Privacy Policy

Last Updated 1/8/2020

 

Alector LLC, a wholly owned subsidiary of Alector, Inc. (“Alector”) is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully in line with all relevant privacy legislation. The purpose of this Privacy Policy is to set out the principles governing our use of information relating to an identified or identifiable individual (“Personal Information”). Alector processes Personal Information when we provide services, sell products, manage our business and other relationships or when you use this website (“Site”) or mobile applications or when you request our newsletters, updates, and press releases or when you otherwise interact with us electronically or in person (collectively, “Services”). By using the Services, you agree to our use of the Personal Information that we obtain about you.

Please read this Privacy Policy carefully. We may change our Privacy Policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you use the Services, including access this Site. If a revision meaningfully reduces your rights, we will notify you by a notice posted on our website, by email, or by other method. BY USING THE SERVICES AND THIS SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SERVICES OR THIS SITE.

For your convenience, this Site may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those 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.

 

Your Data

We may collect, use, store and transfer the following Personal Information to provide the Services and improve our Site.

The data we collect and process. You may give us Personal Information by visiting or interacting with the Site, filling in forms on the Site, interacting with us as part of our Services, or by corresponding with us by phone, email, in person, or otherwise. This Personal Information includes the following data:

  • personal information you provide when you interact with the Site or as part of the Services. The personal information you give us may include your name, title, company, mailing address, email address, phone number, password, resume information, feedback and any other information you choose to provide to us;
  • technical data such as your internet protocol (IP) address, your login data, the web page you visited before visiting our Site, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site;
  • usage data which tells us how you use our Site;
  • marketing and communication data which tells us your preference in receiving marketing from us and our third parties and your communication preferences; and
  • sensitive personal data such as your race or ethnicity, your political opinions, religious beliefs, membership in a trade union, physical or mental health condition, sexual orientation, or criminal offenses.

Please note that we do not ask for any sensitive personal information and request that you omit any such information in any communications with us. If you send us sensitive personal information, we will delete it unless you provide your specific consent to having us include it your account, as it will be processed with the rest of your personal information.

 

Purposes for which we will use your data

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

The ways we plan to use your Personal Information are as follows

  • Site. We collect feedback in order to improve our Site and our Services.
  • Usage. We also use your data, especially usage data and technical data (such as Site visits, page interaction information, and search history), to evaluate and improve our Site and our Services.
  • Cookies and other technologies. We use technologies like cookies to provide, improve, protect, and promote our Site and our Services. Alector currently does not respond to Do Not Track requests.
  • Marketing. We also use your data to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, select the ‘unsubscribe’ link in any email communication from us.
  • Relationship. We will also use your data to manage our relationship with you which will include notifying you about changes our Privacy Policy and asking you to leave a review or take a survey.

 

Sharing your data

We may share Personal Information as discussed below, but we won’t sell it to advertisers or third parties.

Others working for Alector. Alector uses trusted third parties (i.e. IT services, analytics services, etc.) 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 in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your Personal Information per our instructions.

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 their use of your personal information will be governed by their privacy policies and terms.

 

Protecting your data

We review the Personal Information we hold on a regular basis to ensure it is being lawfully processed. We only process Personal Information where we have a legal basis for doing so. Such legal bases may include:

  • Execution of a contract. We need your Personal Informnation to operate our Site, provide our Services to you, respond to your inqueries, or otherwise perform the contract we have entered or are about to enter with you.
  • Compliance with a legal obligation. We are required or allowed to collect and use your Personal Information in order to comply with applicable local laws
  • Legitimate Interest. We or a third party 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.
  • You have consented to the collection and use of your Personal Information.

Before transferring Personal Information to any third party (e.g. partners and back office support), we establish that there is a legal reason for making the transfer, which may include your consent.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We have implemented measures and procedures that adequately protect the privacy of individuals and ensure that data protection is integral to all processing activities. This includes implementing measures which may include:

  • Data minimization (e.g. not keeping data for longer than is necessary);
  • Pseudonymization;
  • Anonymization;
  • Cybersecurity; and
  • A data security policy.

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. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your Personal Information.

 

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.

 

Your rights – individuals in the European Union

If you are an individual in the European Union, you have certain rights with respect to the access, correction, restriction, and erasure of your Personal Information stored by us at any time. You can exercise any of these rights at any time by contacting us at legal@alector.com. Your rights include the following:

  • Accessing your Personal Information. Upon request, we shall provide any 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. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.
  • Correcting your Personal Information. You have the right to ask us to rectify any inaccurate or incomplete Personal Information stored by us. If we have given your Personal Information to any third parties, we will notify those third parties that Alector has received a request to rectify your Personal Information, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however, we are not in a position to audit those third parties to ensure that the rectification has occurred.
  • Erasing your Personal Information. You can ask us to erase your Personal Information stored by us. If we receive a 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 erase your Personal Information, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold – however, Alector will not be in a position to audit those third parties to ensure that the rectification has occurred.

Restricting the use of your Personal Information. We only process your Personal Information where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your Personal Information where:

  • 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. Those third parties should also rectify the personal data they hold – however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.

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. 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 provide certain products or services to you.

 

Your rights – individuals outside the European Union

Accessing Account Information. We will provide you with the means to ensure that Personal Information stored by us is correct and current. You may review this information by contacting us by sending an email to legal@alector.com.

A Record of Data Transfer. Alector will provide the right to request and receive, once a year and free of charge, information about third parties to whom we have disclosed certain types of Personal Information (if any) about you for our direct marketing purposes in the prior calendar year, and a description of the categories of Personal Information shared. To make such a request, please send an email to legal@alector.com and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of Personal Information to third parties for their direct marketing purposes.

 

Information for California residents

California Online Privacy Protection Act

As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Site about individuals who visit our Site or use our Services and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

If you are a California resident, California law permits you to request information regarding:

  • Categories of Personal Information (as defined by applicable California law) collected, sold or disclosed by Alector;
  • Purposes for which categories of Personal Information collected by Alector are used;
  • Sources of information from which we collect Personal Information; and
  • Specific pieces of Personal Information we have collected about you.

In addition, if you are a California resident you may:

  • Opt-out of the sale or disclosure of your Personal Information, in some circumstances;
  • Opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the Services;
  • Opt-in to certain financial incentive programs we may offer related to the collection, sale, or deletion of your Personal Information; and
  • Request deletion of your Personal Information by us and our service providers, in some circumstances.

You will not be discriminated against for exercising your rights under the California Consumer Privacy Act.

 

Collection of Personal Information from California Residents

We have listed below the Personal Information we may have collected from California residents in the past 12 months.

Category of Personal Information we may collect: Identifiers

 

Categories of sources from which we may obtain your “Identifiers” include:

 

Directly from consumers

The purposes for collecting your “Identifiers” include:

 

To send you our newsletter, updates, press releases, etc.

 

Category of Personal Information we may collect: Biometric Information

 

Categories of sources from which we may obtain your “Biometric Information” include:

 

Directly from consumers

The purposes for collecting your “Biometric Information” include:

 

As part of our clinical trials administered by a contract research organization

 

Category of Personal Information we may collect: Internet/Electronic Activity

 

Categories of sources from which we may obtain your “Internet/Electronic Activity” include:

 

Directly from consumers

The purposes for collecting your “Internet/Electronic Activity” include:

 

To improve our Site

 

Category of Personal Information we may collect: Professional Information

 

Categories of sources from which we may obtain your “Professional Information” include:

 

Directly from consumers

The purposes for collecting your “Professional Information” include:

 

To send you our newsletter, updates, press releases, etc.

 

Here is information on whether we sell or share your Personal Information.

 

Selling/sharing your Personal Information

 

Categories of third parties we may sell your Personal Information to

 

Internet service providers, data analytics providers, operating systems and platforms

 

Categories of third parties we may otherwise share your Personal Information with

 

Internet service providers, data analytics providers, operating systems and platforms

 

 

Requests

You can make requests related to your California privacy rights at the attached links:

  • Access My Personal Information: (alector.com);
  • Delete My Personal Information: (alector.com);
  • Do Not Sell My Personal Information: (alector.com).

You may also make those requests by calling 650-409-3248.

Please be aware that we do not accept or process requests through other means (e.g., via fax, social media, email addresses, etc.).

When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.

 

Children

Our Services are not directed to children, and we do not knowingly collect Personal Information from children under the age of 16. If you learn that a child has provided us with Personal Information, then you may contact us as indicated above.

 

Do Not Track

Alector does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

 

Where we store and transfer your data

The Site is controlled by Alector from its offices in the United States. Alector may store and use information in the United States and other jurisdictions; Any Personal Information provided to Alector will be transmitted to or within those jurisdictions.  Alector also may transfer Personal Information to other jurisdictions to facilitate Alector’s third party processors’ access to and/or processing of Personal Information.

Individuals in the EU. Whenever we transfer your Personal Information outside the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it as in the EEA by using either specific contractual clauses approved by the European Commission or data processing agreements which give Personal Information the same protection it has in Europe.

Alector makes no representation that materials on this Site are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited.  Those who choose to access this Site from other locations do so on their own initiative and are responsible for compliance with applicable local laws.

 

Contact

Have questions or concerns about our Site, Services, or Privacy Policy? Contact us at legal@alector.com.