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Privacy Policy

LAST REVISED: December 4, 2024 

Verve Therapeutics, Inc. (“Verve”) respects the privacy of visitors to its website. This Privacy Policy is provided to describe how Verve may collect, use, process, protect, and in some cases, disclose, your Personal Information (as defined below) that is submitted through our website. 

BY PROVIDING YOUR PERSONAL INFORMATION TO VERVE OR OTHERWISE USING OUR WEBSITE OR MOBILE APPLICATIONS, YOU ACKNOWLEDGE THAT YOU UNDERSTAND THE TERMS OF THIS PRIVACY POLICY AND WISH TO CONTINUE TO PROVIDE YOUR PERSONAL INFORMATION FOR THE PURPOSES DESCRIBED. 

For information on our website’s other Terms of Use, please see https://www.vervetx.com/terms-use. The provisions of this Privacy Policy apply only to Personal Information collected via the Verve website. This Privacy Policy does not replace any consent form or notice that you may separately receive in connection with Verve’s use or sharing of your information. 

The Verve website contains links to third-party websites and other online services and content that are not owned or controlled by Verve. This Privacy Policy does not apply to those third-party properties, and Verve is not responsible for the content of those properties or for how those properties treat your information. You should review the privacy policies and terms of use associated with those third-party properties if you decide to access them. However, we do receive information from certain third-party websites with whom we partner, and the terms of this Privacy Policy apply to this information once we receive it in the same manner as these terms apply to information that we collect through our website. For example, some of our clinical trial-related web pages are hosted by third-party vendors, such as Patient Engagement Advisors. 

For purposes of this Privacy Policy, “Personal Information” means any information relating to an individual that can be directly or indirectly used to identify that individual, including but not limited to, name, physical address, email address, phone number, identification numbers, health information, location data, online identifiers (such as an IP address), or one or more factors specific to the individual’s physical, physiological, genetic, mental, cultural, or social identity. Personal Information does not include anonymized information or information that is reported in the aggregate and cannot be traced back to an individual. 

Information We Collect 

We may collect Personal Information from our website users, job applicants, potential and current business partners, service provider employees, consultants, health care professionals, patients, potential and current clinical trial participants, clinical trial investigators, and others with whom we do business. We collect this information directly from individuals, from service providers, data brokers, business partners, government agencies, recruiters, social media, and through our website as outlined below. 

Personal Information You Provide 

We collect the Personal Information you give us—such as by signing up for our e-mail alerts, e-mailing us, applying for a job, submitting clinical trial recruitment-related forms, submitting investment inquiries, working as our business partner or as a consultant, and participating in clinical trials. 

Personal Information that we may collect from you may include: 

  • Identifiers and Contact Information: name, address, email addresses, phone numbers, account names and other unique personal identifiers, online identifiers, Social Security numbers, driver’s license numbers, passport numbers and other similar identifiers 
  • Biographical and Demographic Information: date of birth, gender, age, marital status, race, ethnicity, and information regarding parents or legal guardians 
  • Professional and Employment Information: job title, organizational affiliation, professional credentials, employment history, education history, resume/curriculum vitae, background checks, and other information provided to us directly from you, or from third-party employment websites, or public databases. 
  • Health and Medical Information: information pertaining to treatments and medication, insurance information, medical history, and lab results (provided in connection with clinical trials, patient support programs, adverse event reporting, and other research-related activities) 
  • Financial Information: tax classification and exemption status, bank account information, and other payment related information (in connection with submitting an investigator-sponsored research proposal, as a consultant or service provider, or an investigator in a clinical trial) 
  • Audio or Visual Information: audio or video recordings or photographs 
  • Commercial Information: services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies 
  • Inference Information: information used to create a profile about user to reflect the user’s preferences and characteristics 
  • Security and Access Information: usernames and passwords for accounts that you create on our website or mobile application 
  • Other information that you may provide through our website

 Information We Collect from Third Parties 

We may purchase or otherwise acquire information from third parties, including data brokers, third party service providers, and business partners. We may also collect information from public databases, government agencies, and social media. 

Information We Collect Automatically 

We automatically collect certain information, including Personal Information, about visitors to our website. We do this through the use of cookies, tags, and other similar web tools and tracking technologies. For more information about cookies, and the extent to which they can be declined, please see the “Cookie Policy” section, below. 

Information that we collect automatically may include: details about the devices that are used to access our website (such as the IP address and type of operating system and web browser), dates and times of visits to, and use of, our website, information about how our website is used (such as the content that is viewed on our website and how users navigate between pages),URLs that refer visitors to our website, and search terms used to reach our website. 

How We Use Information We Collect 

To the extent permitted by applicable law, we may use the information we collect, including Personal Information, for our business, development and research, and commercial purposes to: 

  • Communicate information to you about our products, programs (including clinical trials), and business 
  • Respond to your requests and inquiries, including requests related to our clinical trials Process grants and sponsorship applications 
  • Process employment applications 
  • Analyze and respond to product and safety concerns 
  • Recruit for, manage, and conduct our clinical trials and other product or investigational programs
  • Facilitate contact with you regarding clinical trials, including contact that may be initiated by our research partners or the clinical trial sites participating in our clinical trials 
  • Identify, facilitate, and manage business relationships, enter into contracts, and provide necessary payment or billing 
  • Collect publicly available information about your professional occupation, including licensing information and other information such as debarment and regulatory or disciplinary history (if you are a health care provider or other consultant under contract or being considered for a contractual relationship with us) 
  • Improve our website, related applications, and mobile applications 
  • Develop and customize the content we display and send you in our communications, website, related applications, and mobile applications 
  • Analyze communication strategies (such as your interactions with us, including on our website and mobile applications) 
  • Investigate and respond to misuse of our website, related applications, and mobile applications
  • Comply with applicable legal and regulatory requirements, judicial processes, and Verve policies 
  • As otherwise specified in other privacy policies or consent forms that may be provided to you depending on your relationship with Verve and what programs you may participate in 

We may combine any of the information we collect, including Personal Information, with information from other sources, such as public records or websites or offline interactions with you (for example, by telephone or in person). 

We may aggregate and/or de-identify the Personal Information we collect from you to create information that does not identify any individual, and use that information for the above-listed purposes and other business purposes. 

This Privacy Policy places no restriction on our use of non-personally identifiable information that we may collect from your visit to our website, such as questions, comments, ideas, or suggestions. By providing such information to us, you understand and agree that Verve has no obligation to you whatsoever regarding that information and is free to disclose it through any means and use it for any purpose and without compensation to you. 

How We Share Information We Collect 

We may share the information we collect, including Personal Information, with third parties for the purposes described above. These third parties include: 

  • Service providers of Verve, such as vendors, consultants, data storage and analytics providers, content providers, and technology providers (including technology support providers, web hosting providers, communications providers, and application developers) 
  • Other business partners with whom we collaborate regarding our investigational products and programs, such as scientific advisors, joint venture partners, research partners, and strategic collaboration partners 
  • Regulators worldwide, as required by law, including in connection with monitoring, review and approval of our clinical trials, products and services, and adverse event reporting 
  • Other third parties if required to comply with law, regulation, or judicial process or to protect the security, rights, and property of Verve or of users of our website 

Unless prohibited by applicable law, we may also share Personal Information as part of a purchase, transfer, joint venture, or sale of Verve or its assets, such as in a merger or corporate reorganization. If this occurs, the information will be subject to the policies of the receiving organization. 

How We Protect Information We Collect 

While Verve has endeavored to create a secure and reliable website for our users, the confidentiality of any communication or material, including any Personal Information contained within it, transmitted to or from Verve via the website or e-mail cannot be guaranteed. Verve maintains reasonable administrative, technical, and physical safeguards to protect your Personal Information once received. However, no system is completely secure or error-free, and third-party bad actors may still compromise these measures even if they are performed diligently and without error. Verve does not, and cannot, guarantee the complete security of your Personal Information. 

How Long We Keep Information We Collect 

We may keep the information we collect, including Personal Information, as long as necessary for the purpose for which it was collected and for as long as allowed or required by applicable law. 

Your Privacy Choices and Rights 

You may update your communication preferences and the Personal Information you provide to us at any time by following the instructions on the relevant page of our website or by contacting us as described in the “Contact Us” section of this Policy. 

If you have provided Personal Information to us through a third-party website, you should contact that website to update that Personal Information or your communication preferences related to that website. 

If you sign up to receive our e-mail alerts, you may unsubscribe at any time by following the instructions included in the e-mails. However, even if you unsubscribe, we may continue to send you other types of e-mail communications, such as about changes in our policies. 

For information about the choices and rights you have with respect to cookies, please see the section of this Privacy Policy titled “Cookie Policy”. 

Users who are located in certain jurisdictions may have additional choices and rights regarding their Personal Information and our processing of that Information. Please refer to the applicable section of the Policy for your jurisdiction. 

Information for California Residents 

California Residents, as defined under the California Consumer Privacy Act of 2018 (CCPA), may be able to exercise the following rights as to Personal Information. The rights below only apply to the extent your Personal Information is covered by the CCPA. Your rights may be limited when required or allowed by law. 

  • Right to know: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you: 
    • The categories of Personal Information we collected about you 
    • The specific pieces of Personal Information we collected about you 
    • The categories of sources of the Personal Information we collected about you 
    • Our business or commercial purpose for collecting your Personal Information 
    • The categories of third parties with whom we share that Personal Information, the categories of Personal Information we have sold about you (if any), and the categories of third parties to whom the information was sold 
  • Right to Request Deletion: You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions 
  • Right to Correct: You have the right to request a correction of inaccurate personal information that we maintain about you 
  • Right to Opt-Out of “Sale” of Personal Information: Verve does not “sell” Personal Information under the CCPA 
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights 

 

Sensitive Personal Information 

Some information that we may collect is considered to be more sensitive, such as social security numbers, geolocation, health information, or ethnic or racial origin. Verve only uses and discloses Sensitive Personal Information for the purposes described in this Privacy Policy or in accordance with any other notice that you have received or consent that you have provided. 

How to Exercise Your Rights 

To exercise your rights, please submit a request via email at privacy@vervetx.com. Only you, or someone legally authorized to act on your behalf, may make a submit a request. In order for us to comply with the request, you must provide us with enough information to identify you, such as your name and email address. You may designate an authorized agent to make a request on your behalf by drafting, signing, and notarizing a letter that makes clear (i) the identity of your agent and (ii) the purposes for which you are appointing the agent. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it. 

Collection of Personal Information 

In the last 12 months, we have collected identifiers and contact information, biographical and demographic information, professional and employment information, health and medical information, financial information, audio and visual information, commercial information, internet and geolocation information, inferences and other information consumers may provide us. For more information on the types of Personal Information we collect and the categories of sources we collect it from, please see the “Information We Collect” section of this Privacy Policy. We collect this information for the purposes described in the “How We Use Personal Information We Collect” section of this Privacy Policy. We share the categories of Personal Information with third parties for business purposes as described in the “How We Share Information We Collect” section of this Privacy Policy. 

Minors Under Age 16 

We do not sell or share the Personal Information of consumers we know are less than 16 years old. 

California’s “Shine the Light” Law 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We currently do not provide Personal Information to third parties for their direct marketing purposes. To opt-out of having your Personal Information disclosed to third parties for their direct marketing purposes in the future, please email us at privacy@vervetx.com with the subject line “California Shine the Light Request”. 

Information for Washington Residents 

If the processing of Personal Information about you is considered consumer health information subject to the Washington My Health My Data Act (“MHMDA”), you have certain additional rights with respect to that information. MHMDA protects consumer health data that is not protected under HIPAA. This section of the Privacy Policy applies to personal information defined as “consumer health data” subject to MHMDA. 

Consumer Health Data We Collect 

As described in the “Information We Collect” section of this Privacy Policy, the data we collect depends on how you interact with us, the services you use, and the choices you make. Because consumer health data is defined very broadly, many of the categories of data we collect are or could be considered consumer health data. Consumer health data can include: 

  • information about your health-related conditions, symptoms, status, diagnoses, testing (including tests, diagnostics, or other interventions), or treatments. We may collect such information through your navigation of our website, surveys or other communication with you. 
  • measurements of bodily functions, vital signs, or characteristics, including photographs, which may also be considered biometric information under the MHMDA. 
  • information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. 
  • other information that may be used to infer or derive data related to the above or other health information. 

Sources of Consumer Health Data 

As described further in the “Information We Collect” section of this Privacy Policy, we collect Personal Information (which may include consumer health data) directly from you, from your interactions with our services, from third parties, and from publicly available sources. 

Why We Collect and Use Consumer Health Data 

We collect and use consumer health data for the purposes described in the “How We Use Information We Collect” section of this Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the products or services you have requested or authorized. This may include delivering and operating the products or services and their features, personalization of certain product features, ensuring the secure and reliable operation of the services and the systems that support them, troubleshooting and improving the services, and other essential business operations that support the provision of the products (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development). We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law – for example, for advertising or marketing purposes. 

Our Sharing of Consumer Health Data 

We may share each of the categories of consumer health data described above for the purposes described in the “How We Share Information We Collect” section of this Privacy Policy. In particular, we may share Personal Information, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any products or services you have requested or authorized, as described in the previous section above. 

Third Parties With Which We Share Consumer Health Data 

As necessary for the purposes described above, we share consumer health data with the following categories of third parties: 

  • Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems may need access to data to provide those functions. 
  • Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets. 
  • Government agencies. We will disclose consumer health data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process. 
  • Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers. 
  • Other users and individuals. If you use our services to interact with other users of the service or other recipients of communications, such as a provider, we will share data, including consumer health data, as directed by you and your interactions. 

How to Exercise Your Rights 

MHMDA, if applicable, provides certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in this Privacy Policy. If your request to exercise a right under the MHMDA is denied, you may appeal that decision by contacting us as described in the “Contact Us” section of this Privacy Policy, or you may raise a concern or lodge a complaint with the Washington Attorney General at https://www.atg.wa.gov/file-complaint 

Information for Residents of the European Economic Area and the United Kingdom 

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), your Personal Information may be protected by data protection laws in the EEA or UK, such as the European Union General Data Protection Regulation (GDPR). Verve will comply with these data protection laws when it uses and shares your Personal Information as described in this Privacy Policy. 

When using or sharing your Personal Information as described in this Privacy Policy (including transfers out of the EEA and UK described below), Verve relies on the following lawful bases, as appropriate: 

  • Our legitimate interests, such as operating our business 
  • Performance of an employment or other contract with you or pre-contractual measures 
  • Compliance with our legal obligations 
  • With your consent, when applicable 

Verve is headquartered in the United States, and as a result, your Personal Information will be processed by Verve in the United States. Verve may contract with service providers to process your Personal Information on Verve’s behalf; these service providers may be located outside of the EEA and UK. Data protection laws in the United States or other countries may not offer you the same protections as the laws of the country in which you are residing when your Personal Information is collected. By using this Site and by submitting your Personal Information to Verve, you consent to the transfer of your Personal Information to any country and its use and disclosure in accordance with applicable U.S. federal and state laws and with this Privacy Policy. 

Data protection laws in the EEA and UK may provide you the following legal rights with respect to your Personal Information used and shared by Verve: 

  • To withdraw consent at any time, if we are using and sharing your Personal Information on the basis of consent 
  • To access the Personal Information that Verve maintains about you 
  • To request that Verve rectify errors or erase your Personal Information 
  • To request that Verve restrict the way it uses or shares your Personal Information 
  • To object to the way Verve uses or shares your Personal Information 
  • To ask Verve to transfer your Personal Information to someone else 
  • To lodge a complaint with a data protection authority in the EEA or UK 

Verve’s ability or obligation to comply with your requests may be limited by applicable law. To request to exercise one of these rights, please contact us as described in the “Contact Us” section of this Policy. 

Verve’s legal representative in the EU is MyData-Trust, which is located at Waldeck House, Lyne Lane, Chertsey, KT16 0AW, United Kingdom. They may be contacted through Verve at the mailing and email addresses below. 

Information for Residents of Australia and New Zealand 

If you are located in Australia or New Zealand, your Personal Information may be protected by data protection laws of those countries. Verve will comply with these data protection laws when it uses and shares your Personal Information as described in this Privacy Policy. 

If at any time you want to know exactly what Personal Information we hold about you, please contact us as set forth in the “Contact Us” section of this Policy. Our file of your Personal Information will be made available to you within a reasonable time after we receive your request. 

If at any time you wish to change any Personal Information we hold about you because it is inaccurate or out of date, please contact us as set forth in the “Contact Us” section of this Policy, and we will amend your record. 

Should you have any concerns or complaints about how we handle your Personal Information, please contact us as set forth in the “Contact Us” section of this Policy. We will investigate your complaint and will use reasonable endeavors to respond to you in writing within a reasonable time of receiving your complaint. If we fail to respond to your complaint within a reasonable time of receiving it in writing or if you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC) or the New Zealand Privacy Commissioner, as applicable. Details of how to contact the OAIC are located at: https://www.oaic.gov.au/about-us/contact-us or the New Zealand Commissioner at: https://www.privacy.org.nz/about-us/contactus/#:~:text=If%20you%20have%20a%20preferred,we%20can%20do%20to%20help. 

Verve’s Privacy Officer and Executive Director, Information Technology are the responsible data protection officers for Verve. Questions regarding this Policy can be submitted to Verve as described in the “Contact Us” section of this Policy. 

Information for Residents of Canada 

If you are located in Canada, your Personal Information may be protected by the data protection laws of Canada. Verve will comply with those applicable data protection laws when it uses and shares your Personal Information as described in this Privacy Policy. By using our website or otherwise interacting with us, you consent to the collection, use and disclosure of your Personal Information in accordance with the terms of and for the purposes set out in this Privacy Policy. Verve may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the Information for a new or different purpose, where consent has not already been obtained for such use or disclosure. 

If you submit Personal Information of others to us in connection with access to our website, you represent that you have obtained the requisite consent and/or provided appropriate notifications, as required under applicable privacy laws, including such consent and/or notifications as may be required for the transfer of personal information outside of Canada. 

You may have the right to access, update and correct inaccuracies on your Information or withdraw your consent to our further collection, use and disclosure of your Personal Information, subject to certain limited exceptions under applicable law. To exercise these rights, please contact us as set forth in the “Contact Us” section of this Policy. Please be as specific as possible in relation to the Information you wish to access. Once we receive your request, we will review it, verify your identity, and process the request accordingly. 

If you have any questions or complaints about our handling of your Personal Information or rights with respect to your Personal Information, please contact us as set forth in the “Contact Us” section of this Policy, and we will address your complaint, and otherwise further advise you of any rights you may have to complain to the relevant privacy commissioner(s). 

Cookie Policy 

Cookies are small amounts of data that your web browser stores on your device at the request of a website. Cookies are sent back to the originating web domain on your subsequent visits to that domain. Most websites contain elements from multiple web domains, so when you visit the website your browser may receive cookies from several sources. 

By using our website or any of our applications, you consent to the use of cookies. Web browsers may offer users of our website the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of the website may not work correctly. 

Cookies are useful because they allow our website to recognize the user’s device. Cookies also allow users to navigate between pages efficiently, recall preferences, and improve the user experience. For example, once you have completed the careers page registration process, a cookie may be used to avoid having you register again when you return to the page. Inquiries regarding our use of cookies may be directed to us at: privacy@vervetx.com. 

Verve is not responsible for the cookie practices of third-party websites, including those which may be linked to from our website. 

Cookies Used 

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Children’s Privacy

Our website is not directed toward children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13 through the website. We will delete information of children under the age of 13 if we learn any has been collected. 

Changes to this Privacy Policy

Verve may change this Privacy Policy from time to time, with changes effective as of the date indicated on the updated policy. You should check the website periodically for the latest updates to this Privacy Policy. 

Contact Us 

You may contact us with questions, comments, or complaints about this Privacy Policy or our privacy practices, or to exercise your rights regarding your Personal Information processed by us. When raising a request or complaint, please provide sufficient details (including your relationship with us) and any relevant documentation. Our contact information is as follows: 

Verve Therapeutics, Inc. 

Attn: Privacy Officer 

201 Brookline Avenue 

Boston, MA 02215 

Email: privacy@vervetx.com