Effective Date: December 24, 2018

Aptevo Therapeutics Inc. (“Aptevo” “we” or “us”) is committed to protecting the privacy of information about you. This Privacy Policy (this “Policy”) describes how we use, disclose, and protect the information that we collect about you when you:

  • Visit our website (https://aptevotherapeutics.com/) and any other websites that link to this Policy (collectively, the “Site”);
  • Interact with us in-person at events;
  • Interact with us in email, text or other electronic messages between you and our Site;
  • Apply for employment through our career website;
  • Apply to be a research study participant and/or participate in research studies we sponsor; or
  • Otherwise interact with us and we refer you to this Policy.
  • This Policy also contains information about your privacy rights and how you can exercise them.

    Aptevo is the data controller of the Personal Information we collect under this Policy. We encourage you to review the topics in this Policy.

      Personal Information We Process
      Sources of Personal Information
      How We Use Personal Information
      Sharing of Personal Information
      International Transfer of Personal Information
      Data Collection Technologies
      Third Party Websites and Services
      Security
      Retention of Personal Information
      Children’s Privacy
      Marketing
      Special Rights of Individuals in the European Economic Area
      Special Notice to California Residents
      Changes to this Privacy Policy
      Contact Us

    Personal Information We Process

    Personal Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity. We may process the following categories of Personal Information:

  • Contact and Biographical Information, such as your name, date of birth, postal address and/or email address, phone number, and photographs;
  • Digital Information, such as your IP address, device ID, and data collected about your interaction with the Site (such as the webpages you visited on the Site) and our email communications;
  • Recruitment and Professional Information, such as curriculum vitae/resume, job title, work experience, educational information, and other information collected in employment applications, and qualifications;
  • Research Study Participant Qualification Information, such as demographic and medical information used to determine whether you meet the eligibility criteria for enrollment into research studies; and
  • Any Other Information that you provide to us that can be used to identify you.
  • In addition to Personal Information, we may collect other information that alone cannot be generally used to identify you. For example, when you use the Site, we may collect your browser, device type, and operating system information. If any of this information can be used to identify you because, for example, we link it to your Personal Information, we will treat such information as Personal Information.

    Sources of Personal Information

    We collect information in the following ways:

  • Direct interactions, such as when you inquire about our services or products, contact us through the Site, apply for employment or ask to be a research study participant, or in any way engage with us or our personnel;
  • Cookies and automated technologies, such as when you interact with our website, or click on links on our emails;
  • Third party sources, such as your healthcare provider and marketing partners;
  • From our research sites that conduct research studies that we sponsor that may provide us with data about research study participants that has been de-identified under HIPAA or pseudonymized and/or anonymized under GDPR; and
  • Through social media, such as if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform.
  • How We Use Personal Information

    We use your Personal Information for the following purposes:

  • To manage our relationship with you, including to obtain your subscription preferences, send marketing communications, respond to online inquiries, conduct surveys and questionnaires, and register you for events and deliver event-related materials. These uses may be pursuant to our contracts with you or because we have a legitimate interest in doing so (e.g., to keep you informed of our news and events and to provide you with customer service).
  • To evaluate employment applications, if you have submitted an application for employment at Aptevo.
  • For research purposes, such as reviewing requests to participate in research studies, screening eligibility for enrollment, and analyzing and understanding research study results. When we process data for research, we may, when required by law, obtain your consent for such processing.
  • To perform website analytics so that we can better understand how our website is used. We do this pursuant to our interests in maintaining a useful and informational website.
  • To comply with regulatory obligations, in particular where they relate to drug safety, risk management, financial transparency, and similar requirements specific to the pharmaceutical sector, we process any Personal Information necessary for such compliance.
  • We may also aggregate, anonymize, or de-identify your Personal Information so that it can no longer be used to directly or indirectly identify you. This aggregated, anonymized, or de-identified information may be used for any purpose permitted by law.

    Other Uses: In the event of any other purposes for which we wish to use your Personal Information that are not listed above, or any other changes we propose to make to the existing purposes, we will notify you by amending this Privacy Policy in accordance with the Section titled “Changes to this Privacy Policy” below.

    Sharing of Personal Information

    We will share your Personal Information within Aptevo, at your direction, as disclosed to you at the time of collection, or in the following circumstances:

  • Service Providers: We may provide your Personal Information to our services providers that help us run and manage our organization and who process Personal Information solely on our behalf. Our categories of service providers include vendors in the technology, clinical research organizations, marketing, and operations space.
  • Corporate Transaction: In the event Aptevo is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Information as part of that transaction.
  • Third Party Collaborators: We may share your Personal Information with other companies with which we collaborate regarding particular products or services. These may include our co-promote partners for products that we jointly develop and/or market.
  • As Required By Law or to Protect our Legal Rights: We may disclose your Personal Information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests or safety of Aptevo, our business partners, personnel, or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms of Use or (vi) to respond to an emergency.
  • International Transfer of Personal Information

    Aptevo is committed to complying with this Privacy Policy and data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. Aptevo is located in the United States, and we recognize that the laws in the United States may be different and, in some cases, not as protective as the laws other countries, including those located in the European Economic Area. By providing us with your Personal Information and using our Site, you acknowledge that your Personal Information will be transferred and processed in the United States. If you would like to know more about how we protect your Personal Information, you can contact us using the information in the section “Contact Us” at the end of this Privacy Statement.

    Data Collection Technologies

    We use Cookies and other similar technology (together, “Data Collection Technology” on our Site. A “Cookie” is a text file that is placed on your hard disk by a web server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

    Data Collection Technology helps us improve your experience on our online services. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the webpages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

    Your Control of Cookies: Most web browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies. If you choose to decline Cookies, you may not be able to fully utilize all features of this Site. You have the ability to delete Cookies files from your hard drive at any time.

    Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. We follow the DNT signals we receive from your browsers.

    Third Party Websites and Services

    When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

    Security

    We implement technical and organizational measures designed to ensure your Personal Information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with our services. However, no Internet or email transmission is ever 100% secure, and we encourage you to take reasonable precautions to safeguard your Personal Data.

    Retention of Personal Information

    We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of 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, whether we can achieve those purposes through other means, and all applicable legal requirements.

    Children’s Privacy

    Our services are not directed to or intended for use by children. If we learn that we have received Personal Information directly from a child without his or her parent or legal guardian’s verified consent (where required by law), we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.

    Marketing

    If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of any marketing email, or email us using the information in the section “Contact Us.” Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.

    Special Rights of Individuals in the European Economic Area

    If you are located in the European Economic Area and we maintain your Personal Information, you have the following additional rights (under the European Union’s General Data Protection Regulation (the “GDPR”) with regard to your Personal Information:

  • Right to access and receive: You may request a copy of or access to the Personal Information we hold about you. You may also request that we transfer your Personal Information to a third party in a machine-readable format.
  • Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.
  • Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it.
  • Right to erase: You may have the right to request that we delete all or some of your Personal Information. This right may be limited if we have collected your Personal Information for research purposes.
  • Right to withdraw consent: You have the right to withdraw any consent you have previously given to Aptevo at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.
  • Right to complain: You have the right to lodge a complaint with your Supervisory Authority if you are unhappy with how we process your Personal Information. You can find contact information for your Supervisory Authority on the European Commission Data Protection Authorities webpage or through other publicly available sources.
  • Please note that if you decide to exercise some of your rights, we may be unable to provide you certain services, or you may not be able to use or take full advantage of the services we offer. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why. For purposes of the GDPR, Aptevo is the data controller of the information we collect under this Policy.

    Special Notice to California Residents

    California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.

    Changes to this Privacy Policy

    Aptevo reserves the right to modify this Policy at any time. Where any material revisions are made, Aptevo will notify individuals prior to when any material changes to the Policy take effect by reasonable means, including placing notice on the Site or by emailing you using the email address we have on file. Any modified Policy will supersede the current Policy and the date of the when the Policy was revised will be identified at the top of the Site webpage.

    Contact Us

    We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below and we will respond to you as soon as reasonably possible.

    Aptevo Therapeutics Inc.
    Attn: SVP, General Counsel and Corporate Affairs
    2401 4th Ave. Suite 1050
    Seattle, WA 98121 USA
    privacy@apvo.com
    484-318-8840