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 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.

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