Privacy Policy

Adicet Bio, Inc., owner of this website, respects your privacy and understands that you care about your personal data and how it is used. We value your trust in sharing your personal data with us and are dedicated to protecting your privacy, as further described in this Privacy Notice.

For EEA Residents
针对中国用户
 

Privacy Notice for United States Residents

Last Updated: November 1, 2024

This Privacy Notice applies to the processing of data related to the use of our website, https://www.adicetbio.com, or any social media site, mobile sites, or online application owned and/or operated by the Adicet, including any content, functionality and services offered on or through these sites or channels (hereinafter, our “Websites”) and our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Notice does not apply to information collected by us offline or through any other means not included in the above-provided definition of our Websites; or by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

California residents may visit our Additional Information for California Residents for an overview of our practices.

The Privacy Notice is valid for all pages hosted on the Website. It is not valid for the pages hosted by third parties to which we may refer and whose privacy notices may differ. We cannot therefore be held responsible for any data processed on these websites or by them. This Privacy Notice also applies to any other website that we may operate, including Adicet pages on LinkedIn.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Section 11: Changes to Our Privacy Notice). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

1. Information We Collect About You and How We Collect It

We collect several types of information from you about users of our Websites, including information:

  • By which you may be personally identified, such as name, postal address, email address, and/or telephone number (“personal information”).
  • That is about you but individually does not identify you, such as what classifications you fit into (e.g., patient, caregiver, healthcare provider, investor, media, etc.).
  • Records or copies of correspondence between you and Adicet.
  • About your internet connection (including your IP address, operating system and browser type), your search queries on our Websites, the equipment you use to access our Website and other usage details (including traffic data, location data, logs and other communication data and the resources that you access and use on our Website). 
  • Your responses to surveys that we might ask you to complete for research purposes related to our business.


How we collect this information:

  • Directly from you when you post it on our Websites or otherwise provide it to us via our Website (e.g., by completing online forms on our Website (e.g., registration forms on our Website for our services)), or by mail, email, fax, or phone.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies or other tracking technologies.
  • From third parties such as our business partners and agents.


2. Information You Provide to Us

The information we collect on or through our Websites may include:

  • Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our service, posting material, or requesting further services, such as your name, postal address, email address, and/or telephone number. We may also ask you for information when you report a problem with our Websites.
  • Information you provide by filling out job applications, such as resumes/CVs, email address, job title, job history and other background information.
  • Records and copies of your correspondence between you and Adicet.
  • Information about your marketing preferences and details about how you engage with our communications
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Your search queries on the Websites.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contribution. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

3. Information Collected Automatically

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your device type, IP address, operating system, and browser type.

The information about you that we collect automatically does not identify you personally, but rather only by reference to the device you use to access our Websites. This information tells us about your usage of our Websites, which helps us to improve our Websites and to deliver a better and more personalized service to you. By enabling us to take into account your usage patterns and preferences, this information helps us to customize our Websites according to your individual interests, to speed up your searches, and to recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

  • Cookies (browser or flash cookies): A browser cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Certain features of our Websites may also use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. You may limit access of flash cookies to your computer with add-ons and other tools available online. If you limit access of cookies, you may be unable to access certain parts of our Websites. Unless you have adjusted your settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
  • Web Beacons: Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may link non-personal information collected automatically to personal information about you that we otherwise collect as described in this Notice or that you provide to us.

4. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our Websites, are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest- based (behavioural) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible advertiser or content provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Section 5: Choices About How We Use and Disclose Your Information and our Cookie Notice.

5. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To respond to your inquiries for information, and to provide you with information about Adicet and its products and services, by email, regular mail, text message or phone according to your preferences.
  • To present our Websites and its contents to you.
  • For marketing and advertising, including to send you emails and other promotional communications and to display ads about us and our services around the web (including through the use of cookies and similar technologies to target ads based on your interactions over time across our Website, our communications, and other online services.
  • For statistical purposes and to improve and further develop our Websites and the information and services we may offer from time to time.
  • To request your participation in Adicet surveys and other market research which can include requests for demographic, geographic or other personal information and other data which Adicet may use to create useful services and information for users of our Websites and for other lawful business purposes.
  • For job applications.
  • To provide you with notices, information, products, or services that you request from us.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Adicet.
  • To notify you about changes to our Websites or any products or services we offer or provide through it.
  • To allow you to participate in interactive features on our Websites.
  • For the use of cookies in the function and management of our Websites.
  • To prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • For any other purpose with your consent.

Some of our Websites or forms in which we collect information from you may have an “opt-in” option for you to allow Adicet and companies working on its behalf to communicate with you regarding information and services that may be available to you. If you register for one of our Websites, we may provide you with information or services consistent with the information you provide.

6. Disclosure of Your Information

We may disclose personal information that we collect, or you provide as described in this Privacy Notice:

  • To our subsidiaries and affiliates who are required to comply with this Privacy Notice.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Adicet's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Adicet about users of our Websites is among the assets transferred.
  • To fulfil the purpose for which you provide it. 
  • With your consent and/or for any other purposes disclosed by us when you provide the information.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Adicet, users of our Websites, or others.


7. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the information we collect from you and/or the information you provide to us. For example, you may: (1) choose not to provide personal information on our Websites, (2) set your browser preferences and use web tools available to block the cookies sent in connection with your use of our Websites, (3) follow the instructions to unsubscribe from our services included on our Websites and the communications sent to you, and/or (4) email a request to unsubscribe from our services to contact@AdicetBio.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

8. Accessing and Correcting your Information

You may send us an e-mail at to privacy@adicetbio.com  to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

If you delete your User Contributions from our Websites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of our Websites. Proper access and use of information provided on our Websites, including User Contributions, is governed by our Terms of Use.

9. Your State Privacy Rights

In certain circumstances, state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. 

Residents of certain U.S. states may have some or all of the following rights, where applicable to our practices:

  • Right to Know: confirm whether we process their personal information.
  • Right of Access: You have the right to obtain confirmation as to whether or not personal information concerning you are being processed, and, where that is the case, information related to the processing of data and a copy of the data being processed.
  • Right to Delete: You have the right to delete your personal information under certain specified circumstances.
  • Right of Rectification: Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
  • Right to Data portability: You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your personal information.
  • Right to Opt-out of: targeted advertising and sharing personal information for targeted advertising; and selling personal information, if applicable.
  • Limit our use of sensitive data: Either limit (opt-out of) or require consent to process sensitive personal information.

The exact scope of these rights may vary by state and certain rights may not be applicable to our practices. To exercise any of these rights please let us know by contacting us at privacy@adicetbio.com or by contacting our DPO at adicet.dpo@mydata-trust.info. 

10. Data Security and Retention

We have implemented measures designed to protect your personal information from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure networks and behind firewalls and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

Although we do our best to protect your personal information, we cannot guarantee the transmission of information via the internet is completely secure. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites. 

We retain personal information about you for as long as necessary to provide you with information you request and to operate our website. We will keep this information for no longer than necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregate form where that information would not identify you personally.

11. Children Under the Age of 13

Our Websites are not directed at children under 13. If you believe we have any information from or about a child under 13 without parental or guardian consent, please contact us at  so that we may identify and delete that information.

12. Changes to this Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through notices on our Websites. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Notice to check for any changes.

13. Contact Information

Adicet Bio, Inc.
131 Dartmouth Street, 3rd Floor,
Boston, MA 02116
privacy@adicetbio.com
 

ANNEX Y: Additional Information for California Residents

Depending on your residency, you may have certain additional information and certain rights, where such rights are applicable to our practices. In the United States, these rights vary by States.

If you are a Californian resident, additional information should be provided as follows:

Here is a high-level snapshot of our privacy practices, but you need to read the entire Privacy Notice for complete information.

Data Category Collected How We Collect Primary Purpose of Processing Key Disclosures* Can You Limit Sharing?
Identifiers, such as name, email address, and IP address When you visit the Websites; from third-party sites and services; To deliver our Websites; to improve, monitor, personalize and protect our Websites; to communicate with you; to conduct surveys; for marketing and advertising Service providers No
Marketing and advertising partners Yes
Personal information categories listed in the California Customer Records Statute (e.g., name, contact details) When you visit the Websites; from third-party sites and services To deliver our Websites; to improve, monitor, personalize and protect our Websites; to communicate with you; for marketing and advertising Service providers No
Marketing and advertising partners Yes
Commercial information, including but not limited to records of products or services purchased When you visit or use our Websites To deliver our Websites; to improve, monitor, personalize and protect our Websites; to communicate with you; for marketing and advertising Service providers No
Marketing and advertising partners Yes
Professional or employment-related information When you visit or use our Websites; from public or third-party information sources To provide our Websites; to improve, monitor, and personalize our Websites; for marketing and advertising; to process your job application Service providers No
Marketing and advertising partners Yes
Internet or other electronic network activity information, including but not limited to browsing history and search history When you visit or use our Websites; from third-party sites and services To improve, monitor, personalize and protect our Websites; for marketing and advertising Service providers No
Marketing and advertising partners Yes
Inferences drawn from information to create a profile about your behavior, preferences, etc. When you visit or use our Websites; from third-party sites and services To improve, monitor, personalize and protect our Websites; for marketing and advertising Service providers No
Marketing and advertising partners Yes

*As described further in our Privacy Notice, we may disclose all categories of personal information to our service providers, affiliates, and professional advisors for the purposes described in the Privacy Notice. We also may disclose personal information to authorities and others for legal and compliance purposes, and to business transferees in the context of an acquisition or the sale of our business or another corporate transaction.

Do Not Track (“DNT”) requests. DNT is an optional browser setting that allows you to express your preferences regarding tracking by advertisers or other third parties. Some web browsers may allow you to transmit a “Do Not Track” signal to online services and websites. If a website receives such signal, the web browser can block that website from collecting certain Personal Information about you. We will try our best to respond to global privacy controls, including DNT signals. However, we do not assume liability for failure to comply with DNT signal by our partners and / or providers.

If you are a California resident, you have the following rights with respect to your Personal Information, where such rights are applicable to our practices:

“Shine the Light ”and “Eraser” Laws.  You may request a list of all third parties to which we have disclosed certain information for those third parties’ direct marketing purposes.

The right to know. You may have the right to request that we disclose to you the personal information we have collected or sold about you and how it is used and shared. Here is the information you may have access to:

  • the categories of personal information collected;
  • the categories of sensitive personal information collected; 
  • the categories of sources from which the personal information or sensitive personal information is collected; 
  • the business purpose for such collection and sharing; 
  • the categories of third parties to whom to personal information or sensitive personal information is disclosed to; 
  • the specific pieces of personal information collected; 
  • the length of time that the business intends to retain each category of personal information and sensitive personal information. 


The right to access. You may have the right to access personal information which we may collect or retain about you free of charge (for which we have 45 days to respond). If requested, we shall provide you with a copy of your personal information which we collect. You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

The right to opt-out of sale/sharing of my personal information. California residents have the right to opt out of “selling” or “sharing” personal information for targeted advertising purposes. We use cookies and other similar technologies on our website for various purposes as described in our Cookie Notice, but we do not “sell” or “share” personal information. You may have the ability to reject or toggle off optional cookies through a cookie banner on our Website. Please note that your opt out will be specific to the device and browser you use when you opt out.

The right to limit use of sensitive personal information. You may be able to ask us to limit our use of sensitive personal information, such as health information. In general, because we use such information only to provide the Websites for you and for internal purposes, and not for advertising, we may not need to take additional steps to limit use of your information further in response to a request. 

The right to correct inaccurate personal information. You have the right to require rectification of inaccurate personal information about you. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your personal information as directed within 45 days (with the possibility to extend the period once), taking into account the nature of the personal information and the purposes of maintaining your personal information. 

The right to request deletion of personal information. You have the right to request the deletion of your personal information collected, or maintained by us, subject to certain exceptions permitted by law. In the event of a request for deletion, we will acknowledge receipt of your request within ten (10) business days and will endeavour to respond substantially within forty-five (45) days.

The right to not be subject to discrimination (“right to equal service and price”). You have the right not to be denied of goods or services, to be charged for different prices or rates for goods or services or provided a different level or quality of goods or services.

The right to file a complaint. You have a right to lodge a complaint. You can file a complaint with the California Privacy Protection Agency and, where appropriate, the California Attorney General’s office, at the following addresses:
California Privacy Protection Agency: info@cppa.ca.gov
California Office of Attorney General: https://oag.ca.gov/contact

 

For EEA Residents

Last updated: November 1, 2024

This Privacy Notice applies to the processing of data related to the use of the website https://www.adicetbio.com/ (hereinafter “the Website”) for visitors from the European Economic Area,(EEA). 

This Privacy Notice applies to the processing of data related to the use of our website, https://www.adicetbio.com, or any social media site, mobile sites, or online application owned and/or operated by the Adicet, including any content, functionality and services offered on or through these sites or channels (hereinafter, our “Websites”) and our practices for collecting, using, maintaining, protecting and disclosing that information. 

Adicet Bio, Inc. is the Controller, hereinafter as “Adicet”, “we” or “us”, of the personal data, processed under this Privacy Notice. 

With this Privacy Notice, Adicet wants to make sure that you understand what personal data is collected about you, how your personal information is used and how it is kept safe. 

General warning and use of social media

The Notice is valid for all pages hosted on the Website. It is not valid for the pages hosted by third parties to which Adicet may refer and whose privacy notices may differ. Adicet cannot therefore be held responsible for any data processed on these websites or by them. This Notice also applies to any other website that Adicet may operate, including our Company pages on Twitter, Facebook, and LinkedIn.

1. What personal data do we collect?

Information you provide to us. Personal data you may provide to us through the Website or otherwise includes:

  • Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our service, posting material, or requesting further services, such as your name, postal address, email address, and/or telephone number. We may also ask you for information when you report a problem with our Websites.
  • Information you provide by filling out job applications, such as resumes/CVs, email address, job title, job history and other background information.
  • Records and copies of your correspondence between you and Adicet.
  • Information about your marketing preferences and details about how you engage with our communications
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Your search queries on the Websites.


Third party sources. We may combine personal data we receive from you with information we obtain from other sources, such as:

  • Third party data providers. We may obtain personal information about you from third parties such as data brokers, recruiters and from publicly available sources such as LinkedIn. This information may include name, email, phone, work history, location, and other similar information. We only work with trusted partners who commit to comply with applicable data protection laws. 
  • Social media. We may maintain pages on social media platforms, such as Twitter, Facebook and LinkedIn. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this privacy notice.


Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Notice.

2. Why, how and for how long do we collect your personal data? 

Depending on the purpose for which we process your personal data, we need to process one or other personal data. We retain personal data about you for as long as necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. We may further retain information in an anonymous or aggregate form where that information would not identify you personally.

Depending on each case, we use your personal data for the following purposes, or as otherwise described at the time of collection:

Purposes Legal basis
To respond to your inquiries for information, and to provide you with information about Adicet and its products and services, by email, regular mail, text message or phone according to your preferences. This processing is based on our legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.
To provide the Website, its content and associated services; to provide you with notices, information, products or services that you required from us. We may notify you about changes to our Websites or any products or services we offer or provide through it. This processing is either based on contractual necessity where we have a contract with you, or on our legitimate interests to provide you with services you have requested.
For statistical purposes and to improve and further develop our Websites and the information and services we may offer from time to time. This processing is based on our legitimate business interest in analysing and improving our services.
For marketing and advertising, including to send you emails and other promotional communications (including newsletters) and to display ads about us and our services around the web (including through the use of cookies and similar technologies to target ads based on your interactions over time across our Website, our communications, and other online services. Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests.
To request your participation in and otherwise conduct Adicet surveys and other market research which can include requests for demographic, geographic or other personal information and other data which Adicet may use to create useful services and information for users of our Websites and for other lawful business purposes. Except where consent is required, we undertake such surveys on the basis of our legitimate business interests.
For job application This processing is based on our legitimate interest for the purpose of our recruitment process in order to administer and appraise job applications. We understand that the processing of these data is also beneficial to you to the extent that it enables you to get a job by providing a spontaneous application or answering to an offer.
To organize your participation in one of our events This processing is based on our contractual obligations
To prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. We consider that we have lawful interest to understand the way our page is consulted (e.g., how many times our page is consulted, from which country,…).
For compliance and protection purposes, including to: audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce our terms and conditions, and to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. We may have a legal obligation to undertake these processing activities. Otherwise, it is in our legitimate business interests to use your personal information for these purposes, including to defend us against legal claims or disputes.
Use of cookies Cookies may store in certain circumstances personal data which may include: IP addresses, browser type, location, operating system.

Please, see our Cookie Notice for more information.

3. Data sharing

We do not sell or trade to outside parties your personal data. 

We may disclose personal data that we collect, or you provide as described in this Privacy Notice:

  • To our subsidiaries and affiliates who are required to comply with this Privacy Notice.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Adicet's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Adicet about users of our Websites is among the assets transferred.
  • To fulfil the purpose for which you provide it. 
  • With your consent and/or for any other purposes disclosed by us when you provide the information.

You will provide personal data directly to us in the United States. 

Sharing your personal data as explained above may involve a transfer of personal data to a country outside the EEA. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country. Adicet is therefore committed to complying with the transfer rules under applicable data protection laws and therefore will ensure to: 

  • Transfer your data to countries where the data recipient is located that has been recognized as adequate; or
  • Where a country has not received an adequacy decision, to implement appropriate safeguards, such as the EU Standard Contractual Clauses (“SCCs”).

You can contact our Data Protection Officer, hereinafter as DPO, (see contact details below), if you want to have more details about the mechanism supporting data transfer. 

4. How do we protect your information?

We have implemented measures designed to protect your personal data from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure networks and behind firewalls and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

Although we do our best to protect your personal data, we cannot guarantee the transmission of information via the internet is completely secure. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites. 

5. Your rights

You may have the following rights subject to limitation as set forth by applicable data protection law: 

  • Access. the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, information related to the processing of data and a copy of the data being processed.
  • Rectification. the right to require rectification of inaccurate or incomplete data about you.
  • Right to be forgotten. the right to obtain the deletion of your personal data under certain specified circumstances.
  • Restrict processing. the right to restrict processing of data under certain specified circumstances.
  • Data portability. the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your personal data.
  • Object to processing. the right to object, on grounds relating to your particular situation, at any time to the processing of your data. 
  • Right to withdraw consent. When you have given your consent for the processing of your data, you can withdraw it at any time without any cost nor justification.


Please note that all these rights are not absolute and will be assessed on a case-by-case basis by our DPO.  

If you would like to exercise your rights, or you are not satisfied with how we address your request,  please let us know by contacting our DPO, Adicet.dpo@mydata-trust.info.

You have also the right to lodge a complaint if you consider that your personal data is not processed in accordance with the EU GDPR.

Depending where you reside, you have the right to lodge a complaint with the national data protection authority of your habitual residence, place of work or place of the alleged infringement. 

Please find the contact information of all Authorities in section 7 “Contacts”.

5. Children Under the Age of 13

It is not our intention to collect personal information from children under the age of 13 through our Websites or otherwise. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Notice by instructing their children never to provide us personal information. If you have reason to believe that a child under age 13 has provided personal information to us through our Websites, please contact us at privacy@Aadicetbio.com so that we may identify and delete that personal information from our records, unless other applicable law requires us to retain that information

6. Changes to this Privacy Notice

This Notice is effective as of the date stated at the top of this page. We may change this Notice from time to time. Please refer to this Notice on a regular basis.

7. Contacts

Adicet Bio, Inc., acting as Controller
131 Dartmouth Street, Boston, MA 02166
privacy@adicetbio.com

Data Protection Representative (EU)
Rue de Rennes, 140b, 75006 Paris (FRANCE) 
Adicet.dpr.EU@mydata-trust.info

Data Protection Officer 
adicet.dpo@mydata-trust.info

For EU Data Protection Authorities
https://edpb.europa.eu/about-edpb/about-edpb/members_en
 

Privacy Notice
Personal Information Protection Law of the People’s Republic of China

Adicet Bio, Inc. (“Adicet Bio,” “Company,” “we,” or “us”) processes information as required by Articles 7, 17, 23, and 30 of the Personal Information Protection Law (“PIPL”), and personal data will be processed in accordance with the following:

1. Subject matter of the processing
Adicet Bio processes personal data collected from various sources, including clinical study submissions, our websites, or third parties authorized by the data subject. This personal data may include any information that can identify an individual, such as names, employment history, contact details, biometric or health data, pseudonymised data, or other sensitive information.

2. Objectives
a. Personal data will be processed only with express consent (Article 13 of the PIPL) and for the purposes provided during the consent process.
b. Personal data that will be processed without express consent (as established in Article 13 of the PIPL) for the following objectives:

  • To fulfil contractual, pre-contractual, and other obligations with the individual,
  • To fulfil legal obligations as required by laws, regulations, or administrative orders,
  • To exercise Adicet Bio’s rights, such as the right of defence in litigation.


3. Processing of Data
The processing of personal data is based on Articles 5 and 6 of the PIPL. It must be for a specified, reasonable purpose and conducted in a manner directly relevant to the notified purpose, with the least impact on individual rights and interests. The collection of personal information shall be limited to the minimum necessary to achieve the processing purpose.

4. Recipients of Data
The data will be processed exclusively by authorized individuals and processors who are properly instructed and under contract with Adicet Bio. The processing by third parties is limited to what is necessary as established by Articles 5 and 6 of the PIPL.
Data may be communicated to administrative and judicial authorities to meet legal obligations and legislative requirements.
An updated list of processors can be requested from Adicet Bio.

5. Lawfulness of the processing
The lawfulness of processing is based on Article 13.1 (consent), Article 13.2 (contractual need), and Article 13.3 (statutory obligation) of the PIPL.

6. Data Protection Requests
Data protection requests can be addressed to: 

Adicet Bio, Inc.
Attn: Privacy
131 Dartmouth Street, 3rd Floor,
Boston, MA 02116
privacy@adicetbio.com

7. Data Subject Rights
Data protection rights can be requested regarding personal data. These rights are established by Articles 15, 24, 44, 45, 46, 47, and 48 of the PIPL (right to access by the data subject, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object, and the right not to be subjected to automated decision-making).

8. Data Retention
Adicet Bio processes personal information within the minimum scope necessary to achieve the processing purpose. The retention period for personal information is the minimum period necessary, unless otherwise required by law or administrative regulations or agreed by the data subjects.

9. Transfer of Data Outside of China
The management and conservation of personal data are conducted on databases located in China and outside of China. For data processed outside of China, Adicet Bio will obtain specific consent from the individual and ensure the transfer follows required legal provisions, including agreements published by the Cyberspace Administration of China, if necessary, to guarantee a protection level equivalent to PIPL standards.

10. CONTROLLER AND PROCESSOR
The “Personal Information Handler” of data is Adicet Bio, Inc.
 

Privacy Notice
Personal Information Protection Law of the People’s Republic of China

基于《中华人民共和国个人信息保护法》的隐私通知

Adicet Bio, Inc.（“Adicet Bio”、“公司”、“我们”或“我方”）根据《个人信息保护法》第7条、第17条、第23条和第30条的要求处理个人信息，并遵循以下规定：

1. Subject matter of the processing / 处理的主要内容
Adicet Bio处理通过多种渠道收集的个人信息，包括临床研究的实施、我们的网站或经过数据主体授权的第三方收集的个人信息。此类个人信息可能包括任何可识别个人身份的信息，包括但不限于姓名、工作记录、联系方式、生物识别或健康数据、去标识化数据或其他敏感信息。

2. Objectives / 目的
a. 个人信息将仅在获得明确同意的情况下进行处理（《个人信息保护法》第13条），并用于同意过程中告知的目的。
b. 在未经明确同意的情况下，根据《个人信息保护法》第13条，将基于以下目的处理个人信息：

  • 履行与个人签订的合同、先合同及其他义务；
  • 履行法律、法规或行政机关规定的法律义务；
  • 行使Adicet Bio的权利，例如诉讼中的权利。


3. Processing of Data / 信息的处理
个人信息的处理应根据《个人信息保护法》第5条和第6条，基于特定、合理的目的进行，并与告知的处理目的直接相关，以尽量减少对个人权利和利益的影响。收集的个人信息应限于实现处理目的所必需的最小范围。

4. Recipients of Data / 信息的接收者
信息将仅由经授权的、接受适当指示并与Adicet Bio签订合同的个人或组织处理。第三方处理的信息应限于《个人信息保护法》第5条和第6条规定的必要范围。
信息可能会传递给行政和司法机关以履行法律义务和立法要求。
您可向Adicet Bio索取最新的处理者名单。

5. Lawfulness of the processing / 处理的合法性
处理的合法性基于《个人信息保护法》第13条第1款（同意）、第13条第2款（合同需要）和第13条第3款（法定义务）。

6. Data Protection Requests / 信息保护请求
同个人信息保护有关的请求可发送至：
Adicet Bio, Inc.
Attn收件人: Privacy
131 Dartmouth Street, 3rd Floor,达特茅斯街131号3楼
Boston, MA 02116波士顿，马萨诸塞州02116
privacy@adicetbio.com

7. Data Subject Rights / 信息主体权利
个人信息保护权利可以被行使，这些权利包括《个人信息保护法》第15条、第24条、第44条、第45条、第46条、第47条和第48条规定的权利（如查阅权、修正权、删除权、限制处理权、数据可携权、拒绝权、不接受自动化决策的权利）。

8. Data Retention / 信息保存
Adicet Bio对个人信息的处理应限于实现处理目的的最小范围，除法律或行政法规另有规定外，个人信息的保存期限应为实现处理目的所必需的最短时间。

9. Transfer of data outside of China / 个人信息跨境提供
个人信息的管理和存储在中国境内和境外的数据库中进行。对于在境外处理的信息，Adicet将取得数据主体的单独同意，并确保数据传输遵循相关法律规定，并在必要时签订国家网信办发布的标准合同，以确保达到《个人信息保护法》规定的保护水平。

10. CONTROLLER AND PROCESSOR / 个人信息处理者和处理人
“个人信息处理者”为Adicet Bio, Inc.