Privacy Policy

Last Updated January 16, 2024

Alector LLC, a wholly owned subsidiary of Alector, Inc. (collectively “Alector,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully. The purpose of this Privacy Policy is to set out the principles governing our use of information relating to identified or identifiable individuals (“Personal Information”). This Privacy Policy applies to information we collect:

On our website (the “Site”);
When you interact with us directly; or
When we receive your information from a third-party source.

Please read this Privacy Policy carefully to understand how we collect your Personal Information. Be aware we may update this Privacy Policy from time to time. Your continued use of this Site or your continued provision of personal information after we make changes to this Privacy Policy is deemed to be your acceptance of those changes, so please check this Privacy Policy periodically for updates. If a revision is material, we will make commercially reasonable efforts to notify you of that revision by email if possible or by posting a notice on this Site. BY USING THE SERVICES AND THIS SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE IMMEDIATELY CEASE ALL USE OF THE SERVICES AND THIS SITE, AND OTHERWISE REFRAIN FROM PROVIDING US YOUR PERSONAL INFORMATION.

For your convenience, this Site may contain links to third-party websites. The privacy policies and procedures described herein do not apply to such third-party sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third-party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

Personal Information We Collect

We may collect, use, store and transfer the following Personal Information to provide the Services and improve our Site. The table below outlines the categories of personal information we may have collected in the preceding 12 months, along with specific examples of such personal information, the purpose(s) of the collection, and the source of the collection.

Personal Information We Collect	Collection Purpose	Collection Source
Identifiers: First and last name; telephone number; email address; physical address; unique personal identifier, online identifier, photos or images of you; account name	To provide our business and clinical services To manage our relationship with you To comply with our legal and regulatory obligations	You Your Device(s)
Personal information listed in Cal. Civ. Code § 1798.80(e): Name, address, telephone number	To provide our business and clinical services To manage our relationship with you To comply with our legal and regulatory obligations	You
Sensory Information: Audio information, such as call monitoring or customer service recordings	To provide and improve our business and clinical services To manage our relationship with you, including to communicate with you To comply with our legal and regulatory obligations	You Our Service Providers
Internet or Other Similar Network Activity: Browsing history; search history; information on your interaction with our Site, application, or advertisement; device information (e.g., browser type and version, time zone setting, operating system, IP address)	To provide and improve our business and clinical services To provide and improve our Site To comply with our legal and regulatory obligations	You Your Device(s) Our Service Providers
Geolocation data: Approximate device location via IP address	To provide and improve our business and clinical services To provide and improve our Site To comply with our legal and regulatory obligations	Your Device(s)
Preferences: Communication preferences, marketing preferences	To provide and improve our business and clinical services To provide and improve our Site To manage our relationship with you	You Our Service Providers

Please note that we do not ask for any sensitive Personal Information such as race or ethnicity, political opinions, religious beliefs, union membership, physical or mental condition, sexual orientation, or criminal offense. We request that you omit any such sensitive Personal Information in any communications with us. If you send us any such sensitive Personal Information, we will delete it unless you provide your specific consent to having us include it in your account, as it will be processed with the rest of your Personal Information.

How We Collect Your Personal Information

We collect your Personal Information:

Directly from you when you provide it to us. For example, we collect your Personal Information when interact directly with us via phone, email, mail, or in person.
Automatically as you navigate through our Site. For example, we may automatically collect your device information and usage details (e.g., IP address, browser type, the website from where you navigated to the Site, the pages on our Site that you viewed, time and date of access to the Site, device identifiers, approximate location details,) as well as information collected through cookies, web beacons, and other tracking technologies.
From third parties that support our operations. For example, we obtain your Personal Information from our advertisers, service providers, and other business partners to better understand your use of our Site and how we can improve it. We may also collect your Personal Information from third parties to facilitate the performance of a contract with your or one of our business partners.

How We Use Your Personal Information

We use your Personal Information where we have a legal basis for doing so. Such legal bases may include:

Execution of a contract. We need your Personal Information to operate our Site, provide our Services to you, respond to your enquiries, or otherwise perform a contract we have entered or are about to enter with you or one of our business partners.

Compliance with a legal obligation. We are required or allowed to collect and use your Personal Information in order to comply with applicable laws, regulations, or orders from a court or other government agency.

Legitimate Interest. We or a third party may have a legitimate interest in processing your Personal Information. For example, we may have a legitimate interest in collecting and using your Personal Information to conduct business analytics or improve our Site or Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights.

Consent. You have consented to the collection and use of your Personal Information.

We use your Personal Information in the following circumstances:

To perform a contract we are about to enter into or have entered into with you or one of our business partners.
To provide, evaluate, improve, protect, and promote our Site and the Services.
To provide, evaluate, improve, protect, and promote our business and clinical services.
To manage our relationship with you, including to notify you of changes to our Privacy Policy and ask you to leave a review or take a survey.
In connection with a transfer in the event of a corporate sale or change of control.
Where it is necessary to comply with a legal or regulatory obligation including in response to law enforcement or legal requests or requirements. Such circumstances may include:
- Performance under the terms of a legally enforceable contract;
- To meet any applicable law, regulation, subpoena, legal process or enforceable governmental request;
- To enforce applicable Terms and Conditions, including investigation of potential violations;
- To detect, prevent, or otherwise address fraud, security or technical issues; and
- To protect against harm to the rights, property or safety of Alector, our affiliates and partners, or the public as required or permitted by law.
- To audit our compliance with applicable laws.
Where you have provided your consent.

How Long We Retain Your Personal Information

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, unless otherwise legally required. To determine the appropriate retention period for Personal Information, we consider factors such as the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process the Personal Information; whether we can achieve those purposes through other means; and the applicable legal requirements.

How We Share Your Personal Information

For any disclosure of your Personal Information to any third party (e.g., partners, back-office support), we ensure there is a legal basis for making the disclosure, which may include your consent.

We do not sell Personal Information to advertisers or third parties in exchange for financial compensation. That said, we may share your Personal Information for a business purpose with the below categories of third parties:

Third-Party Service Providers. Alector uses trusted third parties (e.g., IT services, analytics services) to help us provide, improve, protect, and promote our Site and our Services. These third parties will access your Personal Information only to perform tasks on our behalf.

Other applications and third-party links. The Site may include links to third-party websites, plug ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Site, we encourage you to read the privacy policies of every website you visit. Please remember that the use of your Personal Information by such websites will be governed by the terms of their own privacy policies.

How We Protect Your Personal Information

We maintain administrative, technical, and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Toward this end, we implement measures such as data minimization, password-protection, encryption, pseudonymization, and anonymization of your Personal Information where practicable. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your Personal Information.

Our Use of Cookies

Our Site may use cookies and other tracking technologies to identify individuals who have previously visited our Site. These cookies help us understand and save your preferences for future visits to our Site. A cookie may be placed by us or by our services providers. If you have provided us with Personal Information, we may associate such Personal Information with information gathered from cookies or other tracking technologies. This allows us to offer increased personalization and functionality when you visit our Site.

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of our Site, including your IP address. More information on Google Analytics can be found at: www.google.com/policies/privacy/partners/. If you would like to opt-out of having your data used by Google Analytics, please use the Google Analytics opt-out available: https://tools.google.com/dlpage/gaoptout/. Alector makes no representations regarding the functionality of Google opt-out mechanisms, and further, opting out of Google Analytics will not preclude the use of your data by other analytics services.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent. You can also choose to turn off all cookies via your browser settings. As with all websites, if you turn cookies off, some of our Services may not function properly.

How to Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us.

Alector, Inc.

131 Oyster Point Blvd, Suite 600

South San Francisco, CA 94080

Tel: (415) 231-5660

Email: dataprivacy@alector.com

ADDITIONAL INFORMATION FOR SELECT STATES AND REGIONS

Individuals in California

If you are a California resident with disabilities and need to be provided with an accessible version of this section or the policy as a whole, please Contact Us at (415) 231-5660 ordataprivacy@alector.com.

Application

Under the California Consumer Privacy Act and California Privacy Rights Act, California residents have certain privacy rights with respect to their Personal Information, which we may collect and process. For purposes of this section, Personal Information does not include:

Publicly available information from government records,
De-identified or aggregated information, or
Other information excluded by law.

Your Rights

California residents have the following rights with respect to their Personal Information:

Right to Know and Access: You have the right to request that Alector disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.

Right to Portability: You have the right to obtain a copy of your Personal Information in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization in certain circumstances.

Right to Delete: You have the right to request that Alector delete personal information that we collect from you, subject to certain exceptions.

Right to Correction: You have the right to request that we modify or correct errors in the Personal Information that we collect from you. However, please note that we may not accommodate a request to change personal information if we believe that doing so would violate any law, legal requirement or rights of another person, or cause the information to be incorrect.

Right to Opt-Out of Sale or Sharing: Alector does not sell or share, and has not in the past 12 months sold or shared, your Personal Information for cross-contextual behavioral advertising.

Right to Limit Use of Sensitive Personal Information: Alector does not use, and has not in the past 12 months used, sensitive Personal Information for purposes other than critical business purposes as permitted under CCPA 1789.121(a) (e.g., providing the service, data security, providing non-personalized advertising, maintaining and servicing accounts).

Right to Non-Discrimination: You have the right to be free of discriminatory treatment by us for exercising your rights listed above.

Exercising Your Rights

To exercise your rights, please email us at dataprivacy@alector.com with the subject line “Privacy Request” or otherwise contact us as outlined above in the How to Contact Us section. Only you or an authorized agent (e.g., a person registered with the California Secretary of State to act on your behalf) (your “Authorized Agent”) may make a request related to your Personal Information.

Once we receive your request, we will verify your identity or the identity of your Authorized Agent using information you provide to us in the request and matching it with information we have about you. With few exceptions, we will only review and fulfill a request from your Authorized Agent if (a) you grant the Authorized Agent written permission to make a request on your behalf, (b) you or the Authorized Agent provides us notice of that written permission, and (c) we are able to verify your and the Authorized Agent’s identity in connection with that notice and the request.

Please note that we cannot process to your request or provide you with Personal Information if we cannot verify your identity, the identity of your Authorized Agent, or the authority of the Authorized Agent to make the request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Appeals

You may have the right to appeal a decision with regard to your privacy request. For example, you may appeal our decision to decline to take an action on a request. To exercise your right to an appeal, please Contact Us at (415) 231-5660 or dataprivacy@alector.com.

“Shine the Light” Disclosures

California law permits customers that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes during the prior calendar year. To make such a request, please Contact Us at (415) 231-5660 or dataprivacy@alector.com.

Individuals in the European Union

If you are an individual in the European Union/UK, you have certain rights with respect to the access, correction, restriction, and erasure of your Personal Information, sometimes known as Personal Data, stored by us at any time. You can ask about exercising any of these rights at any time by contacting us at dataprivacy@alector.com. Depending upon the circumstances and with certain exceptions, your rights may include the following:

Accessing your Personal Information. You have the right to obtain information relating to your Personal Information and our processing of your Personal Information in a concise, transparent, intelligible, and easily accessible form using clear and plain language.
Correcting your Personal Information. You have the right to ask us to rectify any inaccurate or incomplete Personal Information stored by us.
Erasing your Personal Information. Under certain circumstances, you have the right to ask us to erase your Personal Information stored by us. If we receive a legally actionable request to erase your Personal Information, we will ask you if you want your Personal Information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose Personal Information we have erased so you may be contacted again by us, should we come into possession of your Personal Information at a later date.

If we have given your Personal Information to any third parties, we will tell those third parties that Alector has received a request to rectify or erase your Personal Information, unless this proves impossible or involves a disproportionate effort.

Restricting the use of your Personal Information. You have the right to ask us to suspend or otherwise restrict the processing of your Personal Information where we are relying on our “legitimate interests” to process it and:
- You challenge the accuracy of the Personal Information;
- The processing is unlawful but you do not want us to erase it;
- We no longer need the Personal Information for the purposes of the processing but you want us to hold it as you need it to establish, exercise, or defend legal claims; or
- You have objected to our use of your Personal Information but we need to verify whether we have legitimate grounds to use it.

If we have given the Personal Information to any third parties, we will tell those third parties that we have received a request to restrict the use of your Personal Information, unless this proves impossible or involves a disproportionate effort.

Withdrawing your consent. Where we are relying on consent to process your Personal Information (for example consent to receive marketing) you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. You recognize that if you withdraw your consent, we may not be able to provide certain products or services to you.

Finally, you have the right to lodge a complaint about our handling of your Personal Information with the supervisory authority in your EU/UK country of residence. However, before doing so we request that you contact us at (415) 231-5660 or dataprivacy@alector.com to see if we can resolve your complaint to your satisfaction.