A. Information We Collect
We may collect a variety of information from or about you or your devices that you voluntarily submit to us and from various other sources, as part of conducting our research activities or providing our products or services.
The types of personal information we collect and share depend on the nature of the relationship you have with Arcellx and the requirements of applicable laws. We collect and use personal information of:
- Our research participants and potential subjects when conducting research or informing them of opportunities to participate in research;
- Our service providers and suppliers as we arrange and pay for products and services;
- Job applicants and visitors to our websites and locations; and
- Our affiliates and partner organizations who assist in conducting research or delivering our products or services
The types of personal information we collect may include:
- Identity and Contact Data: including names, titles, mailing address, phone numbers, email address or online usernames, government-issued identification numbers, and images;
- Financial and Commercial Data: including salary and income information, financial account or policy names or account numbers;
- Professional and Employment-Related Information: including non-public education information, academic records, employment history, disciplinary records;
- Sensitive Personal Information (also “special categories” or “protected classification”): including health information including medical records, health insurance information, biometrics, disability, geolocation, race and sensory (audio/visual) data;
- Internet Activity, Technical Data and Usage Information: including IP address, login credentials, device fingerprints, behavioral inferences;
- Marketing and Communications Data: including professional contact details, business sector and interest demographics and marketing-willing status indicators
We will specify which of these types of data we use at the point we begin to collect this information from you. For instance, if you are a research subject and have signed an Informed Consent Form, this is a Privacy Notice as part of your study enrollment.
B. How We Collect Information
Direct interactions. You may give us your Identity and Contact Data, Financial and Commercial Data, and Special Categories/or Sensitive Personal Information by filling in forms, as part of the employment application process, requesting or obtaining information, or by corresponding with us through any means.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
- Affiliates and service providers may collect and provide us your Identity and Contact, Internet Activity, Technical Data, and Usage Information Financial and Commercial Data, and Marketing and Communications Data.
- When you use our Site or other access portals, we may collect personal information such as Identity and Contact Data, Internet Activity, Technical Data and Usage Information, Commercial Data, and Marketing and Communications Data.
- When we conduct research activities, we process personal information which may include Sensitive Personal Information.
Cookies and Use of Automated Data Collection and Tracking Technologies
We use automated data collection methods consistent with the provisions of this policy. We and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include details about the Device you are using, how you came to our Site and how you navigate around our Site.
Information from Cookies and Tracking Technologies. We and our third-party partners collect personal information using cookies, pixel tags, web beacons or similar technologies (collectively, “Tracking Technologies”). Our third-party partners, such as analytics and advertising partners, may use these Tracking Technologies to collect information about your online activities over time and across different services for a variety of purposes including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site, keeping track of your specified preferences; and
- To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our advertisements and/or content
We also obtain analytics services from Google LLC (“Google”) through use of their Google Analytics. In order for Google to provide this service to us, they place a cookie or cookies on your Device which allows Google to track certain information about you, your technology or activities online, such as your geographic location, the IP address from which you connected to the Internet, information about your Device, your browser and your Internet provider. We do not control such data collection or how Google uses the data they collect.
How and Why We Use the Personal Information We Collect
To the extent permitted by applicable law, we may use personal information to further our legitimate business interests or to comply with a legal obligation, including completing an employment or services contract with you. The basis on which we use personal information depends on our relationship with the individual and the nature of the information we are using. Purposes for which we may use personal information include the following:
- To provide, maintain, improve, and enhance our Website;
- To communicate with you, provide you with updates and other information relating to our Website or research activities, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you;
- Staffing, facilitating, conducting and managing our research activities or providing our products or services;
- Operating, securing, and improving our business (including both physical premises digital environments);
- Evaluating and engaging with our service providers and business partners;
- To find and prevent fraud, and respond to trust and safety issues that may arise; and
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency
We will specify the purposes and basis for which we process personal information at the time the personal information is collected, or we begin using the personal information.
Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes that are not necessary in order to conduct our research or other legitimate business activities as are reasonably expected by an average person participating in those activities.
How We Share the Information We Collect
We need to disclose your personal information to various parties in the course of our business including:
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your personal information may occur if you post any objectionable content on or through our Website.
Merger, Sale, or Other Asset Transfers. We may transfer or disclose your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.
A list of such parties is available upon reasonable request using the details in the Contact Us section of this policy.
Consent. We may also disclose your personal information with your permission.
In the process of setting cookies and Tracking Technologies, to provide Arcellx with certain analytics services on our Site, some service providers (e.g. Google) may retain such analytics data for their proprietary purposes including for cross context behavioral advertising. Since the retention of analytics data may impact the price of the analytics services to Arcellx, it may be deemed a Sale of Personal Information. You have the right to opt out of this type of sale or sharing of your personal information to third parties and we have provided opportunities on the Site for you to exercise this right including a link on our homepage and a further link in the Contact Us section of this policy as well as by contacting us using details in the Contact Us section.
How We Respond to Do Not Track Signals
Do Not Track (“DNT”) or “Global Privacy Control,” is a preference setting offered by various internet browsers whereby a signal is automatically sent by the browser to each website visited requesting that the user’s activities are not tracked by that website and that the website does not enable onward tracking to other websites. You can usually access your browser’s DNT option in your browser’s preferences. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or usernames, and some other features of a website may become unavailable or not function properly. We have configured our Site with the intent that it honors DNT signals from most browsers. When a user’s browser is set to DNT, we will disable cookies related to marketing and targeting.
We maintain reasonable technical, administrative, and organizational measures to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification of personal information collected through our Site. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.
International Transfers of Personal Information
When we no longer need personal information, or in any event, after legal authority to retain it has expired, we will destroy personal information in accordance with local law and pursuant to our relevant procedures.
Rights to Access and Control Your Personal Information
You are provided certain rights over your personal information that enable you to access and control the use of any personal information about you that we collect and use.
We reserve the right to verify the identity of the individual and to verify the authority of any designated representative (“authorized agent”), in connection with any requests regarding personal information, to help ensure that we provide the information to individuals to whom the information pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
Your rights to access and control your personal information include the following:
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to continue to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that it is complete and accurate and that we are lawfully collecting, using and disclosing (together “processing”) it. This access request will include a list of the types of personal data we have collected and to which third parties we have Sold or Shared your personal data over at least the last 12 months.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. In certain cases we may not be able to comply fully or at all with your correction request, and if so, we will notify you of the reasons for this.
- Object to processing (also known as the right to opt-out) of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing. In certain cases we may not be able to comply fully or at all with your request on reasonable grounds provided the processing does not negatively impact your privacy rights, and if so, we will notify you of the reasons for this.
- You also have the right to object where we use your personal information for direct marketing purposes. This includes your right to request that your Personal Information not be Sold to or Shared with third parties for their own proprietary purposes including for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on that consumer’s personal information from a number of sources. If you wish to modify your preferences in respect to updates or notifications, or the mailing lists you subscribe to, you can modify your preferences on our Site. All commercial and marketing communications (e.g. notification emails and newsletters) include instructions for opting-out of those communications in the future.
- Request erasure of your personal information. You can request we delete personal information where you do not believe there is reason for us continuing to process it, or where you believe we collected or are using it unlawfully, where erasure is required by law or where you have opted-out of our processing. In certain cases we may not be able to comply fully or at all with your erasure request for legal reasons, and to the extent we are permitted to, we will notify you of the reasons for this.
- Request restriction of processing of your personal information. You can request we suspend or limit processing of your personal information only to that which is legally necessary or is strictly necessary to continue orderly business operations. Restricted processing may occur where we are verifying whether we are able to comply with your correction, opt-out or erasure request or where you believe it is in your interests not to erase the personal information.
- Request the transfer (also known as the right of portability) of your personal information to you or to a third party you have chosen. To the extent it is technically feasible we can provide your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided to us to use or where we used the information to perform a contract with you.
Exercising your data access rights
To exercise any of the rights described herein, please contact us using the details provided in the Contact Us section. We will acknowledge your request within 5 days and will complete our response to your request within 30 days unless we agree to a different response period with you or a different response period is permitted or required under applicable law.
If you would like an authorized agent to exercise these rights on your behalf, you (or the authorized agent) must provide a written request including your full name and all contact details (e.g. email address, mailing address) that we have in our records and with which we can authenticate you, as well as (if applicable) the relationship or services obtained from Arcellx. The written request must include the full name and preferred contact details of the authorized agent. We may deny a request from an agent who cannot meet these requirements.
When submitting a request, please describe your relationship with us and your request in sufficient detail to allow us to properly understand, evaluate, and respond to it. We may need to verify your identity before processing your request, which may require us to request additional personal information from you.
We will never discriminate or retaliate against you for exercising any of these rights. However, please note that if the exercise of your rights limits our ability to process personal information, we may not be able to provide our products to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
If you believe that we have not respected your rights outlined herein or we have breached a relevant law and wish to make a complaint, please contact us using the details below detailing the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
If you believe we have not dealt with your complaint adequately, you also have the right to contact a regulatory body or data protection authority in relation to your complaint.
If you have any questions, comments, or concerns about our processing activities, or would like to exercise your data access rights please contact us:
Email us at [email protected] or write to us at
Arcellx, Inc. Privacy Officer
25 W. Watkins Mill Road
Gaithersburg, MD 20878
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