Treeline

Last Updated: February 25, 2025

This Privacy Notice applies to the processing of personal information by Treeline Biosciences, Inc. (“Treeline,” “we,” “us,” or “our”) including on our website available at www.treeline.bio and our other online or offline platforms and research programs which link to, or are otherwise subject to, this Privacy Notice. It explains the types of personal information we may collect when you visit our websites, communicate with us, participate in our research-related initiatives, or otherwise interact or engage with us (collectively, the “Activities”) and describes the purposes for which we collect and use personal information along with additional details about our privacy practices.

Special Note Regarding Clinical Trials: If you are a clinical trial participant (i.e., clinical trial patient, potential clinical trial patient, investigator, or team member), please note that this Privacy Notice is in addition to any informed consent or privacy notice provided by Treeline as part of your clinical trial participation.Any such informed consent or additional privacy notice will override this Privacy Notice with respect to our processing of your personal information obtained by us as a result of your clinical trial participation.

Special Note to United States Residents and Consumers: For information on our processing of “consumer health data” subject to the Connecticut Data Privacy Act, Nevada Consumer Health Data Privacy Law, or Washington My Health My Data Act, as amended, please see Annex A – Supplemental U.S. Consumer Health Data Privacy Notice.

Special Note to Individuals Within the European Union, Switzerland, and the United Kingdom: For information on our processing of personal information subject to the privacy and data protection laws and regulations of the European Union, Switzerland, or the United Kingdom, please see Section 7 below.

1. UPDATES TO THIS PRIVACY NOTICE

2. PERSONAL INFORMATION WE COLLECT

3. HOW WE USE PERSONAL INFORMATION

4. HOW WE DISCLOSE PERSONAL INFORMATION

5. YOUR PRIVACY CHOICES AND RIGHTS

A. Your Privacy Choices. The privacy choices you may have about your personal information are described below.

B. Your Privacy Rights. In accordance with applicable law, you may have the right to:

6. RETENTION OF PERSONAL INFORMATION

We will retain personal information collected as described in this Privacy Notice, for the time absolutely necessary to serve the purposes of processing and to comply with our legal obligations. In case you recall your consent to the collection and processing of your personal information, where consent has been provided, we will immediately delete your data from our electronical and physical records, unless its retention is necessary so as to comply with a legal obligation or to exercise, ground and defend our lawful rights and interests before a Court or any other Regulatory Authority.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

8. SUPPLEMENTAL NOTICE FOR INDIVIDUALS WITHIN THE EUROPEAN UNION, SWITZERLAND, AND THE UNITED KINGDOM

9. CHILDREN’S PERSONAL INFORMATION

10. THIRD-PARTY WEBSITES/APPLICATIONS

11. CONTACT US

ANNEX A – SUPPLEMENTAL U.S. CONSUMER HEALTH DATA PRIVACY NOTICE

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our websites, and/or we may also send other communications.Where permissible by applicable law, you understand and agree you will be deemed to have accepted the updated Privacy Policy if you continue to engage in Activities after the new Privacy Notice takes effect.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you engage in Activities, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Information. Where applicable, we may collect personal information in connection with the creation or administration of a Treeline account. This personal information may include, but is not limited to, your name, email address, phone number, business name, professional title, and other information you store with your account.
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email, messaging or chat features, or other automated interactive tools.Please do not submit unsolicited health or other sensitive information to us.
Clinical Research Studies.We will process your personal information in the scope of clinical trials, whether you are a trial participant, member of a medical staff, a service provider, regulator staff, investigator, or any third party involved in the clinical research.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Interactive Features. We and others who engage in Activities may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, and social media pages).Any information you provide using the public sharing features of the Services will be considered “public.”Therefore, when providing information through public sharing features, please do not provide health or other sensitive information.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Relationships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information, resume, and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you engage in the Activities.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
Usage Information. We may collect personal information about your use of our websites and other Activities, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use our websites and other Activities.
Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your engagement in the Activities.
- Cookies. Cookies are small text files stored in device browsers which facilitate your interactions with the Activities.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code dropped onto your computer or other device that collects personal information about use of or engagement with the Activities. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties.For example, if you access our websites or engage in other Activities using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings or selections. In addition, users of our websites and other Activities may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Activities, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Activities / Business Operations

We use personal information for providing the Activities and operating our business, including:

Managing your information;
Providing access to certain areas, functionalities, and features of the Activities;
Administering our relationship with you as a user, health care provider, clinical researcher, or business partner;
Conducting or sponsoring clinical research studies;
Answering communications received;
Communicating with you;
Sharing personal information with third parties as needed to provide the Activities and operate our business; and
Processing applications if you apply for a job we post on our websites or otherwise.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Allowing you to register for events;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Carrying out analytics;
Measuring interest and engagement in the Activities;
Improving, upgrading, or enhancing the Activities;
Developing new products and services;
Creating de-identified and/or aggregated information;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
Debugging to identify and repair errors with the Activities;
Auditing relating to interactions, transactions, and other compliance activities;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

California Shine the Light:If you are a California resident, you may annually submit a request to us to find out whether we have shared your personal information with third parties for the third parties’ direct marketing purposes. If you would like to submit such a request, please “Contact Us.”

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.

If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Activities, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Activities and Operate our Business

We may disclose any of the personal information we collect to the categories of third parties described below.

Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Activities and the operation of our business. This may include, but is not limited to, service providers that provide us with clinical trial, recruiting, human resources (including insurance and other benefits support), hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and messages, chats or other communications may be disclosed to service providers that help provide our communication features or monitor our communications.

Some of the service providers we may use in connection with the Activities include:

Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
Cookiebot. For more information about how Cookiebot uses your personal information, please visit Cookiebot’s Privacy Policy.

Third-Party Services You Share or Interact With. The Activities may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.Providing personal information to such Third Party Services is at your own risk.

Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

Clinical Research Organizations, Clinical Trial Investigators, and Staff.We will share your personal information with clinical research organizations, clinical trial investigators, and staff participating in clinical trials in whichyou enroll or seek to enroll.
Regulators and/or Government Bodies. We may share your personal information with Regulators, in the scope of clinical trials, or with government bodies for employment-related purposes.
Affiliates. We may share your personal information with our corporate affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our websites (including our other online offerings) to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

A. Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted promotional email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Activities, and you will not be able to opt out of those communications (e.g., communications regarding the Activities or updates to this Privacy Notice.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Activities may not work properly.

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

B. Your Privacy Rights. In accordance with applicable law, you may have the right to:

Confirm Whether We Are Processing Your Personal Information;
Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to our Processing of Your Personal Information;
Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws),if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

6. RETENTION OF PERSONAL INFORMATION

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, the safeguards we may use to support such transfer include the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please “Contact Us.”

8. SUPPLEMENTAL NOTICE FOR INDIVIDUALS WITHIN THE EUROPEAN UNION, SWITZERLAND, AND THE UNITED KINGDOM

This Supplemental European Privacy Notice only applies to our processing of Personal Information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing Personal Information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter a contract. If you choose not to provide Personal Information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the Personal Information.

If we process Personal Information that is considered a “special category of personal data,” then our processing of such Personal Information may be supported by one or more of the following conditions:

Explicit Consent: You may have provided your explicit consent for our processing of your Personal Information.
Necessary for Employment, Social Security, or Social Protection Law Purposes: Our processing of your Personal Information may be necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment, social security, and/or social protection law.
Necessary to Protect Vital Interests: Our processing of your Personal Information may be necessary to protect the vital interests of you if you are physically or legally incapable of giving consent.
Publicly Available Personal Information: Our processing of your Personal Information may relate to Personal Information which has been manifestly made public by you.
Necessary for the Establishment, Exercise or Defense of Legal Claims: Our processing of your Personal Information may be necessary for the establishment, exercise or defense of legal claims.
Necessary for Substantial Public Interest: Our processing of your Personal Information may be necessary for reasons of substantial public interest.
Necessary for Medical Purposes: Our processing of your Personal Information may be necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, or pursuant to contract with a health professional.
Necessary for Substantial Interest in the Area of Public Health: Our processing of your Personal Information may be necessary for reasons of public interest and/or public health.

If your Personal Information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your Personal Information violates applicable law.

If you are located within the European Economic Area, you may find the contact details of the competent authorities in the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are located within the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (ICO) by clinking here: https://ico.org.uk/make-a-complaint/.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, you may contact us as described in “Contact Us” below.

9. CHILDREN’S PERSONAL INFORMATION

Except for clinical trials, the Activities are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Activities in violation of applicable law, you may contact us as described in “Contact Us” below.

10.THIRD-PARTY WEBSITES/APPLICATIONS

The Activities may contain links to other websites/applications and other websites/applications may reference or link to our Activities. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

11. CONTACT US

Treeline is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Postal Mail:
Treeline Biosciences, Inc.
500 Arsenal Street
Watertown, Massachusetts 02472

Email (including EU/UK DPO):
privacy@treeline.bio

EU Data Protection Representative:
euprivacy@treeline.bio