Privacy Policy

Seres Therapeutics, Inc. (“Seres,” “our,” “we” or “us”) respects your privacy and we want you to be familiar with how we collect, use, share, or otherwise process your personal information. This Privacy Notice explains what kind of personal information we may collect when you visit our website(s) or interact with Seres online, through email, participation in our programs or services, or engage in other business interactions with us that refer to this Privacy Notice (collectively, our “Programs”). This Privacy Notice describes:

• The information that we collect or that you provide through the course of recruitment and employment at Seres, when you participate in one of our clinical trials, visit our website(s), engage with us professionally, or otherwise participate or use one of our other Programs or services
• How we use, disclose (share), store and otherwise process that information
• With whom we may share that information
• The safeguards we use to protect that information
• Your rights with respect to information that identifies you or can be used to identify you (“personal information”)

Categories of Personal Information Collected and Disclosed

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or device (“personal information”). The type of personal information we collect depends on the nature of your interactions with Seres and our Programs. For example, we may collect:

• Personal and unique identifiers, such as your name, email, social security number and other contact information you choose to provide to us
• Demographic Information, such as your age or date of birth
• Professional Information, including professional credentials, NPI, specialty, education history, employment history, academic qualifications, etc.
• Internet and electronic network activity information, such as information about your interactions with our website(s) and online resources
• Inferences we derive from the information that we collect

Use of Personal Information

We may use the personal information we collect to:

• Fulfill or meet the purpose(s) for which the information is provided. For example, address questions related to products in development, or in market, or deliver requested information on resources available related to the therapeutic areas or other medical or scientific areas that Seres provides
• Recruit for employment purposes, new-hire onboarding and other activities in the course of employment with Seres, which may include pre-employment screening, scheduling interviews, or communications regarding the application process, benefit administration, payroll, etc.
• Respond to questions on recruitment to our clinical trials or refer you to specific organizations that may provide information on how to participate in clinical trials
• Provide information relating to products in development
• Provide marketing information relating to products marketed by Seres, its affiliates, collaborators, or licensees
• Fulfill our obligations to you under an applicable contract or to conduct business with you
• Provide you with our Programs, or support-related activities
• Identify and engage thought leaders and external experts
• Analyze use of our website(s), or to enhance or develop new features for our website(s)
• Create aggregated analytics for research purposes
• Communicate with you regarding Programs where you are engaged
• Conduct surveys, or polls and obtain testimonials
• Distribute and market our products
• Send you promotional materials, (e.g., newsletters)
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, joint venture, or other sale, transfer or disposition of some or all of our assets, whether in connection with any bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred
• Conduct other legitimate business activities, as allowed by applicable law

We may combine the personal information we collect about you from one source with the personal information we collect about you from another source, such as combining online information with our offline interactions with you (for example, our interactions by telephone or in person). We may also combine any of the information we collect about you with information we lawfully obtain from other sources, such as public records or websites, or other third parties (e.g., health care professionals, patient groups, government agencies). If necessary, we will collect your consent, or provide an opportunity for you to opt out of this type of processing.

Sensitive Personal Information

In the course of offering our Programs, and with your consent, where required, we may also collect and process personal information that is of a sensitive nature, including, for example the following categories of sensitive personal information:

• Username and password that you may select in connection with establishing an account on our websites
• Precise geolocation
• Disciplinary actions, criminal proceedings, etc.
• Identification information (identity card/passport number, Social Security or other taxpayer/government identification number such as driving license details)
• Financial information
• Race and ethnicity, sexual orientation and other protected information
• Information related to your health and medical condition(s); which may include genetic data or biometric information
• Medical treatments, medications, and test results
• Information about your insurance

We may use this information, as necessary, to:

• Facilitate recruitment and employee-related activities, such as background screening, payroll and benefits
• Provide and manage clinical research opportunities and other Programs
• Tailor marketing programs, administer retargeting messaging and profiling activities
• Process and manage safety and quality concerns
• Conduct other legitimate business activities, as allowed by applicable law

We will only process sensitive personal information when we have your express consent, or another legal basis.

Seres will also use your personal information when necessary to comply with applicable law, respond to legitimate requests from government authorities, including authorities that may be outside of your country of residence, to protect or defend our legal interests, and if necessary, to protect the safety of our employees and other stakeholders.

Communicating with You

We may contact you periodically by email, for example, if you have opted in to receive emails from us, to provide information regarding our Programs and provide you with content that may be of interest to you. You can opt out of receiving promotional communications by clicking on the “unsubscribe” button at the bottom of applicable email communications. In addition, some of the features on our website(s) allow you to contact us by phone or submitting an online form. We will respond to you via your requested channel, or that most appropriate to resolve your request, including phone, fax, email, etc.

Sharing Personal Information

We may disclose your personal information with:

• Subsidiaries and corporate affiliates
• Service providers working on our behalf, or providing services such as information technology, website hosting, payment processing, order fulfillment, customer service, etc.
• Third parties to whom you authorize us to disclose your personal information in connection with our Programs
• Authorized law enforcement, regulatory or other government authorities, where required by applicable law, or pursuant to a valid subpoena
• Business partners with whom we collaborate regarding our products and product candidates and programs, such as scientific advisors, joint venture partners and strategic collaboration partners
• Third parties to protect Seres’ rights and interests, such as when needed for corporate audits, to investigate or respond to a complaint or threat, or to exercise our legal rights
• External consultants for the evaluation of personnel, benchmarking reports on our industry in relation to compensation and benefits, management of litigation and legal aid, for the relevant relationship

When we share your personal information for a business purpose we enter a contract with these third parties that describes the purposes for sharing your personal information and requires the third-party recipient to protect the confidentiality and secure the personal information shared and prohibits use or disclosure of the personal information except for the purpose(s) performing the services under the contract, or as necessary to comply with applicable law.

Use of Cookies and Other Similar Technologies

We use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to collect and store analytics and other information when you use our website(s). The cookies we use include both first party and third-party cookies.

Cookies, or similar technologies, may provide us the following information:

• The type of web browser software you use
• The name of the domain from which you access the Internet (including client and server IP addresses, usernames, ports, queries, or other status-related information)
• The Internet address of the website from which you linked directly to our website(s)
• The date and time you access our website(s)
• Which pages you have visited on our website(s)

Cookies may be placed on your computer by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. These cookies can help us to share content from our social media sites, gain helpful insights about how our Programs are used and how we can improve your experiences and interactions during your use of our Programs.

In most cases we will not be able to identify you directly from the information we collect using these technologies. You can refer to our Cookie Notice for further detail as to the cookies we use and for what purposes. You can directly manage your cookie consent preferences and opt-out of sharing your data for marketing or analytical purposes through our Privacy Preference Center which can be accessed by clicking on “Your Privacy Rights” at the bottom of our website(s). If you disable cookies you may be unable to access or utilize certain parts of our website(s), or your experience may be altered.

Third-Party Websites and Services

As a courtesy to you, our website(s) may provide links to other websites not operated by Seres. This Privacy Notice does not address, and Seres is not responsible for the terms of use, information, or privacy practices of any third parties including third parties that may operate websites or provide services to which our website(s) or services link.

Exercising Your Rights

Seres is committed to respecting your choices about the use of your personal information, and we will take reasonable steps to respond to and honor your requests to exercise your rights to access, correct, delete or object to the use, disclosure or other processing of your personal information. If you wish to exercise these rights, please submit your request via this form. You can also contact us by sending an e-mail with your request to: dataprivacy@serestherapeutics.com, or call us, toll-free at: (888) 995-2283.

To protect your privacy and security, we may require you to provide us with information to verify your identity. We will respond to your request in accordance with applicable law, and if we are unable to comply with your request, we will provide you with an explanation.

These rights are not absolute and only apply in certain circumstances and may vary depending on your country, region or US state of residence. This means that we may be unable or not obligated to satisfy your request, for example, due to legal obligations or requirements to which Seres is subject.

Seres will not discriminate against you for exercising your rights, but we may not be able to provide you with Programs or services that you have requested if we are not able to use your information.

Safeguarding Your Personal Information

Although we cannot guarantee the security of activities, transmissions or communications conducted via the Internet, we have implemented reasonable physical, technical, and administrative security measures to protect personal information collected and used as described in this Privacy Notice.

Retaining Your Personal Information

We will retain your personal information for the time-period required or allowed by applicable law. Otherwise, we keep your personal information for as long as reasonably necessary to serve the purpose(s) for which it was collected.

International Transfers of Information

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. We will only transfer your personal information where we have established a legal basis, but you should not participate in our Programs if you do not want your personal information potentially transferred, or otherwise processed, in countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

If you are located in the EEA, your personal information may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures to protect your personal information, such as standard contractual clauses adopted by the European Commission.

Children’s Privacy

We care about protecting the online privacy of children. We will not intentionally collect any personal information from anyone under the age of 18. If you are under the age of 18, please do not send us any information about yourself. If you think that we have collected personal information from a child, or anyone under the age of 18, please contact us.

Changes to This Privacy Notice

Seres may update or make changes to this Privacy Notice from time to time, at our discretion. We encourage you to visit this page periodically and to review our most current Privacy Notice and applicable effective date.

Contacting Us

If you have questions or comments about this Privacy Notice, please contact dataprivacy@serestherapeutics.com or (888) 995-2283.