ALLADAPT IMMUNOTHERAPEUTICS WEBSITE TERMS OF USE

WEBSITE PRIVACY POLICY

Last Updated: 09 Nov 2020

1. PURPOSE
Alladapt Immunotherapeutics, Inc. ("Alladapt") is committed to respecting the privacy of individuals. To better understand how we protect your privacy, we provide this Privacy Policy to explain our online information practices and the choices you have about the way your personal information is collected and used.

2. POLICY OVERVIEW

2.1 Alladapt recognizes the importance of protecting the privacy of information we collect and store from visitors to our website ("Website"). Alladapt is a pharmaceutical company researching and developing novel treatments for food allergies. Our research activities ("Research") include the investigation and development of certain oral immunotherapy drug candidates.  Our Website allows you to easily access and use content, including features, resources and other information intended to help you learn about Alladapt's Research, the products we are developing, and information about our Research.

2.2 This Privacy Policy ("Policy") describes our policies regarding the collection, use, disclosure, and protection of personal data when you visit our Website and the choices you have associated with that data—it does not apply to information you disclose to Alladapt through other means, including if you enroll in a clinical trial. Clinical trial data is handled in accordance with the study protocol and any informed consent form participants. Information collected through websites intended to register and pre-screen potential participants ("Study Site") are also governed by a Study Site Privacy Notice. This Policy is incorporated and made part of the Alladapt Terms of Use. You should review this Policy before providing any personal information.

2.3 We use your data to provide and improve our Website. By visiting our Website, you agree to the collection and use of information in accordance with this Policy. If you do not agree to this Policy, please do not access or use the Website. Alladapt reserves the right to change, modify, add or remove portions of this Policy at any time, without prior notice. Changes take effect on the date that appears on the revised Policy. If you use the Website following a change in this Policy, your use will be understood to signal that you accept and agreed to be bound by the changes. Accordingly, we urge you to review this Policy frequently for changes.

3. MEDICAL DISCLAIMER

3.1 The information on this Website is not intended or implied to be a substitute for professional medical advice, diagnosis, or treatment. All content, including text, graphics, videos, images, and information, contained on or available through this web site is for general information purposes only. Alladapt makes no representation and assumes no responsibility for the accuracy of the information contained on or available through this Website, and such information is subject to change without notice. You are encouraged to confirm any information obtained from or through this Website with other sources and review all information regarding any medical condition or treatment with your physician. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY SEEKING MEDICAL TREATMENT BECAUSE OF SOMETHING YOU HAVE READ ON OR ACCESSED THROUGH THESE WEBSITES.

3.2 Alladapt does not recommend, endorse or make any representation about the efficacy, appropriateness, or suitability of any specific products, procedures, treatments, services, opinions, health care providers, or other information that may be contained on or available through any Alladapt Website. ALLADAPT IS NOT RESPONSIBLE NOR LIABLE FOR ANY ADVICE, COURSE OF TREATMENT, DIAGNOSIS, OR ANY OTHER INFORMATION, SERVICES, OR PRODUCTS THAT YOU OBTAIN THROUGH OUR SITES.

4. INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our Website.

4.1 Types of Data Collected

4.1.1 Personally Identifiable Information. While visiting our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personally Identifiable Information" or "PII"). PII may include, but is not limited to, your e-mail address, first and last name, telephone number, or physical address. For purposes of this Policy, please note that PII includes information you provide about yourself or other family members on whose behalf you are using the Website or completing and submitting our "Contact Us" form, or requesting information about clinical trials in your area, such as through our Pre-Screening Site.  If you submit a form requesting information about a clinical trial, you may be asked to provide information about your health. "You" and "your" includes you and these family members. You may, however, visit portions of the Website without providing any Personal Information.

4.1.2 Usage Data. We may collect information how our Website is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), mobile device identifiers, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4.1.3 Tracking and Cookies Data. We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with small amount of data, which may include a unique anonymous identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website. You may be able to set your browser to refuse all cookies or to indicate when a cookie is being sent. If you do not accept cookies, you may not be able to use some portions of our Website or not all features of the Website may operate as intended. Our Website currently does not respond to "Do Not Track" ("DNT") signals and operates as described in this Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Policy to describe how we do so.

4.1.4 Analytics Services. Alladapt may use third parties to analyze visitor traffic to our Website.

4.2 Use of Data

Alladapt uses the collected data for various purposes, including to provide and maintain the Website, to notify you about changes to our Website, to allow you to participate in any interactive aspects of our Website when you choose to do so, and to respond to your requests, questions and feedback. We also use the collected data to monitor usage of the Website, to provide analysis or information so that we can improve the Website, and to detect, prevent and address technical issues.

We may also de-identify and aggregate your PII for our own purposes.  Aggregated Data is information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified. "De-identified Information" is information that has been stripped of your identifiers, such as your name, contact information, and other identifying data, such that you cannot reasonably be identified as an individual.

We will handle your PII in strict accordance with the law. We only collect PII for specified, explicit, and legitimate purposes and limit the collection of PII to the extent necessary for such purposes. We will store PII for no longer than necessary for the purpose for which PII are processed. PII will be stored and processed in a manner that ensures appropriate security of the information.

5. TRANSFER OF DATA

5.1 This Website is intended for use by users in the United States. Your information, including PII, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

5.2 If you are located outside the United States and choose to provide information to us, please note that the information you provide, including PII, is transferred to the United States and is processed there. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.

5.3 Alladapt will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, and no transfer of your PII will take place to an organization or a country unless there are reasonable controls in place, including the security of your data and other personal information.

6. HOW WE COMMUNICATE WITH YOU

6.1 When you send e-mail or other communications to Alladapt, we may retain those communications in order to process your inquiries, respond to your requests, and improve our Website and related products and services. When you send and receive messages, we may collect and maintain information associated with those messages.

6.2 If you provide us with PII via e-mail, we may send you a welcome e-mail to verify your information. We will communicate with you in response to your inquiries. We will communicate with you by e-mail or telephone, in accordance with your preference.

6.3 You acknowledge that by providing us with your telephone number, cell phone number, and e-mails, we may use that information to send you information on products, services, special deals, and promotions offered by one of our partners or us. If we do, out of respect for your privacy, we will provide an option not to receive these types of communications.

7. DISCLOSURE OF DATA

7.1 You understand and agree that we can disclose your Personally Identifiable Information and other data to third parties, as follows:

7.2 To Vendors, Service Providers, and Research Partners:  Alladapt may disclose your Personally Identifiable Information to third parties who assist us in conducting Research and to perform certain research recruitment services and functions, including clinical research organizations ("CROs"), and others conducting research-related activities on our behalf ("Research Partners"); providers of administrative services such as e-mail communication (including appointment reminders, investment information you request through the Website) and Website support services; to assist us in meeting business operations needs and to perform certain services and functions; and analytics. Pursuant to our instructions, these parties will access, process, or store Personally Identifiable Information only in the course of performing the services we require.

7.3 To Comply with Legal Requirements. Alladapt may disclose your Personally Identifiable Information in the good faith belief that such action is necessary to: (1) comply with a legal obligation; (2) to prevent or investigate possible wrongdoing in connection with the Website; (3) to act to protect the safety of visitors to the Website; (4) to protect and defend the rights or property of Alladapt; or, (5) protect Alladapt against legal liability.

7.4 To Our Subsidiaries, Affiliates, and Service Providers. Alladapt may disclose your Personally Identifiable Information to our subsidiaries or affiliates, strategic partners and to third parties services providers ("Service Providers") we engage to provide services on our behalf, such as web site hosting, customer service, etc. We may use Service Providers to perform related services or to assist us in analyzing how our Website is used, to verify employment and/or educational history or perform background checks. These third parties have access to your Personally Identifiable Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

7.5 Business Transfers or Acquisitions. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, dissolution, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personally Identifiable Information and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.

7.6 We may provide additional notice and ask for your consent if we wish to share your information in a materially different way than discussed in this Policy.

8. CORRECTING AND UPDATING YOUR PERSONAL INFORMATION

8.1 You can correct or update your Personally Identifiable Information by contacting us by e-mail at info@Alladapt.com. It may take us up to 30 days to process your request.

9. SECURITY OF DATA

9.1 The security of your data is important to us. While we strive to use generally accepted industry security standards means to protect your PII from loss, misuse, alteration, or destruction by any unauthorized party, we cannot guarantee its absolute security. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Website or e-mail. Accordingly, you understand and agree that you transmit all data, including PII, to us at your own risk. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

10. PRIVACY AND THIRD PARTY LINKS

10.1 This Policy applies solely to information collected by the through the Website, and if expressly noted in the applicable Privacy Notice, the Pre-Screening Site. In an attempt to provide you with increased value, we may include third party links on the Website. This Policy does not apply to the third party sites and services that are accessible through these links, and we suggest that you contact the operator of the third party service to obtain details about their privacy policies. We have no responsibility or liability for the content and activities of these linked sites or services. Nonetheless, we seek to protect the integrity of the Website and welcome any feedback about these linked sites (including if a specific link does not work).

11. CHILDREN'S PRIVACY

11.1 Our Website is intended only for use by adults, either for themselves or on behalf of family members, and is not intended for use by anyone under the age of 13 ("Child"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you have reason to believe that a child under the age of 13 has provided us with Personally Identifiable Information, please contact us, and we will endeavor to delete that information from our databases.

12. RETENTION OF YOUR PERSONAL INFORMATION

12.1 We will store the Personally Identifiable Information we collect for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

13. YOUR OPTIONS

13.1 You may access and use the Website without providing any Personally Identifiable Information. If you choose to provide any Personally Identifiable Information, you may have the right to request to review, update, correct, suppress, restrict or delete Personally Identifiable Information that you have provided to us through the Website. To make a request, please contact us as indicated below, and we will respond to your request in a manner that is consistent with applicable law within a reasonable period of time. For your protection, we may need to verify your identity before taking action with your request.

14. EXCLUSIONS

14.1 This Policy shall not apply to any unsolicited information you provide to us through the Website or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

15. CONTACT US WITH QUESTIONS

If you have any questions about the Privacy Policy, please contact us:


Alladapt Immunotherapeutics, Inc.
611 Santa Cruz Ave.
Menlo Park, CA 94025
650-420-3900
info@alladapt.com

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