Privacy Policy

Adela, Inc. (“Adela”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.  This privacy policy outlines how Adela collects, uses and discloses your personal information gathered about you, in conformance its applicable privacy law obligations.

This policy applies to personal information we collect:

• when you use our website, located at https://www.adelabio.com/  (“website”);
• when you submit your personal information to us through our website. For example, when you fill the “Contact us” section of our website;
• when you make requests for information about our products, services and programs;
• as part of our recruitment process; and
• as part of your interaction with us by telephone, email, through social media and in person.

This policy does not apply to personal information, including personal health information, that your health care professional may collect and share with us when you use our products or participate in a clinical trial or research program. You will be presented with a separate privacy consent notice in those instances that will outline how we handle your personal information in those specific circumstances.

Please read this policy carefully to understand our privacy 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 website. By accessing or using this website, you agree to this privacy policy.

What is personal information?

Personal information is any information by which you may be personally identified or is about you. For instance, it includes information such as your name, address, telephone number, birth date, and e-mail address.

This policy is also not intended to cover information other than personal information, such as business or anonymous information. We do not collect any medical or personal health information through our website or when you interact with us, e.g., via social media.

Obtaining and withdrawing your consent

Adela will appropriately obtain personal information in accordance with the relevant laws and regulation. Adela will obtain your consent (through this privacy policy or other means) to collect, use and/or disclose personal information except where we are authorized or required by law to do so without consent.

You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your personal information at any time by writing to us (see the ‘Contact information’ section below and, subject to any legal constraints, we will comply with your request.)

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Information we collect and where we get your personal information

We do not collect personal information indiscriminately and will limit collection of information to that which is reasonable and necessary for the purposes it was collected or as authorized by law.

We will inform you of the purposes for which we collect, use and share personal information before or at the time the information is collected, including through this privacy policy. In addition to the purposes identified below, we may inform you of other purposes from time to time, either in writing or orally.

Often it is optional for you to provide your personal information, but other times some personal information is required to serve you. You may choose not to provide your personal information even in such cases, but that may result in our inability to serve you.

In all cases where you voluntarily provide personal information to us, we undertake to collect, use and/or disclose it in accordance with this policy and applicable laws.

We collect personal information in the following ways:

• Directly from you. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail, through the website or otherwise. Other interactions where we may collect your information include:

• When you attend an Adela facility or event;
• When you apply for a position with us;
• If you contact us, such as with a complaint or query; and
• When you engage with us over social media.

• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see ‘Cookies and other Technology section below for more details).
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, our business partners, collaborators or service providers.

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How do we use your personal information?

We use information that we collect about you or that you provide to us to:

• communicate with you, including to authenticate your identity and ensure that your information is correct and accurate;
• fulfill the purposes for which you provided the data or that were described when it was collected;
• facilitate requests they you have made, including for electronic content (e.g., newsletters);
• understand your needs, the suitability of our products and services, and assess future needs;
• administer surveys, or request feedback to improve and manage our relationship with you;
• address your inquiries and complaints;
• present, operate, maintain, enhance, and provide all of the features of our website;
• to market, advertise and promote our products, services and events to you and to other prospective customers;
• keep you informed about our programs and services, including notifying you about  updates to our website, products, or services;
• understand and analyze the usage trends, behaviors, and preferences of our users and prospective users, to improve the way the website works and looks, and to develop new features and functionality;
• research, analyze, develop, manage, protect and improve our programs and services, including our website;
• manage our organization and day-to-day organizational and operational needs;
• protect our website, employees or operations;
• establish and maintain communication with service providers;
• comply with our legal and regulatory obligations; and
• fulfill other purposes related to any of the above.

Recruitment applications

If you submit a job application to us, we will use the information relating to that application (such as your employment history) to assess your suitability to any of our job postings. We may also collect information from third parties about you, such as references you list, for the same purpose.

De-identified, aggregate or anonymized information

We may also de-identify, aggregate or anonymize information to identify trends, manage our organizational and operational needs; develop statistical information, understand how we are performing, develop relevant products, services or offers. Such information may also be shared with third parties for other analytical purposes but will not personally identify any individual and therefore is not subject to this privacy policy.

How and when we may share your information?

We do not sell or lease your personal information to third parties.

We may share your information with our affiliates, collaborators, business partners and service providers to assist us in providing you services, perform functions on our behalf or for our internal business purposes. We contractually require these third parties to keep that personal information confidential and use it only for the contracted purposes.

We may also disclose your personal information to third parties:

In the event that we sell or buy any business or assets or to pursue a partnership or investment opportunity, in which case we may disclose your personal information to the prospective seller, buyer, investor or partner of such business, assets or partnership;

To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal information we hold;

To comply with any court order, law, or legal process, including responding to any government or regulatory request;

To enforce or apply our website terms of use and other agreements; and

To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

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Cookies and other technology

Information that is automatically collected

We, and our third-party service providers, may automatically collect information related to your use of our website, apps and other online resources through cookies and similar tracking technologies. We do not collect personal information that can identify you directly, such as by name, when browsing our website.

How we use information gathered from cookies and other technologies

We use cookies and similar technologies to:

• Make your website experience personalized and efficient
• Understand and improve our digital services and offerings

Cookies

Cookies are small text files that are stored on the browser of your computer that assign an anonymous identifier to your browser and provide information to the cookie sender. Cookies may be placed on your computer by us when you our website or other digital offerings. In addition, we may use third party cookies that track how you use our website or other online resources in order to target advertisements to you on other websites.

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. Please note that if you disable or delete cookies, the website may not function fully or as intended. For more information on cookies and how to manage them, check the support pages for your browser, such as Firefox, Safari, Chrome or Internet Explorer.

Google Analytics

We use Google Analytics (including Google Analytics for Firebase) to better understand your use of our website. Google Analytics collects information on user behavior on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Google uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Google services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network.

Google will not associate your IP address with any other data held by Google. To learn more about Google Analytics, click here. You can deactivate the Google Analytics function with a browser add-on, which you can download here. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.

International storage and transfers of information

We are based in the United States and Canada. We may process, store, and transfer the personal information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Additionally, some of our service providers, collaborators and business partners may be based in different countries. This means your information may be accessible to law enforcement authorities outside of your jurisdiction, in accordance with the laws of that jurisdiction. By using our programs or our website, you consent to the collection, storage, and processing of your information in Canada, United States and in any country to which we may transfer your information in the course of our operations.

Data security

The security of your personal information is very important to us. We protect your information by limiting access to it on a strict “need-to-know” basis, and we implement reasonable physical, organizational and technological safeguards as appropriate.

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

Data retention

We only keep your personal information as long as it is operationally or legally necessary. After that, we will either securely and permanently destroy or make the information anonymous.

Hyperlinks

Our website may contain hyperlinks allowing users to visit other sites operated by other organizations. We are not responsible for the privacy practices or content of any of such websites to which we link. If you access such third-party websites, either directly or via the website, you should review the privacy policy of each site.

Accessing your information

When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain.

To access your personal information, submit a written a request that identifies yourself, the information you want to review and how we can contact you (see ‘Contact information’ below for how to contact us). We may not be able to provide you with all the information you request, depending on the circumstances.

Correcting your information

We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make any appropriate updates needed. You can review your personal information by reviewing the correspondence we send to you or by requesting access to your personal information, as described above. 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

California residents may have additional personal information rights and choices. Please see ‘Additional information for California and Nevada residents’  for more information.

Children's online privacy

We do not direct our website to minors and we do not knowingly collect personal information from children under 16 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal information from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us using the information outlined in the ‘Contact information’ section below.

Do-Not-Track mechanisms

Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honour Do-Not-Track requests sent by your browser.

Additional information for California residents

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.

• Right to know: You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
• Right to make a deletion request: You can ask us to delete your personal information.
• Right to opt-out of sales of your personal information: You can ask that we stop selling your personal information.
• Right to non-discrimination: You have the right to not be discriminated against by us for choosing to exercise your rights under the California Consumer Privacy Act.

In order to exercise these rights, contact us using the ‘Contact information’ outlined below.

Additional information for Nevada residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@adelabio.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Inquiries and complaints

Inquiries or complaints regarding this privacy policy or related to Adela’s practices for data protection and information management may be made using the ‘Contact information’ outlined below.

Contact information

If you have any questions or concerns about this privacy policy or about Adela’s handling of your personal information, please contact us in writing at:

Address: 353 Hatch Drive, Foster City, CA 94404

Email: info@adelabio.com

Please note that we may need to confirm your identity or request additional details in order to process your request.

Changes to this privacy policy

We may modify this policy from time to time and will post the most current version online.

Last updated: May 8, 2024.