Apogee Therapeutics PrivacyNotice
Last Updated: March 10, 2025
Apogee Therapeutics, Inc. (“Apogee,” “we,” or “us”) is committed to protecting your privacy and understands the importance of safeguarding your personal data. This Privacy Notice explains how we process your personal data in connection with the use of our websites (“Websites”) and related services (“Apogee’s Services”), including when you interact with us as a consumer, a patient, business contact (the “Business Services”, or “Services”), or as a healthcare professional.
This Privacy Notice is intended to provide you with meaningful insight into our practices with respect to your personal information. In some cases, we or our representatives may provide you with a separate privacy notice as legally required, such as when you participate in a clinical trial sponsored by Apogee. Where a separate notice is provided, it will supersede this Privacy Notice for that specific scenario.
With limited exception for certain research activity, this Privacy Notice is intended for use by residents of the United States only. If you are a California resident please scroll down to view the Supplemental Privacy Notice for Residents of California. If you are a healthcare professional, scroll down to view the Supplemental Privacy Notice for U.S. HCPs. For residents of the European Economic Area, Switzerland and the UK, scroll down to view the Supplemental Privacy Notice for these jurisdictions.
Please read this Privacy Notice carefully. If you have any questions about our data practices or this Privacy Notice, please contact us at privacy@apogeetherapeutics.com.
Personal Data Processed by Apogee
Depending on your interactions with us, we may process the following categories of personal data:
· Direct Identifiers and contact Information: Such as your name, email address, mailing address, telephone numbers, country.
· Demographic Information: Such as age and gender.
· Business and Interaction Information: This includes details about your relationship and interactions with Apogee, such as participation in Apogee-supported or sponsored initiatives, and information about products, treatments, and health conditions that may be of interest to you.
· Transaction Information: This includes information about purchases, inquiries, and how you use our Websites.
· Professional or Employment-Related Information: If you interact with us as a job applicant or in a professional capacity, we may process information about your specialty, practice, institution, resume details, educational information, and references.
· Sensitive Personal Data: Such as a driver’s license number, Social Security Number, tax ID number or other national ID number, passport number, health information, or disability information.
· Non-Precise Geolocation Data: General information about your approximate location collected via device settings.
· Internet and Other Electronic Activity: Device information (operating system, browser type, language), referring URLs, access times, pages viewed, links clicked, Internet Protocol (“IP”) address, if applicable, and other information about your activities on our Websites.
We collect personal data from:
· You Directly: We collect personal information that you voluntarily provide when you communicate with us. For example, when you use our Services, submit comments, questions, or requests, when you register for a program, participate in a survey, provide a testimonial, participate in an interactive feature or forum.
· Automatic Collection: Through cookies and similar technologies when you interact with our Websites. For more information about cookies and other technologies, please see the “Cookies and Other Tracking Technologies” section below.
· Third Parties: Such as vendors, suppliers, research partners, social media platforms you use to interact with us, and other business partners or affiliates.
· Others You Direct: Any other third parties you have instructed to share information with us.
Why We Process Your Personal Data
1. Website-Related Services
· Administrative Communications: We may send you important information, such as changes to our terms, conditions, and policies and/or other administrative information. Because this information maybe important, you may not opt out of receiving such communications.
· Online Services: We collect and use information about how you and other users interact with our online services through our websites, apps, and online tools such as Google Analytics. We use this information in order to compile statistics for analysis of our Services and our business and to make decisions to optimize the experiences we deliver through digital and online channels.
2. Operating and Providing Business Services
We process personal data to:
· Fulfill and Respond to Requests. We may communicate with you to process, complete and fulfill your requested transactions, or provide our products and services.
· Provide customer service and respond to your Inquiries. We may provide customer service, respond to your questions about applications, clinical trials and other services, verify information provided to us, and determine eligibility for our products, services and programs.
· Communicate with you about our activities, products, and services, and to provide information we think will be of interest to you, which may include marketing and promotional materials.
· For Research. We may use the information we collect from you to better understand our audiences, evaluate user interest in the Services, improve the Services, and perform other market research activities, as well as conduct surveys, identify and recruit individuals to participate in our research programs, interview individuals relating to our research, conduct clinical trials, create directories and compile databases of contact information. When required by law, we will use anonymized or de-identified information for these purposes.
· For Internal Business Purposes. We may use information we collect from you to facilitate our business operations, including data analysis; auditing, assessing quality and safety, monitoring and preventing fraud, infringement, and other potential misuse of the Services; determining the effectiveness of our promotional campaigns and improving our products, services, and technology; and operating and expanding our business activities.
· Communicate with job applicants regarding employment opportunities.
3. Legal Purposes
We may process personal data to detect, investigate, and prevent fraud or illegal activities, respond to legal requests, including requests in connection with investigations and dispute-resolution processes, as permitted or required by applicable law, manage subpoenas and claims, and protect our rights and property or those of others.
4. Pseudonymized and Anonymized Information
We may create pseudonymized but also anonymized information that can no longer identify you. We use such data for research, secondary research, and educational purposes.
How We Disclose Personal Data
We may disclose personal data about you as follows:
· Service Providers and Vendors: We may share your personal information with service providers who provide us with services for our websites, as well as other products and services, such as webhosting, data analysis, payment processing, order fulfillment, customer service, infrastructure provision, technology services, email delivery services, credit card processing, legal services, and other similar services. We grant our service providers access to personal information only to the extent needed for them to perform their functions and require them to protec tthe confidentiality and security of such information.
· Research Partners: We may share your personal information with unaffiliated trusted third parties that partner with us to deliver a Service or to support our commercial or research activities, including third-party vendors, research sites, or potential research sites for research-related purposes, such as recruitment, screening, and conducting studies. Depending on the choices you have made and the nature of the activity, these third parties may contact you regarding Apogee-related products, programs, services and promotions that may be of interest to you. You may always opt-out from receiving marketing communications from our partners by following the instructions in their electronic communications. However, we do not sell, rent or otherwise share your personal information with any unaffiliated third parties for their own use or marketing purposes.
· Regulatory Bodies: We disclose data to regulatory agencies when required for reporting, compliance, or requests for information about clinical trials and operations.
· Business Transfers or Assignments. If we decide to reorganize or divest part or all of our business or a line of our business, including our information databases and websites, through a merger, sale, joint venture or collaboration, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from site users or offline to a third party. We will share your personal data with such third party (without your consent or any further notice to you). In such circumstances, we will seek written assurances that your personal information will be protected consistently with this Privacy Notice.
· Affiliates: We may disclose data between and among Apogee companies under common control or ownership.
· With Your Consent or Direction: We disclose personal data to third parties when you have consented or directed usto do so.
· Legal and Regulatory: We reserve the right to disclose your personal information as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served onus, or to protect the safety, rights, or property of our customers, the public, Apogee or others. We have no obligation to notify you of such disclosures, except as required by applicable law.
· Other Third Parties. We may share information with third parties, such as information shared when you use interactive features. In addition, cookies, pixels, web server data, and other technologies may involve sharing of information with third parties.
Cookies and Other Tracking Technologies
We and our service providers may collect basic information about you and your surfing habits automatically through browser navigational tools, cookies, pixel tags also known as web beacons and similar technologies to collect personal data and improve your experience on our Websites.
Below are descriptions of the online tools we may use to collect this usage information:
Browser Navigational Tools: Certain information is collected by most browsers, such as your computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.
Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.
Pixel Tags and similar technologies: We may also use pixel tags(also known as web beacons, clear GIFs) or similar technologies (collectively, “Pixel Tags”) in connection with some website pages and HTML-formatted email messages to, among other things: track the online activity of users of the Services and our email recipients (including activity on other websites);determine the success of marketing campaigns; and compile aggregate statistics about site usage of the Services and response rates.
Cookies: are small datafiles stored on your hard drive or in device memory that help us improve our online presence and your experience, see which areas and features of our websites are popular, and count the number of visits. We generally use the following categories of tracking technologies:
· Essential (Strictly Necessary): First party cookies that are essential for our Websites to function.
· Functional: Enable enhanced features, personalization, and site functionality. They may be set up by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
· Performance (Analytics): These cookies allow us to measure and improve site performance. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. We use tools like Google Analytics, subject to your consent, where required, in limited geographies to gather traffic information to allow us to improve our websites and support their functionality. To prevent these services from collecting your user activity on websites, see https://tools.google.com/dlpage/gaoptout.
For more information about cookies, and how to exercise your choices, please see “Your Rights” below, as well as the supplementary notices, where applicable.
Cookie Consent: In jurisdictions requiring consent, we only use non-essential cookies (such as analytics) if you have provided prior consent. You can manage your preferences using our cookie consent tool or through your browser settings. Disabling cookies may affect some Website functionalities.
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. Our Websites may not respond to “Do Not Track” signals due to lack of a common standard.
Your Rights
General Rights for All Users:
· Cookie Control: You can set your browser to refuse all or some browser cookies or alert you to their presence. Some site features may not work if cookies are disabled.
· Marketing Communications: You may opt out of marketing emails by clicking “unsubscribe” in the email or contacting us at privacy@apogeetherapeutics.com. We may send you important information, such as changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt out of receiving such communications.
The country or state where you are located or reside may grant you additional privacy rights with respect to the personal data we maintain about you. We included an explanation of these rights for some of these locations below.
We will take steps to verify your identity before processing certain requests. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the individual with whom we collected personal data. We will only use the personal data provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal data, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
You may contact us at privacy@apogeetherapeutics.comto exercise one of these rights. Please include your name and the email address to which you would like us to respond.
Other Aspects of Our Privacy Practices
Links to Other Sites
Our websites may contain links to third-party websites that Apogee does not control. We are not responsible for the privacy practices or the contents of any such linked sites, or for the nature, quality, or accuracy of the content or opinions expressed in such websites. We do not investigate, monitor, or check the quality, accuracy, or completeness of these third-party sites. Inclusion of any linked website on our Websites does not imply or express an approval or endorsement of the linked website by Apogee, or of any of the content, opinions, products, or services provided on such websites. Each of these linked sites maintains its own independent privacy policy. If you visit a website that is linked to our Websites, we encourage you to familiarize yourself with the privacy policy of that website, which is not governed by this Privacy Policy.
International Data Transfers
Any personal information collected for the purposes described in this Privacy Notice and Supplemental Privacy Notices, may be stored and processed, transferred between and accessed from the United States (including our group companies and our external technology service providers), and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Notice regardless of where your personal information is stored or accessed. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your information.
Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and comply with our legal obligations. Retention periods may vary depending on the nature and sensitivity of the data, the reasons for its collection, and applicable legal requirements. We regularly review our data retention policies to ensure that personal data is securely deleted or anonymized when no longer needed.
Information Security
We use reasonable organizational, technical and administrative safeguards to help protect the information collected through the Services. Our security and privacy policies are periodically reviewed and enhanced, and are designed to allow only authorized individuals to have access to the information you provide. However, data transmitted over the Internet cannot be guaranteed to be completely secure from people who might attempt to evade our security measures. Your email is a non-encrypted form of Internet communications which may be accessed and viewed by other Internet users without your knowledge or permission while in transit to us. For that reason, in order to protect your privacy, please do not use email to communicate information to us that you consider confidential. While we strive to protect your personal information, Apogee cannot guarantee the security of any information you transmit to us through our Websites. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at privacy@apogeetherapeutics.com.
Personal Data of Children
We are committed to protecting the privacy of children. Our Websites and any accompanying Services offered are not directed at children who are under 16 years of age. It is our policy to require that individuals requesting information on our products be 16 years of age or older. We may collect the personal information of minors in connection with other business activities, such as adverse event reporting. Should we receive personal information from a person whom we know is under 16 years of age, we will endeavor to delete such information from our website database, and the information will not be used for any purpose. If you believe that a person under 16 years of age has provided us with their personal information, please notify us so that we can take reasonable steps to remove the information from our database.
Updates to this Privacy Notice
We may update this Privacy Notice periodically. If we make material changes, we will notify you in advance when required by law. We encourage you to review this Notice regularly to stay informed about our data practices and your available choices.
Contact Us
For general questions about our privacy practices or this Privacy Notice, please contact us at privacy@apogeetherapeutics.com.
You may also write to us at:
Apogee Therapeutics, Inc.
Attn: Privacy Officer
221 Crescent Street
Waltham, MA 02453
Supplemental Privacy Notice for Residents of California
Last Updated: March 10, 2025
1. If you are a resident of one of the above-mentioned states, you have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of2020 (“CPRA”) and its implementing regulations. Pursuant to these laws, this Privacy Notice is intended to provide you with meaningful insight into our practices regarding your Personal Information, the rights that you have, and how you may exercise them.
Please be aware that the scope of your rights as well as our obligations may differ depending on your state of residence. In those instances, we have identified the states that recognize theright or obligation. In many instances, we may not be subject to the privacy laws of your state.
A. Definitions
· “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
· “Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
· “Third Party” has the meanings afforded to it in the CPRA.
· “Vendor” means a service provider, contractor, or processor as those terms are defined in the CPRA.
To the extent that other terms used in this Supplemental Notice are defined terms under the CPRA they shall have the meanings afforded to them in those statutes. The definition that is applicable to you is provided in the law of the state in which you reside.
B. Collection & Processing of Personal Information
We and our vendors may have collected the following categories of Personal Information about you in the last 12 months:
1) Identifiers, such as name and government-issued identifier (e.g., Social Security number);
2) Personal information, as defined in the California safeguards law, such as contact and financial information;
3) Characteristics of protected classifications under California or federal law, such as age, gender, race, medical conditions, and marital status;
4) Commercial information, such as transaction information and purchase history;
5) Biometric Information;
6) Internet or other electronic network activity information, such as browsing history and interactions with our Websites;
7) Geolocation data, such as device location;
8) Audio, electronic, visual and similar information, such as call and video recordings;
9) Professional or employment-related information, such as work history and prior employer;
10) Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
11) Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
12) Sensitive Personal Information, including:
A. Personal information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a consumer’s email and text messages, unless the business is the intended recipient thereof; or
vi. Genetic data.
B. Biometric data processed for the purpose of uniquely identifying a consumer;
C. Personal Information collected and analyzed concerning a consumer’s health; and
D. Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Retention of Personal Information. We will retain your Personal Information only for a period that is reasonably necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required by law.
C. Sources from Which We Collect Personal Information
We collect your Personal Information directly from California, residents, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies that help us screen and onboard individuals for hiring purposes, and other entities when they share the information with us.
D. Categories of Personal Information We Disclose to Vendors & Third Parties
We may disclose the following categories of Personal Information to Vendors and Third Parties:
1) Identifiers, such as name and government-issued identifier (e.g., Social Security number);
2) Personal information, as defined in the California safeguards law, such as contact and financial information;
3) Characteristics of protected classifications under California or federal law, such as age, gender, race, medical conditions, and marital status;
4) Commercial information, such as transaction information and purchase history;
5) Biometric Information;
6) Internet or other electronic network activity information, such as browsing history and interactions with our Websites;
7) Geolocation data, such as device location;
8) Audio, electronic, visual and similar information, such as call and video recordings;
9) Professional or employment-related information, such as work history and prior employer;
10) Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
11) Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
12) Sensitive Personal Information, including:
A. Personal information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a consumer’s email and text messages, unless the business is the intended recipient thereof; or
vi. Genetic data.
E. Biometric data processed for the purpose of uniquely identifying a consumer;
F. Personal Information collected and analyzed concerning a consumer’s health; and
G. Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
We have not sold or shared your Personal Information in the last twelve months. For purposes of the CPRA, “sold” or “sale” means the disclosure of Personal Information to a Third Party for monetary or other valuable consideration. “Share” or “sharing” means the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
E. Categories of Entities to Whom We Disclose Personal Information
We will only disclose your Personal Information for purposes that are described in Section F of this Privacy Notice. We may have disclosed your Personal Information to:
· Affiliated Entities. We may share your Personal Information with our affiliated companies for the purposes described in this Privacy Policy.
· Service Providers. We may share your Personal Information with service providers who perform services in our behalf. When we do so, we limit the service provider’s access to your Personal Information only to the extent that is needed for them to perform the service.
· Commercial and Collaboration Partners. We may share your Personal Information with commercial and collaboration partners who we may work with to deliver a particular Service or support our commercial or research activities.
· Third Parties. We may disclose your Personal Information to:
o Any Third Party, provided that you have directed us or have provided your consent to do so.
o Other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
o Government authorities, regulatory bodies, or courts when the disclosure is reasonably necessary for our business operational purposes, to assert and defend legal claims, or otherwise as permitted or required by law.
F. Purposes for Processing Personal Information
We and our Vendors may use your Personal Information to:
· Operate, manage, and maintain our business;
· Provide our products and services;
· Develop, improve, repair, and maintain our products and services;
· Personalize, advertise, and market our products and services;
· Conduct research, analytics, and data analysis;
· Maintain our facilities and infrastructure;
· Undertake quality and safety assurance measures;
· Conduct risk and security controls and monitoring;
· Detect and prevent fraud;
· Perform identity verification;
· Perform accounting, audit, and other internal functions, such as internal investigations;
· Comply with law, legal process, and internal policies;
· Maintain records;
· Exercising and defend legal claims.
· For employment purposes, including hiring and managing employees; or
· Otherwise accomplish our business purposes and objectives.
We and our Vendors will only use your Sensitive Personal Information for the following purposes:
· To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
· To ensure security and integrity to the extent the use of the consumer's Personal Information is reasonably necessary and proportionate for these purposes;
· For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us; provided that we will not disclose your Personal Information to a Third Party and or build a profile about you;
· To perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
· To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
G. Your Rights Under California State Privacy Law
As a resident of California you are entitled to certain rights with respect to your Personal Information. These include the following:
· The Right to Non-discrimination. We will not discriminate against you for exercising any data subject rights that you have under California state privacy law. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
· The Right to Access Certain Personal Information. You may request that we provide you with access to certain Personal Information that we have collected about you, subject to exceptions provided by law.
· The Right to Delete Certain Personal Information. You may request that we delete certain Personal Information that we have collected about you, subject to exceptions provided by law.
· The Right to Opt-out of Processing for Targeted Advertising and Sales. You have the right to opt-out of the processing of your Personal Information for targeted advertising and sales, as defined by state law. However, as we explain in Section D, above, we do not process your Personal Information for these purposes.
· The Right to Correction. You may request that we correct any inaccurate Personal Information that we maintain about you.
Additionally, as a California resident, you have the following rights, subject to certain exceptions:
· Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:
o The categories of Personal Information to be collected;
o The purposes for which the categories of Personal Information are collected or used;
o Whether or not that Personal Information is sold or shared;
o If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
o The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
We have provided such information in this Privacy Notice, and you may request further information about our privacy practices by contacting us as at the contact information provided above.
· Right to Deletion. You may request that we delete any Personal Information about you we that we collected from you.
· Right to Correction. You may request that we correct any inaccurate Personal Information we maintain about you.
· Right to Know. You may request that we provide you with the following information about how we have handled your Personal Information in the 12 months preceding your request:
o The categories of Personal Information we collected about you;
o The categories of sources from which we collected such Personal Information;
o The business or commercial purpose for collecting Personal Information about you;
o The categories of Personal Information about you that we shared or disclosed and the categories of Third Parties with whom we shared or disclosed such Personal Information; and
o The specific pieces of Personal Information we have collected about you.
· Right to Receive Information About Onward Disclosures. You may request that we disclose to you:
o The categories of Personal Information that we have collected about you;
o The categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and
o The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
· California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of the Services, you may ask us to remove content or data that you have posted to the Services by writing to privacy@apogeetherapeutics.com.Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
H. Submitting Data Privacy Requests
You may submit a request to exercise one or more of the rights outlined in Section G, above, by contacting our Privacy Office at privacy@apogeetherapeutics.com.
We may ask you to provide information that will enable us to verify your identity. In some instances, we may decline to honor your request if an exception applies, such as when the disclosure of Personal Information would adversely affect the rights and freedoms of another person. We will respond to your request consistent with applicable law.
As explained in Section G, we will not discriminate against you for exercising your rights under state law. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your rights.
Supplemental Privacy Noticefor U.S. Healthcare Professionals
Last Updated: March 10, 2025
This Privacy Notice is intended for healthcare professionals and institutional healthcare providers who are considering working with or who already work with Apogee. This Privacy Notice supplements Apogee’s Privacy Notice, provided above.
We may collect personal information regarding your professional credentials, educational and professional history, institutional and government affiliations, and information included on a resume or curriculum vitae about your education and work history. We may also collect information about Apogee and third-party programs, products and activities with which you have engaged, including but not limited to: details about our interactions with you, your prescribing of our products, the agreements you have executed with us, and any payments made to you for services provided; and publicly available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence-related information.
As a healthcare professional or an institutional healthcare provider, you are responsible for obtaining any legally required authorization, consent or other permission from your patients prior to providing their personal information to Apogee through the Services. By submitting any personal information about a patient, you represent and warrant to us that you have obtained all required permissions to do so.
Supplemental Privacy Notice for Residents of the European Economic Area, Switzerland and the UK
Last Updated: March 10, 2025
If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), personal information about you may be protected by data protection laws in the EEA, Switzerland, or UK, such as the European Union General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection, the UK GDPR and the UK Data Protection Act 2018 as amended and in force. Apogee will comply with these data protection laws when it processes personal information about you as described in this Notice.
To learn more about this Notice and/or to exercise any of your privacy related rights mentioned below, you can contact Apogee's Data Protection Officer at privacy@apogeetherapeutics.com.
Also,as Apogee is based outside the EEA territory, it has designated as its EURepresentative an EEA based company with the following details: LumisInternational GmbH, Giesebrechtstrasse 15, 10629 Berlin, Germany, hs@lumisinternational.com.
When processing personal information as described in this Notice, Apogee relies on one of the following legal bases, as appropriate:
· Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
· Where it is necessary to comply with contractual obligations with you;
· Where the processing is necessary for our compliance with a legal obligation;
· Where the processing is necessary to protect the vital interests of an individual; or
· Where the processing is in Apogee’s legitimate interest, for example, Apogee processes data for scientific and statistical research purposes, for scientific development, for the improvement of our products and services, to provide security measures to protect its employees, contractors, patients, information, and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations) or in other ways strictly necessary to carry out our business.
In addition to the above, where Apogee processes special categories of data about individuals (information about individuals’ health, ethnicity, religion, trade union membership, genetic and biometric data etc.), it shall only do so in accordance with applicable laws and regulations. For such processing Apogee relies on the following conditions:
· Where individuals provide explicit consent;
· Where required for rights and obligations related to employment;
· Where required for vital interests of any individual;
· Where processing is necessary for the purposes of provision of healthcare or occupational medicine, pursuant to a contract with a health care professional; and
· Where processing is necessary for scientific research.
Apogee is headquartered in the U.S. and as a result, personal information about you will be processed by Apogee in the U.S. Apogee may contract with service providers to process personal information on Apogee’s behalf; these service providers may be located outside of the EEA, Switzerland, and UK. Data protection laws in the U.S. or other countries may not offer you the same protections as the laws of the country in which you are residing when personal information about you is collected.
Where Apogee processes personal information in countries that may not provide the same level of data protection as in the country in which you are residing, Apogee will implement reasonable and appropriate legal, technical, and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorized access, use or disclosure. In the absence of an adequacy decision adopted by the European Commission or the Swiss/UK Data Protection Authorities, Apogee will implement appropriate data transfer mechanisms (such as the Standard Contractual Clauses (SCCs)) for any cross-border data transfers from your country to a third party (controller or processor) located in a third country with the aim to secure such transfers and achieve an adequate level of data protection.
Data protection laws in the EEA, Switzerland, and the UK may provide you the following rights with respect to personal information processed by Apogee:
· Information and Access: Request details about how your personal data is processed, and the right to obtain a copy of the personal data we hold about you.
· Rectification: Correct inaccurate or incomplete personal data we maintain about you.
· Erasure: Request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw consent.
· Restriction: Request we limit or restrict processing of your personal data in specific situations, such as while verifying the accuracy of data or objecting to processing.
· Portability: Receive your personal data in a structured, commonly used, and machine-readable format and transfer it to another controller where technically feasible.
· Objection: Object to certain types of processing, including direct marketing or processing based on legitimate interests.
· Withdraw Consent: Where processing is based on consent, withdraw it at any time, and it will not affect the lawfulness of prior processing.
· Complaint: Lodge a complaint with a supervisory data protection authority, if you believe your data protection rights have been violated. Contact information for EEA data protection authorities can be found on the European Data Protection Board website. Contact information for the UK data protection authority can be found on the Information Commissioner’s Office website and the Swiss one here.
Please note that these rights are not absolute. Apogee’s ability or obligation to comply with your requests may be limited by applicable laws. Apogee will require appropriate evidence of your identity or to be provided with additional relevant information based on your relationship with us before we are able to act on your request when the information, we have is insufficient to accommodate your request. To request to exercise one of these rights if you are located in the EEA, Switzerland, or UK, please contact us at privacy@apogeetherapeutics.comwith your name, address, telephone number, and the email address where you’d like to receive our response.