California HR Privacy Notices

Effective date: June 30, 2023

About the California HR Privacy Notices

This document highlights how Adaptive Biotechnologies Corporation and our affiliates and subsidiaries (“Adaptive,” “we,” “our” or “us”) collect, use, disclose, and otherwise process personal information related to individuals who are California residents and who work for (as a full-time employee or contractor) or apply to work for Adaptive.

This document contains the privacy notices for California Employees, California Contractors and California Job Applicants. Please use the links to navigate to the privacy notices for each category, as well as to the specific sections outlining what information we collect and to whom we may disclose it:

California Employee Privacy Notice
- Categories of Information Collected and Disclosed
California Contractor Privacy Notice
- Categories of Information Collected and Disclosed
California Applicant Privacy Notice
- Categories of Information Collected and Disclosed

1. California Employee Privacy Notice

PURPOSE OF THIS NOTICE: This California Employee Privacy Notice (the “Notice”) describes how Adaptive Biotechnologies Corporation and our affiliates and subsidiaries (“Adaptive,” “we,” “our” or “us”) collect use, disclose and otherwise process personal information relating to our current employees and staff, as well as Adaptive officers, directors and owners who are California residents (each an “Employee”) and is intended to satisfy our applicable notice and privacy policy requirements under the California Consumer Privacy Act and the regulations issues thereto (collectively, the “CCPA”). The information in this Notice is intended to provide an overall description of our processing of Employee personal information. We may provide Employees additional notices about our data practices, such as those covered by other laws (e.g., if we conduct a background check). We encourage you to carefully read this Notice, together with any other privacy notice we may provide to you).

SCOPE OF THIS NOTICE: This Notice applies, generally to the Employee personal information that we collect, use, and otherwise process the context of your employment relationship with us including personal information that we process to manage your working relationship, administer benefits, grant and control access to our systems and assets, and process Employee onboarding and terminations, as well as personal information we receive related to Employee beneficiaries, dependents and emergency contacts.

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 government 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, which is subject to different privacy notices, or to the personal information we collect about customers (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 and Disclosed: Below, we define, generally, the categories of personal information about Employees that we collect and have collected in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. In some cases (such as where required by law), we may ask for to consent or give you certain choices prior to collecting or using certain personal information:

Personal Information Collected		May Be Disclosed To
Category	Description
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	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Categories of Personal Information Described in Cal. Civ. Code § 1798.80	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	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Commercial Information	including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	· Service providers
Characteristics of Protected Classifications Under State, Local and Federal Law	such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under state, local 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)	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
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	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Audio, Electronic, Visual, or Similar Information	audio, electronic, visual, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars)	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Professional or Employment Related Information	professional or employment-related information, such as performance information, professional membership records, references, assessment records, resumes, cover letters and work history, attendance records, conduct information (including disciplinary and grievance records), and termination data	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Education Information	defines as information 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)	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Inferences and Profiles	such as inferences drawn from any of the personal information identified above, to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	· Service providers Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Sensitive Personal Information	such as (a) Social Security number and other government identifiers; (b) financial account and payment information (e.g., for direct deposit purposes); (c) racial or ethnic origin or sexual orientation (e.g., on a voluntary basis to support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law, or union membership); and (d) health information (e.g., as necessary to provide reasonable accommodations)	· Service providers · Advisors and agents · Benefits providers · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Operating systems and platforms

We do not sell or share (as defined by the CCPA) personal information or sensitive personal information related to Employees, including those we know who are under the age of 16.

Sources of Personal Information. In general, we may collect the Employee personal information identified in the table above from the following categories of sources:

Directly from you
Recruiters and recruiting platforms
Referrals and references
Former employers
Other Employees
Publicly available information and data brokers
Service providers, representatives and agents, including service providers used for routine background checks
Affiliates and subsidiaries

Retention. Adaptive retains the personal information we collect only as reasonably necessary for the purposes described below or otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our tax, accounting and recordkeeping obligations, to consider you for additional positions (with your permission, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.

Purposes for collecting and using personal information. Subject to applicable legal restrictions, generally, we collect, use, disclose and process Employee personal information as reasonably necessary for the following purposes:

Compensation and Benefits: relating to our administration of payroll, compensation, and benefits, including:

Administering employee payroll, salary, and compensation, travel and expense reimbursement
Administering employee pensions, IRAs and 401K, health insurance, medical plans, and other employee benefits (which may include the collection of personal information about others such as beneficiaries
Administering Employee Stock options
Salary, bonus and compensation analysis
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
Conducting Employee performance reviews, compensation and bonus reviews, and headcount and salary reviews
Providing training and career development
Tracking attendance, time entries and working hours
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 and to ensure you have and maintain the correct qualifications and skills to perform your role and identify any future training needs
Verification and management of Employee identity and credentials, licensing, work visas, memberships 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, including monitoring and reporting on equal opportunity

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 and 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:

to detect, prevent, investigate and respond to suspected or alleged misconduct or violations of company polices or work rules
to detect, prevent, investigate and respond to security and privacy incidents
Providing and managing access to physical and technical access controls
Maintaining and reviewing, access and activity logs and records 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 Ethics and Business Conduct and Employee Handbook for additional information about our monitoring practices.

Health and Safety: for health and safety purposes, such as contact tracing or including conducting appropriate screenings of Employees prior to entering or accessing certain locations or premises.

Auditing, Accounting and Corporate Governance: 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.

Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use or disclose of sensitive personal information about Employees beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about Employees as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Your CCPA Rights. California Employees have certain rights under the CCPA with respect to their personal information, subject to certain limitations and exceptions

Deletion: the right to request deletion of their personal information that we have collected about them.
Know/access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
Correction: the right to request correction of inaccurate personal information we maintain about them.
Opt-out of sales and sharing: the right to opt-out of the sale and sharing of their personal information. However, as discussed above we do not sell or share Employee personal information.
Limit use/disclosure of sensitive personal information: the right to request to limit certain uses and disclosures of sensitive personal information. However, as discussed above, we do not use or disclose Employee personal information beyond the purpose authorized by the CCPA.
Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. Employees may submit a request to Adaptive to exercise their CCPA rights to know/access, to delete and to correct their personal information held by us by submitting a privacy request to us online through our Data Subject Requests Portal or by calling (206) 659-0067 (and selecting the options for the People and Culture Team).

We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e., by completing all required fields on our webform if you choose to submit a request in that manner).
Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

In some cases, we may request additional information in order to verify your request or where necessary to process your request. Authorized agents may initiate a request on behalf of another individual through one of the above methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

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

2. California Contractor Privacy Notice

PURPOSE OF THIS NOTICE:This California Contractor Privacy Notice (the “Contractor Notice”) describes how Adaptive Biotechnologies Corporation and its affiliates and subsidiaries (“Adaptive,” “we,” “our” or “us”) collect, use, disclose and otherwise process the personal information relating to our contractors and other non-employee workers who are California residents (each a “Contractor”) and is intended to satisfy our applicable notice and privacy policy requirements under the California Consumer Privacy Act and the regulations issues thereto (collectively, the “CCPA”). The information in this Notice is intended to provide an overall description of our processing of Contractor personal information. We may provide Contractors additional notices about our data practices, such as those that are covered by other laws (e.g., if we conduct a background check). We encourage you to carefully read this Notice, together with any other privacy notice we may provide to you.

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

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 available data lawfully made available from state or federal government 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, which is subject to different privacy notices, or to the personal information we collect about customers (which is subject to our Privacy Policy).

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 and Disclosed:Below, we define, generally, the categories of personal information about Contractors that we collect, and have collected in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. In some cases (such as where required by law), we may ask for to consent or give you certain choices prior to collecting or using certain personal information:

Personal Information Collected		May Be Disclosed To
Category	Description
Identifiers	such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (or Employer Identification number), driver’s license number, passport number, or other similar identifiers	· Service providers · Advisors and agents · Recruiters· Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Categories of Personal Information Described in Cal. Civ. Code § 1798.80	such as records that may contain name, signature, Social Security number (or Employer Identification 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	· Service providers · Advisors and agents · Recruiters· Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Commercial Information	including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	· Service providers
Characteristics of Protected Classifications Under State, Local and Federal Law	such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under state, local, 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)	· Service providers· Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
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	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Audio, Electronic, Visual, or Similar Information	audio, electronic, visual, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars)	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Professional or Employment Related Information	professional or employment-related information, such as performance information, professional membership records, references, assessment records, resumes, cover letters and work history, attendance records, conduct information (including disciplinary and grievance records), and termination data	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Education Information	defines as information 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)	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Inferences and Profiles	such as inferences drawn from any of the personal information identified above, to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Sensitive Personal Information	such as (a) Social Security number, Employer Identification number, and other government identifiers; (b) financial account and payment information (e.g., for direct deposit purposes); and (c) health information (e.g., as necessary to provide reasonable accommodations)	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Operating systems and platforms

We do not sell or share (as defined by the CCPA) personal information or sensitive personal information related to Contactors, including those we know who are under the age of 16.

Sources of Personal Information: In general, we may collect the Contractor personal information identified in the table above from the following categories of sources:

Directly from you
Recruiters and recruiting platforms
Referrals and references
Former employers
Other Contractors or Employees
Publicly available information and data brokers
Service providers, representatives and agents, including service providers used for routine background checks
Affiliates and subsidiaries

Retention: Adaptive retains the personal information we collect only as reasonably necessary for the purposes described below or otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our tax, accounting and recordkeeping obligations, to consider you for additional positions (with your permission, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.

Purposes for collecting and using personal information: Subject to applicable legal restrictions, generally, we may collect, use, disclose and process 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.]

Health and Safety: for health and safety purposes, such as contact tracing or including conducting appropriate screenings of Employees prior to entering or accessing certain locations or premises.

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.

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

Sensitive Personal Information: Notwithstanding the purposes described above, we do not collect, use or disclose of sensitive personal information about Contractors beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about Contractors as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Your CCPA Rights: California Contractors have certain rights under the CCPA with respect to their personal information, subject to certain limitations and exceptions:

Deletion: the right to request deletion of their personal information that we have collected about them.
Know/access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
Correction: the right to request correction of inaccurate personal information we maintain about them.
Opt out of sales and sharing: the right to opt-out of the sale and sharing of their personal information. However, as discussed above we do not sell or share Contractors personal information.
Limit use/disclosure of sensitive personal information: the right to request to limit certain uses and disclosures of sensitive personal information. However, as discussed above, we do not use or disclose Contractors personal information beyond the purpose authorized by the CCPA.
Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. Employees may submit a request to Adaptive to exercise their CCPA rights to know/access, to delete and to correct their personal information held by us by submitting a privacy request to us online through our Data Subject Requests Portal or by calling (206) 659-0067 (and selecting the options for the People and Culture Team).

We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e., by completing all required fields on our webform if you choose to submit a request in that manner).
Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

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.

3. California Applicant Privacy Notice

PURPOSE OF THIS NOTICE:This California Applicant Privacy Notice (the “Applicant Notice”) describes how Adaptive Biotechnologies Corporation and its affiliates and subsidiaries (“Adaptive,” “we,” “our” or “us”) collect, use, disclose and otherwise process the certain personal information relating to external job applicants and candidates for positions with Company (”Applicants”)and is intended to satisfy our applicable notice and privacy policy requirements under the California Consumer Privacy Act and the regulations issues thereto (collectively, the “CCPA”). The information in this Notice is intended to provide an overall description of our processing of Applicant personal information. We may provide Applicants additional notices about our data practices, such as those that are covered by other laws (e.g., if we conduct a background check or extend an employment offer). We encourage you to carefully read this Notice, together with any other privacy notice we may provide to you.

SCOPE OF THIS NOTICE: This Applicant Notice applies, generally, 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 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 available data lawfully made available from state or federal government 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), or to the personal information we collect about our customers (which is subject to our Privacy Policy).

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 and Disclosed: Below, we define,generally, the categories of personal information about Employees that we collect and have collected in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. In some cases (such as where required by law), we may ask for to consent or give you certain choices prior to collecting or using certain personal information:

Personal Information Collected		May Be Disclosed To
Category	Description
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	· Service providers · Advisors and agents · Recruiters · Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Categories of Personal Information Described in Cal. Civ. Code § 1798.80	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	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Characteristics of Protected Classifications Under State, Local and Federal Law	such as race/ethnicity, gender, sex, veteran status, disability, and other characteristics of protected classifications under state, local 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)	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
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	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Audio, Electronic, Visual, or Similar Information	audio, electronic, visual, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars)	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Professional or Employment Related Information	professional or employment-related information, such as performance information, professional membership records, references, assessment records, resumes, cover letters and work history, attendance records, conduct information (including disciplinary and grievance records), and termination data	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Education Information	defines as information 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)	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Inferences and Profiles	such as inferences drawn from any of the personal information identified above, to create a profile about an individual reflecting her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Internet service providers · Operating systems and platforms
Sensitive Personal Information	such as (a) Social Security number and other government identifiers; (b) financial account and payment information (e.g., for direct deposit purposes); (c) racial or ethnic origin or sexual orientation (e.g., on a voluntary basis to support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law, or union membership); and (d) health information (e.g., as necessary to provide reasonable accommodations)	· Service providers · Advisors and agents · Recruiters Affiliates and subsidiaries · Regulators, government agencies, and law enforcement · Operating systems and platforms

We do not sell or share (as defined by the CCPA) personal information or sensitive personal information related to Applicants, including those we know who are under the age of 16.

Sources of Personal Information. In general, we may collect the Applicant personal information identified in the table above from the following categories of sources:

Directly from you
Recruiters and recruiting platforms
Referrals and references
Former or other employers
Our Employees
Publicly available information and data brokers
Service providers, representatives and agents, including service providers used for routine background checks
Affiliates and subsidiaries

Retention. Adaptive retains the personal information we collect only as reasonably necessary for the purposes described below or otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our recordkeeping obligations, to consider you for additional positions (with your permission), as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.

Purposes for collecting and using personal information: Subject to applicable legal restrictions, generally, we collect, use, disclose and otherwise process 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

Other Business and Commercial Purposes: in addition, we may use the personal information we collect about Applicants for other purposes including analytics and insights.

Sensitive Personal Information: notwithstanding the purposes described above, we do not collect, use or disclose of sensitive personal information about Applicants beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about Applicants as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Your CCPA Rights. California Applicants have certain rights under the CCPA with respect to their personal information, subject to certain limitations and exceptions

Deletion: the right to request deletion of their personal information that we have collected about them.
Know/access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
Correction: the right to request correction of inaccurate personal information we maintain about them.
Opt out of sales and sharing: the right to opt-out of the sale and sharing of their personal information. However, as discussed above we do not sell or share Applicants personal information.
Limit use/disclosure of sensitive personal information: the right to request to limit certain uses and disclosures of sensitive personal information. However, as discussed above, we do not use or disclose Applicants’ personal information beyond the purpose authorized by the CCPA.
Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. Employees may submit a request to Adaptive to exercise their CCPA rights to know/access, to delete and to correct their personal information held by us by submitting a privacy request to us online through our Data Subject Requests Portal or by calling (206) 659-0067 (and selecting the options for the People and Culture Team).

We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e., by completing all required fields on our webform if you choose to submit a request in that manner).
Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

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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California HR Privacy Notices

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