: Discussions of the minimal residual disease result with your treating physician.

Run our organization or help your health care provider run their organization
We can use and share your health information to run our laboratory, develop and improve our services to improve your care, and contact you when necessary. We can also share your health information with your health care provider to help them run their business, such as to process claims for payment for services they provide to you or to conduct quality control.

Example: We share health information about you with our third party service providers to manage our business, for example helping us process your test orders and helping us securely store your information.

Bill for your services
We can use and share your health information to bill and get payment from health plans or other entities.

Example: We may give information about you to a third party billing business associate to forward to your health insurance plan so it will pay for the services you received.

Help with public health and safety issues
We can share health information about you for certain situations such as:

• Preventing disease
• Participating in public health investigations
• Helping with product recalls
• Reporting adverse reactions to medications or certain other injuries
• Reporting suspected abuse, neglect, or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety

Do research
We may maintain certain of your information in certain databases, which may be used or accessed by individuals within our organization for research purposes. We can use or share your information for health research (1) if we have obtained your signed authorization or (2) if we have received approval from an Institutional Review Board or Privacy Board to conduct the research without your express authorization. We can also use your information without your signed authorization to prepare for research, such as to prepare a research protocol, or share it for those purposes. We generally may share information for research purposes about anyone who is deceased without the deceased’s signed authorization.

Work with a coroner, medical examiner, or funeral director
We can share health information about an individual with a coroner, medical examiner, or funeral director when the individual dies.

Address workers’ compensation, law enforcement, and other government requests
Subject to certain limitations, we can use or share health information about you:

• For workers’ compensation claims or benefits
• For law enforcement purposes or with a law enforcement official
• With health oversight agencies for activities authorized by law
• For special government functions such as military, national security, and presidential protective services

Comply with the law
We will share information about you if state, federal or national laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

Respond to lawsuits and legal actions or proceedings
We can share health information about you in response to a court or administrative order, or in response to a subpoena or other lawful process.

How else can we use or share your health information?
We are allowed or required to share your information in other ways and to other individuals–often in ways that contribute to the public good, such as public health or for law enforcement purposes. For more information see: http://www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html

We may not use or share your information other than as described in this notice without your written authorization. If you do provide such authorization, you may revoke that authorization, in whole or in part, at any time. You must send us your revocation in writing.

 

OUR RESPONSIBILITIES
We are required to:

• Maintain the privacy and security of your personal health information in accordance with applicable law;
• Provide you with this notice of our legal duties and privacy practices with respect to your personal health information;
• Notify you if a breach occurs that may have compromised the privacy or security of your personal health information; and
• Adhere to the duties and privacy practices described in this notice and give you a paper copy of the notice upon your request..

For more information see: http://www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html

 

CHANGES TO TERMS OF THIS NOTICE
We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.

 

OTHER INSTRUCTIONS FOR NOTICE
Adaptive’s U.S. Privacy Officer and International Data Protection Officer is
Kate Godfrey, Vice President, Compliance and Privacy Officer, who can be reached by mail at
1551 Eastlake Avenue East, Suite 200,
Seattle, Washington 98102,
by telephone at (206) 693-2227 or by email at privacy@adaptivebiotech.com.

PRIVACY SHIELD PRIVACY POLICY

Effective Date: October 4, 2018

This Privacy Shield Privacy Policy applies to Personal Data (as defined below) transferred from countries that are members of the European Union (EU) or from Switzerland to Adaptive Biotechnologies Corporation (“Adaptive” or “we” or “us”) in the United States in reliance on the EU-U.S. Privacy Shield Framework or the Swiss-U.S. Privacy Shield Framework, respectively. To learn more about the Privacy Shield Framework, please visit https://www.privacyshield.gov/.

The scope of this Policy is distinct from other privacy policies that Adaptive maintains, including the Adaptive Online Privacy Policy, and Adaptive’s HIPAA Notice of Privacy Practices (applicable to health information that we collect in conjunction with our clinical laboratory businesses). Please refer to those other privacy policies to learn about our treatment of Personal Data collected in those other contexts.

Adaptive has certified with the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. For more information about these Principles, or how to enforce your rights, please contact: privacy@adaptivebiotech.com. You may find our certification page at https://www.privacyshield.gov/list. If there is any conflict between the policies in this Privacy Shield Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. For purposes of enforcing compliance with the Privacy Shield Principles, Adaptive is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

Adaptive commits its cooperation with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regards to disputes over human resources data transferred from the EU and Switzerland in the context of the employment relationship. Adaptive will comply with any advice provided by such authorities as it relates to pertinent activities.

We may update this Policy from time to time consistent with the requirements of the Privacy Shield Framework, and we will provide appropriate notice of an such amendments on the Adaptive website Legal-Privacy page, https://www.adaptivebiotech.com/legal-privacy.

 

I. DEFINITIONS

“Data Subject” means the individual to whom any given Personal Data covered by this Privacy Shield Policy refers.

“Personal Data” means any information relating to an individual residing in the European Union or Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Personal Data” means Personal Data regarding an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

 

II. TYPES OF PERSONAL DATA ADAPTIVE RECEIVES FROM THE EU AND SWITZERLAND
The Personal Data that Adaptive may collect in reliance on this Privacy Shield Privacy Policy includes individual contact information, health information (which we treat as Sensitive Personal Data), certain financial information which may include payment account information, and information on personal preferences and demographics. Additionally, Adaptive may collect information relating to an expression of interest in employment and background checks.

 

III. PURPOSES FOR PERSONAL DATA COLLECTION AND USE
Adaptive obtains Personal Data in reliance on this Privacy Shield Privacy Policy in order to:

  1. Conduct research and development
  2. Undertake product development
  3. Perform contracts and services
  4. Conduct healthcare operations
  5. Engage in marketing and sales, with proper consent
  6. De-identify or anonymize the information so it is no longer Personal Data and may be used for purposes other than those described here.
  7. Consider expressions of interest for employment and evaluate candidates and, if hired, employees.

Adaptive maintains reasonable procedures to help ensure that EU and/or Swiss Personal Data is reliable for its intended use, accurate, complete, and current. If Adaptive seeks to use Personal Data covered by this Privacy Shield Policy for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Adaptive will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Adaptive takes reasonable and appropriate measures to retain Personal Data in identifiable form only for as long as it serves a purpose of legitimate use or other processing.

 

IV. PURPOSES FOR SHARING AND RECIPIENTS OF PERSONAL DATA

A. Third-Party Agents and Service Providers: We share Personal Data with unaffiliated third parties who provide us with services, such as those who assist us with technology, data analysis, or similar services. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide at least the same level of protection that the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third party agents and service providers process EU and/or Swiss Personal Data in accordance with our Privacy Shield obligations and (ii) to cease and remediate the adverse effects of any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers that perform services on our behalf for their handling of EU and/or Swiss Personal Data that we transfer to them.

 

B. Third-Party Data Controllers: In some cases, we may transfer EU and/or Swiss Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We will make such transfers only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by or notice provided to the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If we obtain knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, Adaptive will take reasonable steps to prevent or stop such processing. The third-party data controllers to whom we may disclose Personal Data include but are not limited to:

  1. Research and Development Partners. 
  2. Acquirers or Assignees: In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Adaptive or its assets, we may transfer Personal Information to the acquiring party or assignee.
  3. Corporate Investment Partners.

 

C. Entities Entitled Under Law: We also may disclose Personal Data in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to meet national security or law enforcement requirements, or (v) to evaluate job candidates, check references or background, and if hired, regarding employment.

 

V. DATA SUBJECTS’ ACCESS TO THEIR PERSONAL DATA
Each Data Subject has the right to access the Personal Data Adaptive has obtained regarding he or she in reliance on the Privacy Shield and to request that we correct, amend, or delete that Personal Data if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, alternative choice of opt-in/out, or deletion of your EU and/or Swiss Personal Data, you can submit a written request to us as indicated in the “Contacting Us” section of this Policy below. We may request specific information from you to confirm your identity in order to respond to such a request. In some circumstances we may charge a reasonable fee for access to your information. If your EU and/or Swiss Personal Data was provided to us by an Adaptive customer, we may facilitate your access to such data by directing you to the customer that provided your data to us.

 

VI. SECURITY
Adaptive maintains reasonable and appropriate security measures to protect EU and/or Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield Framework.

 

VII. COMPLAINTS AND MECHANISMS FOR RECOURSE
Each Data Subject may raise questions or complaints about the use or disclosure of their EU and/or Swiss Personal Data in conformance with the Privacy Shield Principles. If you have any such questions or complaints, please write to us as directed in the “Contacting Us” section of this Policy below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU and/or Swiss Personal Data within 45 days of receiving your complaint.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, JAMS (free of charge) at https://jamsadr.com/eu-us-privacy-shield.

Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. Information on the conditions for and steps necessary to pursue this option is available at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

 

VIII. CONTACTING US
If you have any questions or concerns related to this Privacy Policy or the information practices of this organization, please write to us at:

Adaptive Biotechnologies Corporation
Attn: Kate Godfrey, JD, CCEP
VP, Compliance and Data Privacy Officer
1551 Eastlake Avenue East, Suite 200
Seattle, Washington 98102
USA

Email to: privacy@adaptivebiotech.com

ONLINE PRIVACY POLICY

Effective Date: March 29, 2018

This Online Privacy Policy sets out how Adaptive Biotechnologies Corporation uses and protects any personal information that you give us when you use our online services that link to this document.  We reserve the right to update or modify this policy at any time in the exercise of our discretion, with or without notice to you, and that will be effective upon our posting of a modified policy.

The words “Adaptive” and “we” or “us” refer to Adaptive Biotechnologies Corporation or its subsidiary or affiliate that maintains the relevant website or provides the relevant services, and the term “you” refers both to you in your individual capacity and, if applicable, to your employer or institution if you are accessing our websites or services in your capacity as an employee, agent or other representative of such an entity.

If you are located in the European Union and we process any of your personal information to which the EU General Data Protection Regulation 2016/679 (GDPR) applies, this Online Privacy Policy includes provisions specific to that processing and Adaptive may be a data controller or processor, in respect of such processing under the GDPR, to the extent necessary and applicable.

This Online Privacy Policy may cover personal information that you provide when establishing or updating your account for our products or services such as in an immunoSEQ® Analyzer user account (such as your name, contact details and payment information) or a clonoSEQ®service account. However, it does not govern any data that may be uploaded to or generated within either platform or service itself, including data generated from samples you (or others on your behalf) may send us for processing in connection with such services. This data is instead governed by the applicable terms of use you accepted upon or after account creation (as may be updated from time to time) and/or, if applicable, a written agreement between you and us.

In addition, you or anyone on your behalf are specifically requested not to send to us via email or via our external web site information that comprises protected health information.  Such information may be submitted in Adaptive’s secure portal in connection with our clonoSEQ CLIA service. In such cases it is governed by other policies that are compliant with the Health Information Portability and Accountability Act (HIPAA). To read about your rights and our obligations for this information, please see our Notice of Privacy Practices at https://www.adaptivebiotech.com/hipaa-privacy-practice/.

 

WHAT WE COLLECT
We may collect the following information from you:

  • Personal information you give us on our website or by email in order to obtain our services (Personal Information) including:any personal information you enter on our websites, including when completing a “contact us” form or establishing or updating your profile in a service user account, your name and job title, your employer name or other affiliation, contact and shipping information including your email address, credit card or other payment card information, information obtained through our use of cookies (explained below), purchase history (which we sometimes aggregate with similar information from other customers), and when provided, certain health information.
  • Automatic Information: We receive, store and use (in accordance with this Online Privacy Policy) certain types of information whenever you interact with us. For example, like many websites, we obtain certain types of information when your web browser accesses our websites, including the following: the Internet protocol (IP) address used to connect your computer to the Internet; login; password; computer and connection information such a browser type, version, and time zone setting, browser plug-in types and versions, operating system, and operating platform. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes. Our websites also incorporate third-party analytical tools to help us monitor performance and usage patterns, for example Google Analytics http://www.google.com/analytics/

 

PERSONAL INFORMATION RELATING TO EU CITIZENS

Transfers of your Personal Information
Adaptive is located in the United States. If you are located in the European Economic Area (EEA) and you submit Personal Information to Adaptive, that information will be transferred to the United States. Adaptive carries out such transfers on the basis of your consent and/or Adaptive’s EU-US Privacy Shield certification. You can access Adaptive’s EU-US Privacy Shield registration here and Adaptive’s EU-US Privacy Shield policy here https://www.adaptivebiotech.com/privacy-shield-policy. Adaptive also takes reasonable security measures to protect your Personal Information during such transfers and to protect its privacy and security in the United States.

Your rights in relation to your Personal Information
To the extent that the EU General Data Processing Regulation (“GDPR”) applies to Adaptive’s processing of your Personal Information, you may have the following rights in relation to that Personal Information, including the rights:

  1. to correct any Personal Information that we hold about you;
  2. to have your Personal Information removed under certain circumstances unless continued processing is necessary by law;
  3. to have the processing of your Personal Information restricted where you dispute its accuracy, if you think its processing is unlawful, or if you otherwise object to its processing, or when Adaptive no longer needs your Personal Information and you need it in relation to a legal claim;
  4. to receive copies of your Personal Information under certain circumstances; and
  5. to complain to your national data protection regulator if you feel that any of your Personal Information is not being processed in accordance with the GDPR.

You may withdraw your consent to the processing of your Personal Information or marketing communications at any time by emailing: privacy@adaptivebiotech.com. If you withdraw your consent, Adaptive will stop processing your Personal Information, unless it has any other legal basis for doing so, and will stop sending you marketing communications.

To exercise any of these rights, make a complaint, or request any additional information, please contact us at privacy@adaptivebiotech.com.

 

WHAT WE DO WITH YOUR PERSONAL INFORMATION
We collect your Personal Information to understand your needs and improve or develop our services, and in particular for the following reasons:

  • To respond to any inquiry you submit on our website
  • To enable you to create an account on our website
  • To respond to a request for a quote or information that you submit on our website or otherwise.
  • To provide our services to you if you request them
  • Internal recordkeeping
  • To improve our products and services or develop new products or services.
  • With your prior opt-in consent, to send you emails or other communications about existing or new or future products or services, Adaptive business, special offers or other information that we think you may find interesting.
  • With your prior opt-in consent, to contact you by email, phone, fax or mail for market research purposes.
  • With your prior opt-in consent, to send you promotional information about third parties that we think you may find interesting.
  • We will never sell your information. As we continue to develop our business, we might sell or acquire subsidiaries, affiliates or business units. In such transactions, your Personal Information may be one of the transferred business assets but remains subject to the promises made in the most recent pre-existing Online Privacy Policy. Also, in the unlikely event that Adaptive or substantially all of its assets are acquired, your Personal Information would be one of the transferred assets.

 

HOW WE MIGHT SHARE YOUR PERSONAL INFORMATION

Service Providers
We may disclose your Personal Information to third-party service providers to provide us with services such as website hosting, payment processing services and postal services.

Business Partners
We may disclose your Personal Information to our business partners in order to perform services you request or authorize, including as set forth in this policy, in accordance with our commercial practices.

Corporate Transactions or Events
We may disclose your Personal Information to a third party in connection with a corporate reorganization, merger, sale, joint venture, transfer, investment transaction, or other disposition of all or any of our business, including in connection with any bankruptcy or similar proceedings.

Legal Obligations
We may use or disclose your Personal Information as we deem necessary or appropriate under applicable laws, to respond to requests from public and government authorities including public and government authorities outside your country of residence, to comply with court orders and other legal processes, to legally protect the rights, property, or safety of Adaptive, our users, or others and  to enforce our Terms of Use or other agreement with you.

Sales and Marketing Purposes
When you provide your consent, we may use or disclose your Personal Information for sales and marketing purposes, including by disclosing your Personal Information to third parties for such purposes.

 

LINKS TO OTHER WEBSITES
Our websites may contain links to enable you to visit other websites of interest easily. We do not have any control over any such other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting such sites and such sites are not governed by this Online Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

 

SECURITY
We are committed to taking reasonable steps to protect the security of your Personal Information. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information we collect.

 

HOW WE USE COOKIES
A cookie is a small file which asks permission to be placed on your computer’s hard drive. A cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our websites in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. In addition, we use Google Analytics to analyze web traffic, but we do not authorize Google to share in any information about you with any third parties.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our websites.

 

INFORMATION ACCESS, UPDATES AND CHOICE
You may choose to provide information to us by completing a registration form, sending us an email or otherwise contacting us. In the registration form, you may have an opportunity to elect to receive certain communications from us. Our email correspondence will include instructions on how to update certain personal information and how to unsubscribe from our emails and postal mail correspondence. Please follow the instructions in the emails to notify us of changes to your name, email address and preference information. When we think appropriate, we may take additional steps, such as confirmation emails, to verify your identity before granting access to your personal information. If you choose to unsubscribe from our email and/or postal mail services, you will no longer receive this correspondence. However, we may retain your information for a period of time to resolve disputes, troubleshoot problems or for other valid business or legal reasons.

 

CHILDREN
Our websites are directed toward adults. We do not knowingly collect or use any personal information from children under age of 13, and if we become aware that we have collected such information we will delete it.

 

WEBSITE TERMS OF USE
If you choose to visit our websites, your visit and any dispute over privacy is subject to this Online Privacy Policy and our Website Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the state of Washington, United States of America, which is available at https://www.adaptivebiotech.com/terms-of-use/.

The use of our websites is governed by the laws of the state of Washington and the United States. If you are accessing our websites from any location with regulations or laws governing personal data collection, use or disclosure that differ from those of the United States and Washington State, then through your continued use you are transferring personal information to the United States and you consent to that transfer and to the collection and processing of such information in the United States. You also consent to the exclusive jurisdiction of any disputes arising in connection with our websites in the federal and state courts located in King County, Washington, USA. You also agree to attempt to first mediate any such disputes in good faith as we may request.

 

REVISIONS
We may revise this Online Privacy Policy from time to time. All updates to this statement will be posted on this web page. If we make significant changes, at our election, we will notify you by posting a notice on the website or by email (and only if we have your current email address and you have not previously requested that we refrain from emailing you). Please check our website for the most current version of our Online Privacy Policy. Your continued use of our websites after we have revised this Online Privacy Notice constitutes your acceptance of the changes.

CA PRIVACY NOTICES

Effective Date: January 1, 2020

California Resident Privacy Notices
Adaptive Biotechnologies Corporation (“Adaptive,” “we,” “our” or “us”)
California Employee Privacy Notice

PURPOSE OF THIS NOTICE: This California HR Privacy Notice (the “Notice”) describes our collection and use of certain personal information relating to our current and former full-time, part-time and temporary employees and staff, as well as Adaptive officers, directors and owners who are California residents (each an “Employee”).   This Notice describes our collection and use of personal information about Employees and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  We may provide Employees additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check and/or collect health information).

SCOPE OF THIS NOTICE: This Notice applies to personal information that we collect and use in order to manage the employment relationship (including emergency contact information) and other personal information related to our administration of benefits to Employees.

What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this notice.  This Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as protected health information (or “PHI”), consumer credit reports and background checks, publicly available data lawfully made available from state or federal governement records, or other information that is exempt under the CCPA.  This Notice also does not apply to the personal information we collect from contractors or job applicants, or from customers or end users of our products and services, including Employees in the context of their personal use of our products and services (which is subject to our Privacy Policy). 

Are our practices the same for all Employees?  The categories of personal information we collect, and our use of personal information may vary depending upon the circumstances, such as an Employee’s role and responsibilities with Adaptive. The information in this Notice is intended to provide an overall description of our collection and use of personal information about Employees.

Categories of Personal Information Collected: Generally, we may collect the below categories of personal information about Employees:

Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Paper and electronic records: such as records that may contain name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Commercial information: including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Characteristics of protected classifications: such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under California or federal law. (Note: generally, this information is collected on a voluntary basis, and is used in support of our equal opportunity and diversity and inclusion efforts or where otherwise required by law.)

Internet or other electronic network activity information: including browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information.

Audio, video and other electronic data: audio, electronic, visual, thermal, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).

Biometric information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including fingerprints, faceprint, hand, palm, vein patterns, DNA, imagery of the iris, retina, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information (collected where permitted by and subject to applicable laws).

Employment History: professional or employment-related information.

Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Inferences drawn from personal information collected: inferences used to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Purposes for collecting and using personal information: Generally, we may use the above categories of personal information for the following purposes:

Compensation and Benefits. Relating to our administration of compensation and benefits, including:
• Administering employee payroll, salary, reimbursement and compensation
• Administering employee pensions, IRAs and 401K, health insurance, medical plans, and other employee benefits administration (which may include the collection of personal information about others such as beneficiaries, where necessary to administer such benefits)
• Administering Employee Stock options
• Reviewing, assessing and administering employee salary and compensation increases and bonuses
• Calculating deductions, issuing tax return-related documents and forms to employees
• Reviewing timecards and reported time worked
• Monitoring and managing PTO, holiday, FMLA, and other leaves of absences

Management of Employment Relationship. To manage our relationship with Employees, including related to:
• Hiring, terminations, relocation, transfers, promotions and disciplinary actions
• Reviewing performance and related management
• Conducting Employee performance reviews, compensation and bonus reviews, and headcount and salary reviews
• Administering and monitoring compliance with our policies and procedures
• Maintaining records of emergency contact information for use in the event of an emergency
• Administering or performing employment contracts where applicable
• Conducting pre-employment and employment screening
• For professional development and training purposes
• Verification and management of applicable Employee credentials, licensing and other qualifications
• Facilitating employee communication and collaboration, such as through the corporate directory, employee bios and other similar
• Facilitating the safety of our Employees
• In support of our equal opportunity employment policy and diversity and inclusion program

Business Operations and Client Services. Relating to the organization and operation of our business and our performance of services to clients, including related to:
• Operating our business by developing, producing, marketing, selling and providing goods and services
• Providing after-sales services to clients
• Auditing and assessing performance of business operations, including client services and associated activities
• Training and quality control
• Satisfying client reporting and auditing obligations
• Facilitating business development opportunities, as relevant
Facilitating communications in furtherance of the foregoing

Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:
• Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
• Monitoring for, preventing, investigating, and responding to security and privacy incidents
• Providing and managing access to physical and technical access controls
• Monitoring activities, access and use to ensure the security and functioning of our systems and assets
• Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring. [Please see the Adaptive Code of Conduct for additional information about our monitoring practices.]

Auditing, Accounting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.

Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
[Other Business and Commercial Purposes. In addition, we may use the personal information we collect about Employees for other purposes including analytics and insights.

CONTACTING US ABOUT THIS NOTICE:  If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact privacy@adaptivebiotech.com.

Adaptive Biotechnologies Corporation (“Adaptive,” “we,” “our” or “us”)
California Contractor Privacy Contractor Notice

PURPOSE OF THIS NOTICE: This California Contractor Privacy Notice (the “Contractor Notice”) describes our collection and use of certain personal information relating to our current and former contractors and other non-employee workers who are California residents (each a “Contractor”).   This Contractor Notice describes our collection and use of certain personal information about Contractors and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  We may provide Contractors additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check and/or collect health information).

SCOPE OF THIS NOTICE: This Contractor Notice applies to personal information that we collect and use in order to manage work assignments and our working relationship with Contractors.

What is personal information? In this Contractor Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this notice.  This Contractor Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as protected health information (or “PHI”), consumer credit reports and background checks, publicly avaulable data lawfully made available from state or federal governement records, or other information that is exempt under the CCPA.  This Contractor Notice also does not apply to the personal information we collect from employees or job applicants.

Are our practices the same for all Contractors?  The categories of personal information we collect, and our use of personal information may vary depending upon the circumstances, such as a Contractor’s work assignment or the amount or sensitivity of the information or assets they may access as part of their work assignment. The information in this Contractor Notice is intended to provide an overall description of our collection and use of personal information about Contractors.

Categories of Personal Information Collected: Generally, we may collect the below categories of personal information about Contractors:

Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Paper and electronic records: such as records that may contain name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Characteristics of protected classifications: such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under California or federal law. (Note: generally, this information is collected on a voluntary basis, and is used in support of our equal opportunity and diversity and inclusion efforts or where otherwise required by law.)

Internet or other electronic network activity information: including browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information.

Biometric information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including fingerprints, faceprint, hand, palm, vein patterns, DNA, imagery of the iris, retina, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information (collected where permitted by and subject to applicable laws).

Employment History: professional or employment-related information.

Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Inferences drawn from personal information collected: inferences used to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purposes for collecting and using personal information: Generally, we may use the above categories of personal information for the following purposes:

Management and Oversight. To manage work assignments and the working relationship with contractors, including:
• Reviewing, assessing and administering payments to or for Contractors
• Reviewing timecards and reported time worked
• Reviewing and validating qualifications (e.g., credentials and licenses) and experience and approving assignments
• Conducting due diligence and screening of Contractors
• Monitoring compliance with company policies and procedures
• Administration of relevant training
• Administration of speaking events or similar engagements
• Maintaining records of emergency contact information for use in the event of an emergency
• Granting access to relevant systems, tools and assets
• Otherwise as necessary related to a particular job assignment

General Business Operations. In support of our business operations, including related to:
• Auditing and assessing performance of business operations, including client services and associated activities
• Training and quality control
• Satisfying client reporting and auditing obligations

Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:
• Monitoring for, preventing and investigating suspected or alleged misconduct or violations of policies and procedures
• Monitoring for, preventing, investigating, and responding to security and privacy incidents
• Providing and managing access to physical and technical access controls
• Monitoring activities, access and use to ensure the security and functioning of our systems and assets
• Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring. [Please see Adaptive Code of Conduct for additional information about our monitoring practices.]

Auditing, Accounting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.

Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.

[Other Business and Commercial Purposes. In addition, we may use the personal information we collect about Contractors for other purposes including analytics and insights.

CONTACTING US ABOUT THIS NOTICE:  If you have any questions or concerns regarding our use of personal information as described in this Contractor Notice, please contact privacy@adaptivebiotech.com.

Adaptive Biotechnologies Corporation (“Adaptive,” “we,” “our” or “us”)
California Applicant Privacy Notice

PURPOSE OF THIS NOTICE: This California Applicant Privacy Notice (the “Applicant Notice”) describes our collection and use of certain personal information relating to external job applicants and candidates for positions with Company (”Applicants”).  For California residents, this Applicant Notice describes our collection and use of certain personal information about Applicants and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”).  We may provide Applicants additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer).

SCOPE OF THIS NOTICE: This Applicant Notice applies to the personal information that we collect from and about Applicants, in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us.

What is personal information? In this Applicant Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this notice.  This Applicant Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as consumer credit reports and background checks, publicly avaulable data lawfully made available from state or federal governement records, or other information that is exempt under the CCPA.  This Applicant Notice also does not apply to the personal information we collect from employees or contractors (which is subject to  separate privacy notices).

Are our practices the same for all Applicants?  The categories of personal information we collect, and our use of personal information may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities.  The information in this Applicant Notice is intended to provide an overall description of our collection and use of personal information about Applicants.

Categories of Personal Information Collected: Generally, we may collect the following categories of personal information (as set forth in the CCPA) about Applicants:

Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Paper and electronic records: such as records that may contain name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Commercial information: including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Characteristics of protected classifications: such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under California or federal law. (Note: generally, this information is collected on a voluntary basis, and is used in support of our equal opportunity and diversity and inclusion efforts or where otherwise required by law.).

Internet or other electronic network activity information: including browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information.

Employment History: professional or employment-related information.

Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Inferences drawn from personal information collected: inferences used to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purposes for collecting and using personal information: Generally, we may use the above categories of personal information for the following purposes:

Recruiting, Hiring and Managing, and Evaluating Applicants. To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
• Scheduling and conducting interviews
• Identifying candidates, including by working with external recruiters
• Reviewing, assessing and verifying information provided, to conduct criminal and background checks, and to otherwise screen or evaluate Applicants’ qualifications, suitability and relevant characteristics
• Extending offers, negotiating the terms of offers, and assessing salary and compensation matters
• Satisfying legal and regulatory obligations
• Communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested
• Maintaining Applicant personal information for future consideration
• In support of our equal opportunity employment policy and practices

Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:
• Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
• Monitoring for, preventing investigating, and responding to security and privacy incidents
• Providing and managing access to physical and technical access controls
• Monitoring activities, access and use to ensure the security and functioning of our systems and assets
• Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring

Auditing, Accounting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.

Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
Other Business and Commercial Purposes. In addition, we may use the personal information we collect about Applicants for other purposes including analytics and insights.

CONTACTING US ABOUT THIS NOTICE:  If you have any questions or concerns regarding our use of personal information as described in this Applicant Notice, please contact privacy@adaptivebiotech.com.

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