Adaptive Phage Therapeutics Privacy Policy – Adaptive Phage Therapeutics

What Does Our Privacy Policy Include?

Adaptive Phage Therapeutics, Inc. (“APT”, “our”, “we”, “us”) take data privacy seriously and we are committed to keeping your data and any patient specific data safe. We created this Privacy Policy to educate you on the measures we take to protect your information, access rights to the information, and to be transparent with how we use and disclose the information you provide to us. If you do not understand any aspects of our Privacy Policy, please feel free to contact us as described at the end of this Privacy Policy. We may update this Privacy Policy from time to time by posting a new version online.

Our Privacy Policy focuses on the information provided to us through our website, products, applications, advertisements, and services (collectively, the “Services”). This information is used to communicate with you electronically.

APT collects a variety of information such as username, first and last names, email addresses, zip code information, place of business, address, and phone number. Additionally, and if provided, we also may collect basic medical information. This information is used only to verify authenticity and to facilitate directed communications to you as requested. We respect your privacy. We do not sell, rent, or loan any provided information to any third party. Any information you give us is held with the utmost care and security and will be used only in ways in which you have consented and to improve our Services. Obviously, if you choose to not provide all requested personal information, you may not be able to completely access and/or obtain maximum benefit in using our Services.

When you use our Services, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of our Services. We do not use “cookies.”

Our Services includes advertisements from our ad servers, ad networks and social media platforms. Information about you and your engagement with these services will also be provided to us. For example, if you choose to integrate with a third-party application to share social media posts, we could also receive such data from these apps. We are not responsible for the privacy practices of such other sites, and we will only use this information consistent with our Privacy Policy.

Additionally, our Services also include the use of APT’s phage bank mobile application (the “PhageBank App”). This app is distributed by APT as part of our on-going clinical trials on APT provided iPads. The app provides a treating physician and/or pharmacist information relating to the administration of a precision matched phage therapeutic to a patient. Specifically, by logging into an account created by APT on the PhageBank App, you are automatically accepting and acknowledging APT’s Privacy Policy. To the extent you work as part of a team and are using an account created for someone other than yourself (an “Authorizing Individual”), you represent that you have been authorized to represent the Authorizing Individual and that you too accept and acknowledge this Privacy Policy. Additionally, our PhageBank App relies on limited personal Information obtained from you regarding your patient. Specifically, the PhageBank App relies on a de-identified patient ID number, a corresponding weight (in kilograms) of that patient (“De-Identified Information”) and in some limited cases, other patient specific data. This is the only information that we request regarding your patient. Additionally, log file information is automatically reported by your browser or mobile device each time you access the PhageBank App. When you use our app, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the app, domain names, landing pages, pages viewed, and other such information. This information is used to improve the PhageBank App.

What Information Do We Collect?

We collect two types of information: (1) the De-Identified information described above (i.e., a de-identified patient ID number and a corresponding weight (in Kilograms) of that patient) that we receive from you or an Authorizing Individual about your patient, and (2) information that we collect through your use of the APT’s phage bank App.

Information You Provide and Information We Collect:
You provide us information in several ways through our Services:

Account Information. We will collect and store usernames, email addresses, contact information, passwords.
De-Identified Information. Using the PhageBank App, we will collect de-identified patient ID numbers, wound area, and weight (in kilograms) of that patient.
Browsing and Usage Information: We use technologies to collect information about your use of our Services, including the PhageBank App. We use these tools to improve the quality of our service, including for example, user preferences and/or tracking user trends.

How Do We Use and Share Personal Information Or Health Information?

We do not collect or share Personal Information or Health Information that would otherwise be regulated under the Health Insurance Portability and Accountability Act (“HIPAA”). Instead, we only collect the De-Identified Information using the PhageBank App. Subject to applicable legal restrictions, this De-Identified Information may be used as follows:

To provide you with the Services;
To communicate with you, provide you updates, respond to your requests, and provide customer support;
To improve and enhance our Services, including developing new products, features, and functionality, such as, for example, by creating aggregate data for research, product development or enhancement, or statistical analysis.
For other specific purposes that we provide you with notice of at the time the information is collected;
For compliance purposes, including enforcing our Terms of Use or other legal rights; and
For security purposes to protect our PhageBank App and Services.

We may also share the De-Identified Information in limited circumstances (subject to applicable legal restrictions) as follows:

To subcontractors, service providers and other third parties we use to support our business and who are bound by contractual obligations (e.g., Business Associate Agreements) to keep the De-Identified Information confidential and use it only for the purposes for which we disclose it to them.
To your patient’s health care provider, health care professional, health plan, employer’s clinical team, health care benefits consultant, or benefits manager clinical team if request by you.
As required by state or federal law, which can include providing information as required by statute, regulation, subpoena, court order, legal process, or government request.
To report, either directly or indirectly, to the federal Food and Drug Administration adverse events related to the phage products.
To report to the Centers for Disease Control and Prevention or other federal agency and/or state government agencies as required for public health surveillance and related purposes.
For a merger, sale, or other asset transfers in connection with a corporate transaction, in which we are acquired by or merge with another company.
As otherwise authorized by law.

Do Not Track Signals.

APT does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, most web browsers will allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Children And Minors.

APT’s Services, including the APT PhageBank App, are to be used by adults who are at least age 18 or such older age as may be required by applicable state law. We do not knowingly collect nor solicit any information from anyone under the age of 13 though our Services. If we learn that we have inadvertently collected information from a child under the age of 18 (or such older age of majority), we will use reasonable efforts to quickly delete that information.

How Is Your Information Protected?

We use industry standard physical, technical, and administrative security measures and safeguards in compliance with HIPAA to protect the confidentiality and security of any De-Identified Information obtained using our Services. However, even with these safeguards, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. You should report any security violations or breaches to us by contacting us at clinical@aphage.com by calling us at +1-844-972-0500.

Where Will Your Information Be Maintained?

Our Services, including the PhageBank App, is operated and managed on secure, HIPAA-compliant cloud-based servers.

How Will You Know If This Policy Changes?

We may change this Privacy Policy from time to time in the future. We will post any revised version of the Privacy Policy on our website at aphage.com/privacy and at other places we deem appropriate. Continued use of our Services will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

How Can I Contact You If I Have Questions?

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, please email us at clinical@aphage.com or call us at +1-844-972-0500, or by regular mail at:

Adaptive Phage Therapeutics
708 Quince Orchard Rd, Suite 205
Gaithersburg, MD 20878
Attn: Chief Legal Officer