What Does Our Privacy Policy Include?

Adaptive Phage Therapeutics, Inc. (“APT”, “our”, “we”, “us”) takes data privacy seriously and we are committed to keeping your patient’s specific and di-identified information safe. We created this Privacy Policy to educate you on the measures we take to protect your patient’s information, on their rights to their information, and to be transparent with how we use and disclose the information you provide to us. If you do not understand any aspects of our Privacy Policy, please feel free to contact us as described at the end of this Privacy Policy. We may update this Privacy Policy from time to time by posting a new version online.

Our Privacy Policy focuses on the information provided to us through our products, applications, and services (collectively, the “Services”). With this information, the PhageBankTM Mobile Application (the “PhageBank App”) provides you, the treating physician and/or pharmacist, with information relating to the administration of a precision matched phage therapeutic to a patient. 

As with our PhageBank Terms of Use, by logging into an account created by APT on the PhageBank App, you are automatically accepting and acknowledging PhageBank Privacy Policy. To the extent you work as part of a team and are using an account created  for someone other than yourself (an “Authorizing Individual”), you represent that such person accepts and acknowledges this Privacy Policy and that you are authorized you represent by such person to act on their behalf. Our PhageBank App relies on limited personal Information obtained from you regarding your patient. Specifically, the PhageBank App relies on a de-identified patient ID number and a corresponding weight (in kilograms) of that patient (“De-Identified Information”).  This is the only information that we request regarding your patient.  Please read this policy carefully to understand what we do with this De-Identified Information.

However, our PhageBank App may also contain links to third party sites that are not owned or controlled by APT. We are not responsible for the privacy practices of such other sites. APT may share this De-Identified Information with these sites to the extent necessary to provide the Services and in a manner consistent with our Privacy Policy.

What Information Do We Collect?

We collect two types of information: (1) the De-Identified information described above (i.e., a de-identified patient ID number and a corresponding weight (in Kilograms) of that patient) that we receive from you or an Authorizing Individual about your patient, and (2) information that we collect through your use of the PhageBank App.

Information You Provide and Information We Collect:

You provide us information in several ways through our technology. 

  • Account Information. Once APT has created an account for you, we will ask that you enter your username and password, which we will collect and store.
  • Browsing and Usage Information: We use technologies to collect information about your use of the PhageBank App. We use these tools to improve the quality of our service, including for example, storing user preferences and/or tracking user trends.

How Do We Use and Share Personal Information Or Health Information?  

We do not collect or share Personal Information or Health Information that would otherwise be regulated under the Health Insurance Portability and Accountability Act (“HIPAA”).  Instead, we only collect the De-Identified Information described above – namely a patient’s weight and a de-identified patient ID number.  Subject to applicable legal restrictions, this De-Identified Information may be used as follows:

  • To provide you with the Services;
  • To communicate with you, provide you updates, respond to your requests, and provide customer support;
  • To improve and enhance our Services, including developing new products, features, and functionality, such as, for example, by creating aggregate data for research, product development or enhancement, or statistical analysis.
  • For other specific purposes that we provide you with notice of at the time the information is collected;
  • For compliance purposes, including enforcing our Terms of Use or other legal rights; and
  • For security purposes to protect our PhageBank App and Services.

We may also share the De-Identified Information in limited circumstances (subject to applicable legal restrictions) as follows:

  • To subcontractors, service providers and other third parties we use to support our business and who are bound by contractual obligations (e.g., Business Associate Agreements) to keep the De-Identified Information confidential and use it only for the purposes for which we disclose it to them.
  • To your patient’s health care provider, health care professional, health plan, employer’s clinical team, health care benefits consultant, or benefits manager clinical team if request by you.
  • As required by state or federal law, which can include providing information as required by statute, regulation, subpoena, court order, legal process, or government request.
  • To report, either directly or indirectly, to the federal Food and Drug Administration adverse events related to the phage products.
  • To report to the Centers for Disease Control and Prevention or other federal agency and/or state government agencies as required for public health surveillance and related purposes.
  • For a merger, sale, or other asset transfers in connection with a corporate transaction, in which we are acquired by or merge with another company.
  • As otherwise authorized by law.

Do Not Track Signals. 

APT does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, most web browsers will allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Children And Minors. 

The PhageBank App is to be used by adults who are at least age 18 or such older age as may be required by applicable state law.  We do not knowingly collect nor solicit any information from anyone under the age of 13 though our Services.  In the event that we learn that we have inadvertently collected information from a child under the age of 18 (or such older age of majority), we will use reasonable efforts to quickly delete that information.

How Is Your Information Protected?  

We use industry standard physical, technical and administrative security measures and safeguards in compliance with HIPAA to protect the confidentiality and security of the De-Identified Information. However, even with these safeguards, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. You should report any security violations or breaches to us by contacting us at [email protected] by calling us at +1-844-972-0500.

Where Will Your Information Be Maintained?  

The PhageBank App is operated and managed on secure, HIPAA-compliant cloud-based servers.

How Will You Know If This Policy Changes?  

We may change this Privacy Policy from time to time in the future. We will post any revised version of the Privacy Policy on our website at aphage.com/privacy and at other places we deem appropriate. Continued use of our Services will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

How Can I Contact You If I Have Questions?  

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, please email us at [email protected] or call us at +1-844-972-0500 , or by regular mail at:

Adaptive Phage Therapeutics
708 Quince Orchard Rd, Suite 205
Gaithersburg, MD 20878
Attn: Chief Legal Officer