Effective date: March 1, 2021
Overview of Our Collection and Use of Personal Information
Personal Information Collected. Generally, we collect the following categories of personal information:
- Identifiers: includes direct identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, government identifiers, and other similar identifiers
- Customer records includes paper and electronic customer records containing personal information (such as name, contact information) that individuals provide us in order to obtain our products and services. For example, this may include information collected when an individual register for an account or enters into an agreement with us related to our services.
- Protected classifications:includes characteristics of protected classifications under US state or federal laws, such as race, sex, age, and disability, such as disability information and medical conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities we host).
- Commercial information: includes records of personal property, products or Services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
- Internet or other electronic network activity information: such as browsing history, clickstream data, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.
- Audio, video and electronic data: includes audio, electronic, visual, thermal, olfactory, or similar information, such as, thermal screenings and CCTV footage (e.g., collected from visitors to our premises and call recordings (e.g., of customer support calls).
- Geolocation data: precise location information.
- Employment information: professional or employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).
- Education information: information about an individual’s education history.
- Inferences: inferences drawn from personal information to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Purposes of Use. Generally, we use and disclose personal information for the following purposes:
- Providing support and Services and operating our websites;
- Analyzing and improving our business;
- Personalizing content and experiences;
- Advertising, marketing and promotional purposes;
- Securing and protecting our business;
- Defending our legal rights;
- Auditing, reporting, corporate governance, and internal operations; and
- Complying with legal obligations.
If you are a California resident, review section 16.B. CCPA – California Residents below for more about our information practices and your rights under the California Consumer Privacy Act (“CCPA”), including your rights to opt-out of the “sale” of your personal information as defined by the CCPA.
- individuals who access or use of our websites and online services (together, the “Services”) or whose personal information we otherwise receive in providing the Services;
- individuals that register for our Services, for example an immunoSEQ®Analyzer user account or a Diagnostics Portal account;
- our current, former, and prospective clients and business partners;
- attendees and participants at events that we host or sponsor;
- individuals who use our Services; and
- other individuals that otherwise communicate or interact with us.
- the samples and associated personal information that we receive from our institutional clients, as a data processor, or any information generated from such samples;
- the samples and associated personal information that we receive from US study participants from any clinical or research study of which Adaptive is sponsoring, or any information generated from such samples;
- samples and information that we receive related to our clonoSEQ and T-Detect laboratory and testing services or any other information that is subject to HIPAA, such as samples we receive for testing purposes associated with our laboratory services; this information is subject to our HIPAA Notice of Privacy Practices; or
- job applicants and candidates who apply for employment, or to employees and non-employee workers, whose personal information is subject to different privacy notices which are provided to such individuals in the context of their employment or working relationship with Adaptive.
2. COLLECTION OF PERSONAL INFORMATION
Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain of the Services and/or we may be unable to fully respond to your inquiry.
Information We Collect Directly. We collect information directly from individuals that use our Services, register for or attend our events or otherwise communicate or interact with us. For example:
- Personal information you give us for marketing purposes: including your business contact information, such as if you sign up to receive news, updates, offers and other marketing communications from us, we may collect your name and contact information. We may also collect name, email address, and other information when you participate in promotions, events or activities offered by us (collectively, “events”) or submit surveys or feedback to us.
Information Related to the Use of Our Services. We may collect information via automated means or derive information about you when you use our website or Services or otherwise interact with us. For example:
- Other: we may use CCTV and similar tools to monitor and secure our premises, which may lead to the collection of recordings about visitors to our premises. Further, if you contact our customer support services or participate in public events or webinars, we may record these interactions.
Information We Collect from Third Parties. We may collect personal information about you from third parties we work with such as third-party providers of services to us (e.g., fraud detection, identity verification and security), social networks, advertising networks, analytics providers, event sponsors, joint marketing partners, public records, and our affiliated companies.
- information from third party platforms related to your posts about or interactions with us on social media services.
- information from advertising networks or analytics providers related to your viewing of interactions with our ads, marketing or other content.
- demographic information, updated professional or contact details and similar information from data brokers, public records, and affiliated companies.
3. PURPOSES AND USE OF PERSONAL INFORMATION
We may collect, use, disclose, and otherwise process your personal information for the purposes described in this section.
A. Legal Bases for Processing Personal Information (where applicable)
Certain laws, including the General Data Protection Regulation (GDPR), require that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other similar relevant laws, such as the UK Data Protection Act), we may process personal information for the following legal bases:
- Performance of contract: processing of your personal information which is required for us to perform obligations or exercise rights under contracts that you may have with us (for example, if you use our Services).
- Compliance with laws: to comply with our legal obligations (for example, maintaining information in accordance with tax, audit, or company law requirements and responding to legal process).
Our legitimate business interests: in furtherance of our legitimate business interests including:
- to facilitate your participation in interactive features you may choose to use on our websites and Services and to personalize your experience with the Services by presenting content tailored to you.
- to correspond with you, notify you of events or changes to our Services, or otherwise respond to your queries and requests for information, which may include marketing to you.
- to send you advertising material via email, such as surveys and promotions (except where consent is required under applicable laws).
- to provide and personalize the Services.
- for data analysis, audits, fraud monitoring and prevention, and developing new products, enhancing, improving or modifying our websites, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- to protect and defend our legal rights and interests and those of third parties.
B. Use and Processing of Personal Information
We collect, use, and otherwise process your personal information for the below commercial or business purposes. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below. Where GDPR or other similar relevant laws apply, we have set forth the legal bases for such processing (see above for further explanation of our legal bases) in parenthesis.
- Providing support and Services: including to provide our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
- Analyzing and improving our business: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new Services; to conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes. (Legal basis: our legitimate business interests and/or with your consent)
- Personalizing content and experiences: including to tailor content we send or display on our websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate business interests and/or with your consent)
- Advertising, marketing, and promotional purposes: including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate business interests and/or with your consent)
- Securing and protecting our business: including to protect and secure our business operations, assets, Services, network, and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate business interests and/or compliance with laws)
- Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate business interests and/or compliance with laws)
- Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping, and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business. (Legal basis: our legitimate business interests and/or compliance with laws)
- Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests. (Legal basis: our legitimate business interests and/or compliance with laws)
Aggregate and De-identified Information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve, and develop our business, products, and Services; prepare benchmarking reports on our industry; and for other research, marketing, and analytics purposes.
4. DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect as set forth in this section.
- Service providers: to third-party service providers to provide us with services such as website hosting, payment processing services, and postal services.
- Event organizers: to third parties involved with events that you register for, to facilitate your participation in those events.
- Business partners: 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 and restructuring: in connection with planning, due diligence, negotiation and implementation of an actual or potential 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.
- Advertising and analytics partners: to third parties that provide advertising, campaign measurement, online and mobile analytics, and related services to us (with your consent, where required by applicable laws). They may use this information to help us better reach individuals with relevant ads and to measure and improve our ad campaigns, or to better understand how individuals interact with our Services. In addition, these third parties may combine the information collected from us and our Services with information collected about you from third-party sites, apps and services, in order to make inferences about you and your interests, to better tailor advertising and content to you across multiple sites, apps, and services, and to collect associated metrics.
- With consent: to third parties for other purposes, with your consent.
Aggregate and De-identified Information. We may share aggregate or de-identified information, which does not identify and is not linked or linkable to a particular individual, with third parties for research, marketing, analytics, and other purposes.
5. COOKIES AND SIMILAR TECHNOLOGIES
Our websites may use first party and third-party cookies, pixel tags, plugins and other tools, which are used in order to operate, secure and ensure the proper functionality of the websites and are otherwise necessary to the operation of the website (“necessary cookies”). On some of our websites, we may also use these tools to gather device, usage, and browsing information in order to personalize and improve your experience while using the websites, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our websites and on third-party websites.
Cookies. A cookie is a small file that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others are used to enable a faster log-in process or to allow us to track your activities while using our website. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.
Pixel Tags. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some websites to, among other things, track the actions of users of the websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the websites and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
Managing Your Cookie Preferences. You can manage your cookie preferences for our websites and opt out of certain cookies as explained below.
Cookie Settings. On most of our websites, you can review or change your preferences for that website by adjusting your cookie settings.
Please note, that your preferences are applied on a browser and device basis. So, you will need to set your cookie preferences for each browser and device you use to access certain of our websites. Further, if you subsequently delete cookies, your preferences may be lost and need to be reset. Our websites that only use necessary cookies do not include a cookie settings manager.
- Browser controls: In addition, you may block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our websites may not be available or function properly if you block or disable cookies.
- Do-not-track signals: Please note that our websites do not recognize or respond to any signal which your browser might transmit through the so-called ‘Do Not Track’ feature your browser might have. If you wish to disable cookies on our websites, you should not rely on any ‘Do Not Track’ feature your browser might have.
6. INTEREST BASED ADVERTISING
In addition, we may share certain hashed customer list information, such as email address, (“Custom Lists”) with third parties—such as Facebook, LinkedIn and Google—so that we can better target ads and content to our users and others with similar interests within their services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.
Your Preferences. On our websites that include targeting cookies, you may review, opt out of or update your preferences for third-party advertising tags and cookies on that website, using our Cookie Settings manager, as noted in section 5 above. In addition, you can opt out of being included in our Custom Lists by submitting a request here.
In addition, you can learn more about the information collection practices and “opt-out” procedures of many third-party ad companies by visiting www.aboutads.info/choices (US), or www.youradchoices.ca/choices/ (Canada), or www.youronlinechoices.com (EU).
7. TRANSFERS OF YOUR PERSONAL INFORMATION
Adaptive is located in the United States. If you are located outside the United States—such as in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland—and you submit personal information to Adaptive, that information will be transferred to the United States and other jurisdictions in which we or our vendors operate. The data protection laws in these jurisdictions may not be equivalent to those in your jurisdiction of residence. Adaptive will take steps to ensure that your personal information is subject to appropriate safeguards, including, where required, by implementing appropriate adequacy measures, such as the EU standard contractual clauses (as approved by the European Commission) for the transfer of personal data to processors established in third countries. The current form for the standard contractual clauses can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. For additional information regarding the mechanism under which your personal data is transferred outside of the EEA/UK, you may contact us as set forth below, in section 15 Contact and Comments.
8. RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
In this section we describe the choices individuals have regarding our collection, use, and handling of their personal information.
Access, amendment and deletion. You may request to review, make amendments, have deleted, or otherwise exercise your rights, under applicable privacy laws, over your personal information that we hold, subject to certain limitations under applicable law. You may submit a request to us related to your personal information by emailing us at firstname.lastname@example.org. Please note that we may maintain copies of information that you have updated, modified, or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Your access to or correction of your personal information is subject to applicable legal restrictions and the availability of such information. Further, we may take reasonable steps to verify your identity before granting such access or making corrections.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality that we owe to others, if we are legally entitled to deal with the request in a different way, or if relevant exemptions apply to some or all of the personal information subject to the request.
- GDPR – EEA/UK: section 16 A. GDPR – EEA/UK below provides information about data subject rights under the GDPR and UK Data Protection Act.
- CCPA – California Residents: section 16 B. CCPA – California Residents below sets forth additional information for California residents, about their rights under the CCPA.
9. LINKS TO OTHER WEBSITES
We have implemented security measures to protect the personal information we collect from unauthorized access or disclosure, including technical and organizational security measures to safeguard and secure the personal information we collect. Despite this, data security cannot always be guaranteed. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at email@example.com. In addition, you or anyone on your behalf are specifically requested not to send to us any health information or other sensitive personal information via email or via our external website outside of information related to the purchasing of T-Detect; for information related to our clonoSEQ services, such information may be submitted in Adaptive’s secure Diagnostics Portal.
11. RETENTION PERIOD
Our websites are directed toward adults. We do not knowingly collect or use any personal information from children under the age of 13, and if we become aware that we have collected such information we will delete it.
15. CONTACT AND COMMENTS
Adaptive Biotechnologies Corporation
Attn: Kate Godfrey, JD, CCEP
VP, Government Affairs, Chief Compliance and Privacy Officer
1551 Eastlake Avenue East, Suite 200
Seattle, Washington 98102, USA
16. ADDITIONAL INFORMATION FOR INDIVIDUALS IN CERTAIN JURISDICTIONS
A. GDPR Rights – EEA/UK
To the extent that the GDPR or the UK Data Protection Act applies to Adaptive’s processing of your personal information, you may have the following rights in relation to that personal information:
- to obtain from us confirmation as to whether or not personal information concerning you is being processed, and where that is the case, to request access to the personal information. The accessed information includes – among others – the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal information have been or will be disclosed. You have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs;
- to correct any personal information that we hold about you;
- to have your personal information removed under certain circumstances unless continued processing is necessary by law;
- 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;
- to receive copies of your personal information under certain circumstances;
- to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded;
- to request that we change the manner in which we contact you for marketing purposes. You can request that we do not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes;
- to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside the EU/EEA/UK. We may redact data transfer agreements to protect commercial terms; and
- 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.
- to withdraw your consent, where the processing of your personal information is based on consent (see the Purposes and Use of Personal Information section above); if you withdraw your consent, Adaptive will stop processing your personal information, unless we have another legal basis for doing so.
You may submit a request to us regarding your personal data held by Adaptive here. Please note that we may rely on applicable exemptions under EU, Member State, or UK law in order to deny part or all of your request. If we do so, we will inform you when responding to your request.
B. CCPA – California Residents
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (CCPA), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. Below, we provide information as required under California privacy laws, including the CCPA. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
Categories of Personal Information We May Collect and Disclose. Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The list below sets out generally the categories of personal information we may collect about California residents and how we may disclose such personal information to third parties for a business purpose.
|Personal Information Collected||Categories of Third Parties to Whom We May Disclose this Information|
|Identifiers||Includes direct identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, government identifiers, and other similar identifiers.||
|Customer Records||Includes paper and electronic customer records containing personal information (such as name, contact information) that individuals provide us in order to obtain our products and services. For example, this may include information collected when an individual register for an account or enters into an agreement with us related to our services.||
|Protected Classifications||Includes characteristics of protected classifications under US state or federal laws, such as race, sex, age, and disability, such as disability information and medical conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities we host).||
|Commercial Information||Includes records of personal property, products or Services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||
|Internet or other electronic network activity information||Includes browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.||
|Geolocation Data||Includes precise location information.||
|Employment information||Includes professional or employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).||
|Education information||Information about an individual’s education history.||
|Audio, video and electronic data||Includes audio, electronic, visual, thermal, olfactory, or similar information, such as, thermal screenings and CCTV footage||
|Inferences||Includes inferences drawn from personal information to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.||
Categories of Personal Information Sold. The CCPA defines a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” certain categories of personal information as defined under the CCPA. We may disclose or make available to third-party ad companies (e.g., through third-party tags on our websites) identifiers and internet and other electronic activity information in order to improve and measure our ad campaigns and reach customers and potential customers with more relevant ads and content. Where relevant, users can opt out of third-party tags and cookies, other than those that are “necessary”, by adjusting their cookie settings.
Sources of Personal Information. We have collected the above categories of personal information from the following sources:
- directly from you and, in some cases, from third parties;
- automatically (e.g., through cookies) when you use our website or online services;
- social networks;
- clients and business partners;
- platform providers and operators;
- payment processors; and
- third-party service providers
CCPA Rights. California law grants California residents’ certain rights as set forth below.
- Do-Not-Sell: California residents have the right to opt-out of our sale of their personal information. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.
- Requests to Delete: Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.
Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to receive information about how we have handled their personal information in the prior 12 months, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties to whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
- Right to Non-discrimination:California residents have the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting Requests. California consumers (or their authorized agents) may submit verifiable Requests to Know and Requests to Delete by submitting a request to us online here. You may also submit a request to us by phone at (888) 552-8988 (US Toll Free). We will respond to California residents’ requests as required by the CCPA.
You must complete all required fields on our webform (or otherwise provide us with this information via phone). We will take steps to verify your request by matching the information provided by you with the information we have in our records. If we are unable to adequately verify a request, we will notify the requestor. In some cases, we may request additional information in order to verify your request or where necessary to process your request. You may also submit a Do-Not-Sell request on most of our websites by clicking the “Do Not Sell My Info (California Residents)” link in the footer of our website; and by adjusting your Cookie Settings.
Please note, that our websites that include only necessary cookies do not include a Cookie Settings manager.
For more information about our privacy practices, you may contact us as set forth in the Contact and Comments section above.