Version 1.1 — Updated September 16th, 2025.
This privacy policy explains how personal data which are related to representatives of patient organizations, research foundations, support groups and other affiliated organizations (collectively referred to as “PO Representatives,” “you”, or “your” in this privacy policy) are processed by Axcela Bio AB (“Axcela Bio”). The PO Representatives may be employees, board members, advisors, volunteers, collaborators or similar. The information relating to PO Representatives is processed, analysed and included in software products and services (collectively referred to as the “Services”) to enable faster development and launch of new treatments, by helping our customers identify PO Representatives which are relevant to various important clinical and scientific research, key collaborations, industrial relationships, as well as to understand a PO Representative’s relevance to our customers’ initiatives. Axcela Bio offers its Services to companies and does not provide Services directly to consumers.
Axcela Bio has obtained a publishing certificate for its database, which has been issued by the Swedish Agency for the Media (Sw: Mediemydigheten). Consequently, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) does not apply to Axcela Bio’s publication of personally identifiable information of PO Representatives in the database. The GDPR allows countries to make exemptions to the GDPR’s rules on personal data processing if necessary to protect the freedom of expression (see Article 85 of the GDPR). The Swedish publishing certificate is such a legal exemption made from the GDPR.
More information about publishing certificates is available here: https://mediemyndigheten.se/ansokan-och-registrering/utgivningsbevis-och-databaser/.
Axcela Bio does not include any special categories of personal data (as defined in the GDPR) in the database.
For the purposes of this privacy policy, references to personal data includes any information relating to an identifiable, living, natural person.
We collect, use, store, and transfer different kinds of publicly available personal data about you. Such data may be obtained from you (if you contact us) or from third-party sources, e.g. third-party websites and publicly available databases. Such information may include, for example, your name, publicly available contact details (such as e-mail address), business address, city-level location, job title, LinkedIn, and other social media accounts as well as relationship to different patient organizations. We may also license certain data from third parties.
We use the personal data to provide our Services to our customers, which includes generating professional profiles of patient organizations and PO Representatives. These profiles are searchable by our customers. If you identify yourself to us, including by sending us an e-mail with questions or comments, we may use your information (including personal data) to respond to your questions or comments, and we may save your questions or comments for future reference.
We disclose personal data in the following contexts:
We may share your information (including personal data) with our customers and their registered users, who may be located throughout the world, through their use of our Services. Axcela Bio’s customers include those in the pharma and life science industries. Once any of our customers has accessed information through the Services, such customer shall be responsible for any obligations under applicable law arising out of such customer’s usage, sharing, or other processing of such information, including any notice or consent obligations under applicable law; this privacy policy does not apply to any such usage, sharing, or other processing by any of our customers or its registered users.
We may disclose your information (including personal data) if we believe in good faith that we are required to do so in order to comply with any applicable law.
We may employ third party independent contractors, vendors, and suppliers (collectively, “Service Providers”) to provide specific services and products, such as hosting and maintaining the Services, providing fraud screening, and developing applications for the Services. In the course of providing products or services to us, these third-party Service Providers may have access to information we collect about you. We will seek to minimize the personal data transferred to such Service Providers (to the extent possible), and will require Service Providers to follow appropriate privacy policies and will not authorize them to use your personal data except for the express purpose for which it is provided, but we cannot control the actions of such third parties.
If applicable, we reserve the right to transfer information to a third party in connection with a sale, merger, or other transfer of all or substantially all of the assets of Axcela Bio, or in case of bankruptcy.
We endeavour to retain your personal data only for as long as necessary to fulfil the purposes for which we collected it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We reserve the right to modify or revise this Privacy Policy from time to time. If we make material changes that result in significant additional uses or disclosures of your personal data, we may provide you notice through the Services and/or or by other means including if necessary, communication with you, to provide you the opportunity to review the changes before they become effective. We may also make minor changes to this privacy policy that generally will not significantly affect our use of your personal data, for which such communications/notices are not generally required. The date for the latest updated version of this privacy policy is specified at the top of this privacy policy. If any changes to this privacy policy are unacceptable to you, you should stop using our Services. Your continued use of the Services following the posting of changes to this privacy policy constitutes your full acceptance of those changes.
We are committed to protecting your privacy and to being transparent about our privacy practices. If you have any questions, comments, or want to provide feedback about this privacy policy, please contact us as follows
By e-mail: privacy@axcela.bio
By postal mail or courier:
Attn: Legal Counsel
Axcela Bio AB
Poppelgatan 9
SE-42674 Västra Frölunda
Sweden
This U.S. Supplemental Privacy Notice (the “Supplement”) provides supplemental information to the general privacy policy above and applies to residents of U.S. states with Comprehensive State Privacy Laws, as defined below. This Supplement describes the types of personal information that Axcela Bio may collect or process from U.S. residents in those states, how we may use and disclose that information, and how you may exercise any rights you may have regarding our processing of your personal information.
his Supplement applies to personal information collected or processed by Axcela Bio from or about U.S. residents in states with comprehensive privacy laws (collectively, hereafter, “Comprehensive State Privacy Laws”), including, for example, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”), together referred to as (“CCPA”); the Colorado Privacy Act (“CPA”); the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”); the Virginia Consumer Data Protection Act (“VCDPA”); and similar state privacy and data protection laws. This Supplement only applies to residents in those states with Comprehensive State Privacy Laws unless otherwise noted.
Personal information subject to this Supplement does not include the information covered by certain federal and state laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), clinical trials, or other exemptions as described in Comprehensive State Privacy Laws. In addition, even personal information covered in this Supplement may be collected and processed—including by disclosure to governmental entities or third parties—outside the requirements of this Supplement where applicable Comprehensive State Privacy Laws allow, including where such action is necessary to comply with federal, state, and local laws; to prepare for any law suit; to protect the vital interests of a consumer or other individual; to act in the public interest in areas of public health; to cooperate with government authorities; or to protect against security threats and illegal, fraudulent, or malicious activity and any subsequent investigation of that activity.
In the past 12 months we may have collected, processed the following categories of personal information in developing and providing the Axcela Bio Services:
| Category | Examples | Business or commercial purposes for which we collect, use, and sell consumer information |
|---|---|---|
| A. Identifiers. | Any identifiers that have been manifestly made public, including name, business address, publicly available contact details (such as email address), current or past employer, job title, department and seniority, company location, publishing affiliation, and/or associated institution(s), collaborations and collaborators, LinkedIn and other social media accounts, positions (including on advisory boards and boards of directors). We may also collect any information you share with us, such as if you contact us. | For the purposes of providing our Services and allowing Axcela Bio's customers and their users access to our Services. If you identify yourself to us, including by sending us an e-mail with questions or comments, we may use your information (including consumer information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. |
| B. Personal information categories listed in the California Customer. Records statute (Cal. Civ. Code § 1798.80(e)). | Any personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) that have been manifestly made public, including name, current or past employer, affiliation, and/or associated institution(s). | For the purposes of providing our Services and allowing Axcela Bio's customers and their users access to our Services. |
| C. Professional or employment-related information. | Any professional or employment-related information that has been manifestly made public, including current or past employer, affiliation, and/or associated institution(s), compensation, LinkedIn and social media account information, and positions (including on advisory boards and boards of directors). | For the purposes of providing our Services and allowing Axcela Bio's customers and their users access to our Services. |
| D. Inferences drawn from other personal information. | Profile reflecting your expertise (among other things), as well as your influence and relevance to our customers' initiatives. | For the purposes of providing our Services and allowing our customers and their Registered Users access to our Services. |
We collect and use personal information for the business or commercial purposes described in the table above and in the manner described in Section 1 of this Privacy Policy.
During the last year, Axcela Bio has disclosed personal information to service providers (e.g., cloud computing and storage vendors; security contractors, and consultants), for our own operational business purposes.
As a resident of a state with a Comprehensive State Privacy Law, you may have some of the following privacy rights, subject to some limitations or exemptions as required or allowed by law:
If you would like to opt-out of having your personal information provided to our customers (as applicable) or otherwise exercise your privacy rights, please send an e-mail to privacy@axcela.bio.
We will make reasonable efforts to promptly respond to your requests in accordance with applicable laws, but your rights under Comprehensive State Privacy Laws are not absolute. For example, any such request must provide sufficient information that allows us to verify that you are the consumer whose personal information we have collected. We may, after receiving your request, require additional information from you to honour your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Where required by applicable Comprehensive State Privacy Laws, we permit residents of certain states to designate an authorized agent to submit certain requests on your behalf, as outlined below.
California residents may designate an authorized agent to submit a request to opt-out of sale or share of personal information, to limit the use of Sensitive personal information, or to access, correct, or delete your personal information. In each case, the agent must provide us with documentation demonstrating that you have provided signed permission to the agent to exercise these rights with us on your behalf. We may deny the request if we do not receive such proof. In addition, for requests to access, correct, or delete your personal information, we may also require you to do either of the following: (1) verify your own identity directly with us; or (2) directly confirm with us that you have provided the authorized agent permission to submit the request on your behalf. These requirements of proof do not apply if the agent has a power of attorney pursuant to California Probate Code.
Colorado, Connecticut, Delaware, Nebraska, New Hampshire, New Jersey, Oregon, Minnesota, Montana, and Texas residents may designate an authorized agent to submit a request to opt-out out of our processing of personal data for the purposes of targeted advertising, sale or profiling in furtherance of decisions that produce legal or similarly significant effects. If you use an authorized agent to submit a request, we will not act on that request unless we are able to authenticate, with commercially reasonable effort, both your identity and the authorized agent’s authority to act on your behalf.
For all requests via authorized agents, we require that your agent provide us with your personal information and provide signed documentation demonstrating that you authorized the agent to submit a request on your behalf. The request must also include suicient detail that allows us to properly understand, evaluate, and respond to the request. If we need more information to process your request, we will contact you via e-mail or in writing.
Authorized agents may submit requests by sending an e-mail to privacy@axcela.bio.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with your state’s law pertaining to powers of attorney.
We are committed to protecting the privacy of Consumers’ personal information and being transparent about our privacy practices. To exercise any rights you might be entitled to under applicable Comprehensive State Privacy Laws, and for any other questions, comments, or feedback on this US Supplement or our privacy policy, please send an e-mail to privacy@axcela.bio.