Notice at Collection
Effective date: March 25, 2024
Below is information about how Adaptive Biotechnologies Corporation collects, uses and discloses personal information
We at Adaptive Biotechnology Corporation (“Adaptive,” “we” or “us”) think transparency is important. In this overview, we summarize the relevant personal information we collect and how we use it. For California residents, this information is required under California privacy laws such as the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information. This notice does not address or apply to our handling of publicly available information made lawfully available by state or federal governments, nor does it apply to personal information that is subject to an exemption under the CCPA, CPRA or other applicable laws or regulations. You can find more information about our privacy practices and how we collect and use personal information in our Privacy Policy. Current and former employees, contractors, and job applicants can find more information about how Adaptive processes their personal information at the California HR Privacy Notices.
1. For which purposes does Adaptive use and disclose personal information?
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;
- Planning and managing events;
- Market research and surveys;
- Securing and protecting our business;
- Defending our legal rights;
- Auditing, reporting, corporate governance, and internal operations; and
- Complying with legal obligations.
2. Which categories of personal information do we collect, and to which third parties do we disclose it for a business or commercial purpose?
Our collection, use, disclosure, and other processing of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with them. The table below sets out, generally, the categories of personal information (as defined by the CCPA) we collect about California residents and how we may disclose such personal information to third parties for a business or commercial purpose.
| Categories and Description of Personal Information Collected | Categories of Third Parties to Whom We May Disclose this Information for a Business or Commercial Purpose | |
| 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. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · event organizers · business partners who provide services you request · advertising networks · analytics providers · social networks · internet service providers · operating systems and platforms · others as required by law or directed by you |
| 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. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · business partners who provide services you request · others as required by law or directed by you |
| 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). | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · event organizers · business partners who provide services you request · others as required by law or directed by you |
| Commercial Information | Includes records of personal property, products or Services purchased, obtained, or considered, or other purchasing or use histories or tendencies. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · business partners who provide services you request · others as required by law or directed by you |
| 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. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · advertising networks · analytics providers · social networks · operating systems and platform providers · others as required by law or directed by you |
| Geolocation Data | Includes precise location information, which may be used to provide certain functions to you on our websites. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · business partners who provide services you request · others as required by law or directed by you |
| Professional and employment information | Includes professional or employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships). | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · others as required by law or directed by you |
| Education information | Information about an individual’s education history. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · others as required by law or directed by you |
| Audio, video and other electronic data | Includes audio, electronic, visual, thermal, olfactory, or similar information, such as, thermal screenings and CCTV/video footage | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · others as required by law or directed by you |
| Profiles and 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. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · analytics providers · others as required by law or directed by you |
| Sensitive personal information | As an employer and/or prospective employer, assigned work location, contract holder or holder of other employer-like relationship, we may collect certain sensitive information about you. You can read more about our privacy practices as an employer in our California HR Privacy Notices. We may also collect health information in our capacity as a HIPAA regulated entity set out in our HIPAA Notice of Privacy Practices. | · service providers · advisors and agents · government entities and law enforcement · our affiliates and subsidiaries · others as required by law or directed by you |
3.What categories of personal information may be sold or shared with third parties?
The CCPA defines a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available to third-party ad companies (e.g., through third-party cookies and pixel 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 such third-party tags and cookies, other than those that are “necessary,” by adjusting their cookie settings. Our Cookie Preference Manager is also accessible through the “Do Not Sell or Share My Info” link in the footer of our website.
4. From which sources do we collect personal information?
We have collected the above categories of personal information from the following sources:
- directly from you
- service providers
- advisors and agents
- government entities and law enforcement
- our affiliates and subsidiaries
- event organizers
- business partners who provide services you request
- advertising networks
- analytics providers
- social networks
- internet service providers
- operating systems and platforms
- others as required by law or directed by you
5. For which purposes do we collect and use personal information?
As described in more detail in Section 4 of the Privacy Policy, we collect, use and otherwise process the above personal information in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:
- Providing support and Services and operating our websites;
- Analyzing and improving our business;
- Personalizing content and experiences;
- Advertising, marketing and promotional purposes;
- Planning and managing events;
- Research and surveys;
- Securing and protecting our business;
- Defending our legal rights;
- Auditing, reporting, corporate governance, and internal operations; and
- Complying with legal obligations.
Notwithstanding the above, we only use and disclose sensitive PI as authorized pursuant to the CCPA (section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)). Accordingly, we will only use and disclose sensitive personal information as reasonably necessary (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 and regulatory obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.
6. Who may we disclose your personal information to?
As described in more detail in Section 5 of the Privacy Policy, we may disclose your personal information for the purposes described above, in order to provide our Services to you, to respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and as follows:
- To vendors and service providers;
- To event organizers;
- To business partners;
- To Adaptive affiliates and subsidiaries;
- For corporate transactions and restructuring;
- To third parties due to legal obligations;
- To protect us and others;
- To advertising and analytics partners;
- With consent or where you have requested us to disclose your personal information.
If you have any questions about how Adaptive collects, uses or discloses your personal information, please contact privacy@adaptivebiotech.com.
7. How can I exercise my rights regarding my data?
As a California resident, you have certain rights regarding your data. This includes the rights to Request to Know/Access (right to request specific pieces of personal information we have collected about you, subject to some exemptions), Request to Correct (right to correct inaccurate personal information we may maintain about you), the Request to Delete (right to request deletion of personal information may maintain about you, subject to some exemptions), and the Opt Out of Sales and Sharing (right to opt out of sharing and selling of your personal information, as specified in the law). You can find more information about your rights in our Privacy Policy.
California consumers (or their authorized agents) may submit verifiable Requests to Know/Access, Requests to Correct, and Requests to Delete. You can submit a request to us:
- online through our Data Subject Request Portal; or
- by phone at (888) 552-8988 (US Toll Free); or
- email to the Adaptive Privacy Office at privacy@adaptivebiotech.com.
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. Authorized agents may initiate a request on behalf of another individual online using our webform; 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.
You may exercise their right to opt out by clicking the “Do Not Sell and Share My Info” link in the footer of our website; and by adjusting their Cookie Settings.
Global Privacy Control
In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org.
You can find more information about how to exercise your rights in our Privacy Policy. If you have additional questions, you can contact us at privacy@adaptivebiotech.com.