YOUR PERSONAL INFORMATION
Please note this website is not intended for children and we do not knowingly collect personal information relating to children. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
WHO MAKES DECISIONS IN RELATION TO THE PERSONAL INFORMATION YOU PROVIDE?
Adaptimmune Limited ("Adaptimmune", "we", "us", "our") operates and provides this website and is responsible for taking decisions relating to your personal information. We are a data controller for the purpose of Data Protection Legislation. Our registered office is at 60 Jubilee Avenue, Milton Park, Abingdon, Oxfordshire, England, OX14 4RX. Further contact details for Adaptimmune Limited can be found on the contact us pages of our website.
We have a Privacy Officer who is responsible for overseeing any questions, concerns or complaints relating to this policy or the processing of your personal information. Please reach out to the Privacy Officer by e-mail on email@example.com.
WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We may collect, use, store and transfer different types of personal data about you including:
- Your name and contact data that you provide to us (e.g. your email address, telephone number or home address).
- Information provided voluntarily by you, for example, when you register for information by filling in forms on our website (e.g. the contact us section) or by corresponding with us by phone, e-mail or otherwise.
- Information about your use of our website including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data. Like most websites, we use "cookies" to help us make our website – and the way you use it – better. There are more details in our section on Cookies below. In addition, with regard to each of your visits to our website we will automatically collect certain information e.g. your IP address used to connect your computer to the internet, your browser type and language.
- Marketing and communications data based on your preferences in receiving information from us.
- If you are a healthcare professional ("HCP"), we may collect additional personal information about you either through your use of the website or in relation to other interactions that you have with Adaptimmune, including:
- personal details, including your name, age, gender and contact details;
- professional details such as your job title, your professional field of expertise, your professional credentials, data related to your membership of associations and boards and any other professional affiliations you may have, and data relating to scientific research, publication of your research and articles, adverse event data and data related to your use of our products and your interactions with us; and
- details of any interactions with Adaptimmune, including information relating to your use of our products, and the services you provide to your patients.
- We may collect and use personal data about you in order to comply with our adverse event reporting obligations which may include information such as your date of birth, gender and information about your health.
We use a database tool provided by Equisolve Inc. (“Equisolve”) to provide investor relations information to you if you have provided your contact details in order to receive such investor relations information.
We also collect aggregated data such as statistical or demographic data to monitor and obtain information on the use of our website. We may also use analytics providers such as Google Analytics to provide this aggregated data and information.
If you provide personal information in a CV or other application form as part of our recruitment process or when otherwise applying for a job vacancy with us (which may include but not be limited to your contact information, such as your home address and contact details (including your mobile telephone number), your date of birth, your academic background, educational and professional qualifications, your right to work, visa status, employment history and status; and any other information about you that you disclose to us during the application process) information about the way in which that personal data will be used and processed by Adaptimmune will be communicated to you in a separate privacy notice.
WHAT DO WE DO WITH THE INFORMATION YOU PROVIDE?
We will only use your personal data for the purposes for which it was initially collected. We may use your personal data for the following reasons:
- We may use your contact information to send you information about the website or to provide you with updates or notifications (for example, to provide you with e-mail alerts unless you indicate at any time that you do not wish us to do so).
- We may use your contact information to provide investor relations information, where you have opted to receive such information.
- We may use your contact information to respond to you where a response is requested or required.
In addition to this we may use the information collected for one or more of the following purposes:
- To provide information to you that you request from us relating to our services, products or our clinical trials.
- To provide information to you relating to other similar services, clinical trials or developments that may be of interest to you (unless you indicate at any time that you do not wish us to do so).
- To inform you of any changes to our website, services or clinical trials.
- To operate our business effectively and in accordance with our legal obligations as a pharmaceutical company developing medicinal products. This includes responding to reports that you make, or that someone else makes on your behalf, relating to adverse events suffered in the course of a clinical trial to enable us to monitor product safety, complying with applicable laws, regulation and guidance, which might include responding to the requests of regulators, government agencies or the courts.
- To operate our business in accordance with our legal obligations as a company listed on NASDAQ. This includes compliance with the SEC (Securities Exchange Commission) guidelines and regulations.
- To engage with third parties with whom we have a contractual relationship or a legitimate interest in so doing.
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To improve our operations. This might include research to analyze trends and use of our website for internal review purposes or to improve the services we provide to you.
If you are an HCP, we collect and process your personal data to manage our contractual relationship with you (or the Healthcare Organisation you work for) or if we have a legitimate interest in processing your data. This may include planning or effecting collaborations with you, arranging visits or meetings and better understanding your areas of expertise and interest so that we can ensure our communications to you are relevant.
We may use this information to contact you both online and offline if required.
WHAT ARE THE LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION?
Data Protection Legislation permits Adaptimmune to process your personal data in the way that we do because the processing is:
- necessary for the performance of our contract with you, including to provide you with products or information you have requested;
- necessary in order to comply with a legal obligation to which we are subject;
- necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business; to discharge our legal obligations; to store and disclose information where necessary; to evaluate, develop and improve our services; to keep our clients and suppliers informed about our business services; to respond appropriately to queries received about our business and products; to prevent fraud; to protect our business interests; and to ensure complaints are investigated; or
- for purposes that are not incompatible with the purposes we have described to you above, including archiving purposes in the public interest, scientific research or statistical purposes, if permitted by Data Protection Legislation.
We will make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will generally rely on your specific consent in order to process such data. However, it may be necessary for us to use certain personal data in order to comply with our legal obligations.
IS YOUR PERSONAL INFORMATION PROVIDED TO ANYONE ELSE?
We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Those third parties may then use your personal data for the same reasons as set out in this policy and in accordance with Data Protection Legislation.
We may also share your personal data with third parties where we are legally required by law to disclose your personal information; or to further fraud protection and reduce the risk of fraud; or where we consider disclosure is necessary to exercise, defend or protect our legal rights; or to protect your vital interests or those of other people. In relation to our adverse event reporting obligations we may need to share your personal data with appropriate regulatory third parties.
In certain cases we may obtain your consent to share your contact details with another third party. In such circumstances we will let you know who that third party is and why we need to share your details.
CAN I FIND OUT WHAT INFORMATION YOU HOLD ON ME?
You have the right to access your personal information that we hold.
You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
WHERE DO YOU STORE MY PERSONAL DATA?
We may store your personal data at any of our group companies namely Adaptimmune LLC, Adaptimmune Therapeutics plc or Adaptimmune Limited. All personal data is stored securely. We may also transfer your personal data to third party subcontractors or website service providers to store on our behalf.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that is not deemed to provide adequate protection of your information by the European Commission. It may also be processed by staff operating outside the EEA who work for us or for one of our subcontractors or suppliers. We may share, transfer or store your personal data within our group of companies, including our subsidiary Adaptimmune LLC based in Philadelphia, U.S. All of the Adaptimmune companies are subject to the same privacy rules when processing your personal data. Where we transfer your personal data to an Adaptimmune company or a third parties outside of the EEA that is not deemed to provide adequate protection of your information by the European Commission we will make sure that such Adaptimmune company and any third parties provide an adequate level of protection for your personal data and so that the transfer is permitted under Data Protection Legislation, including by implementing appropriate safeguards.
We will ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your information from unauthorized access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data you transmit to our website; any transmission is at your own risk.
THE ACCURACY OF YOUR PERSONAL DATA
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
YOU LEGAL RIGHTS
You have certain legal rights in relation to your personal data, namely a right to request access to your personal data, a right to request correction of your personal data if you consider that it is inaccurate, or delete it, if you consider that we do not have the right to hold it, a right to erasure of your personal data, a right to object to processing of your personal data in certain circumstances, a right to request restriction of processing of your personal data in certain circumstances, a right to request transfer of your personal data and a right to withdraw consent to processing of your personal data (to the extent such processing is based on previously obtained consent).
Further detail on the above rights can be found on the Information Commissioner’s website; www.ico.org.
You will not have to pay a fee to exercise your legal rights. However we may be permitted to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may also be permitted to refuse to comply your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your legal right to access or exercise any other rights in relation to personal data. This is to ensure we do not give your personal data to the wrong person.
HOW QUICKLY WILL YOU RESPOND TO ANY REQUEST?
We will endeavour to respond as soon as reasonably possible and in any event within one month of receiving a request to exercise any rights in relation to your personal information in compliance with Data Protection Legislation. Occasionally it may take us slightly longer if your request is particularly complex or you have made a number of requests.
Adaptimmune is not responsible for the content of third party websites or for how these websites handle your personal data and your use of these websites is at your own risk.
WHAT IS A COOKIE?
A cookie is a piece of information, in the format of letters and numbers as a small text file that is placed on your computer by web page servers when you visit a website. The information the cookie contains is set by the server and it can be used by that server whenever you visit the website in order to distinguish you from other website visitors.
You can learn more about how to manage your cookies by visiting the Help function of your internet browser, or you can visit www.aboutcookies.org which provides detailed information on managing cookies on popular browsers.
Please be aware that parts of the website may not function correctly if you disable cookies and you may not be able use the website features to its fullest.
Cookies can be categorised in accordance with the categories found in the ICC UK cookie guide as set out below:
- Strictly necessary cookies – these cookies are essential in order to enable you to move around a site and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
- Performance cookies – these cookies collect information about how visitors use a site (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
- Functionality cookies - these cookies allow a site to remember the choices a user makes, such as a user name or language preference.
- Targeting or advertising cookies - these cookies collect information about a user's browsing habits and are usually placed by advertising networks with the site operator’s permission.
Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the site, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended.
WHAT DO WE DO WITH YOUR IP ADDRESS AND COOKIES?
We use your IP address to help diagnose problems with our server and to administer our website. Your IP address is used to gather broad demographic information and is stored as a partial identifier.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only hold your personal data for as long as reasonably necessary to fulfill the purposes for which it was originally collected. In considering how long to retain personal data we take into account the type of personal data, the purposes for which we process your personal data and applicable legal requirements.
We do not carry out automated decision-making or profiling in relation to your personal information.
CONTACTING US WITH ANY QUERIES
If you have any questions about this privacy statement, the practices of this website, or use of our trademarks and copyrighted material, or for any other concerns please feel free to contact us.
If you have any concerns about our use of your information, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so would be grateful if you could reach out to us first.