Privacy Policy

Effective as of September 29, 2022.

This Privacy Policy describes the privacy practices of Aditum Bio Management Company, LLC ("Aditum," "we", “us” or "our") and how we handle personal information that we collect through our digital properties that link to this Privacy Policy (the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), please consult the EEA/UK GDPR supplemental notice below.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, email address, mailing address, professional title, organizational affiliation, and phone number.
Identity data, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
Communications that we exchange with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.
Registration Information, such as information that may be related to a product or an event for which you register.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Financial data, such as your income, economic status, financial account numbers, investment holdings and preferences, and ability to invest.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

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

Public sources, such as public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors that provide demographic and other information.
Business and marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, 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, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, 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 Service, 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.

Cookies and similar technologies. Like many online services, we may use the following technologies:

Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.
Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

provide, operate and improve the Service and our business, including researching prospective and current portfolio companies and financing them;
establish and maintain your user profile on the Service;
conduct Know Your Customer checks and other screens permitted by law;
process payments and transactions with you;
enable security features of the Service, such as by sending you security codes, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We and our service providers may collect and use your personal information for marketing purposes. We may send you Aditum-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, email delivery, marketing, and website analytics).

Investment partners. Portfolio companies, investors, and others who may be interested in you or your business.

Business and marketing partners. Third parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Aditum or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your choices

You have the following choices with respect to your personal information. Users who are located in the EEA or UK can find additional information about their rights in the EEA/UK GDPR supplemental notice below.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, please visit our Cookie Policy.

Local storage. You may be able to limit use of HTML5 cookies in your browser settings. Unlike other cookies, Flash-based local storage cannot be removed or rejected via your browser settings, but you can adjust the settings of your Flash player to block it. Blocking Flash storage may impede the functionality of Flash applications, including those employed by the Service. For more information on Flash local storage visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com or consult our Cookie Policy to understand how you can opt out of receiving cookies.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in the UK and the EEA should read the important information provided in the EEA/UK supplemental notice below about transfer of personal information outside of the EEA and UK, as applicable.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

How to contact us

Aditum Bio Management Company, LLC

Address:

1111 Broadway Suite 1300

Oakland, CA 94607

Telephone: (510) 227-2101

Email: info@aditumbio.com

EEA/UK GDPR Supplemental notice

If you are located in the EEA or the UK and access our Services, this EEA/UK GDPR supplemental notice applies to you. For the purposes of this section ‘personal information’ shall mean ‘personal data’ as defined in the General Data Protection Regulation 2016/679.

Who is the controller?

Aditum Bio Management Company, LLC is the controller of your personal information.

Who is the EU representative?

Aditum has appointed European Data Protection Office as its EU representative, which can be contacted:

-By using EDPO’s online request form at https://edpo.com/gdpr-data-request; or

-By writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

Who is the UK representative?

Aditum has appointed EDPO UK LTD as its UK representative, which can be contacted:

-By using EDPO’s online request form at https://edpo.com/uk-gdpr-data-request; or

-By writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

Who is the Data Protection Officer (“DPO”)?

Aditum’s Data Protection Officer can be contacted at privacy@aditumbio.com.

Our legal basis for using your personal information

Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing as set out in the table below.

Processing Purpose

Legal Basis

We need to process your personal information to operate our Services, including establishing and maintaining your user profile, managing your transactions, responding to your requests or inquiries, providing you with access to content or information you requested, etc.

The processing of your personal information is necessary to perform the contract governing the provision of our Services or to take the necessary steps prior to signing up for the Services.

We may need to process your personal information for additional purposes, such as:

Research and development purposes
To ensure access and maintenance of our Services, and to ensure their proper functioning
For marketing purposes
For compliance, fraud prevention and safety
For sharing your personal information with third parties as described in this Privacy Policy
To disclose your personal information to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets.
To protect our interests as a company, for different purposes, such as:
- Enforcement of the Terms of Service
- Assess claims that any content violates the rights of third-parties
- Establishing or exercising our legal rights or defending against legal claims

We rely on our legitimate interests to process your personal information when performing these processing activities. We do not use your personal information for these purposes where our interests are overridden by the impact on you.

We are subject to certain legal obligations that may oblige us to disclose your personal information to courts, law enforcement or regulatory authorities.

The processing of your personal information is necessary to comply with our legal obligations.

You may allow third party ad partners and advertisers to use tracking technologies while you use our Website or Services.

In these scenarios, the processing of the personal information you voluntarily provide to us is based on your consent. Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent to the processing.

Your rights

Under applicable EU and UK data protection laws, you have the following rights in respect of your personal information:

to obtain information about how and on what basis your personal information is processed and to obtain a copy;
to rectify inaccurate personal information;
to erase your personal information in limited circumstances where (i) you believe that it is no longer necessary for us to hold your personal information; (ii) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (ii) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (iv) where you believe the personal information we hold about you is being unlawfully processed by us;
to restrict processing of your personal information where: (i) the accuracy of the personal information is contested; (ii) the processing is unlawful but you object to the erasure of the personal information; (iii) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim; or (iv) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
to object to decisions which are based solely on automated processing or profiling;
where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
to obtain a copy of or access to safeguards under which your personal information is transferred outside of the UK or EEA (as applicable).

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us and we may be required to no longer process your personal information. Moreover, if your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.

When you request us to provide the personal information we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, however, we invite you to contact us first. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

Cross-border data transfer

Your personal information may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the UK or EEA (as applicable), you should be aware that your personal information may be shared with, and transferred to, Aditum affiliates and third-party service providers who are located outside the UK or EEA (as applicable). We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

we will ensure that transfers within Aditum and its affiliates will be covered by an agreement entered into by members of Aditum (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Aditum group;

where we transfer your personal information outside Aditum or to third parties who help provide our Services, we will obtain contractual commitments from them to protect your personal information; and
where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal information is disclosed.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

How long do we keep your personal information

We apply a general rule of keeping personal information only for so long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.