Privacy Policy

We at Generate Biomedicines, Inc. (“Generate”) are committed to maintaining and protecting your privacy. This Privacy Notice describes how we collect, use, and disclose your personal information when you visit our SOLAIRIA Study websites that link to this Privacy Notice (the “SOLAIRIA Websites”) or participate in any SOLAIRIA Study pre-screening activities. Please read this Privacy Notice carefully.

If you are a current research participant in the SOLAIRIA Study, please review the Informed Consent Form for the SOLAIRIA Study for an explanation of our privacy practices and how we use your personal information during the clinical trial.

If you have any questions about this Privacy Notice or our data practices, please see our contact information below.

How We Collect Your Personal Information

We may collect personal information:

Directly from you. We may collect information you provide to us directly, such as when you send us a comment or question, complete a pre-screening questionnaire, or when you request information through the SOLAIRIA Websites.
Through Automated Tracking Technologies. We collect personal information through cookies and other automated tracking technologies when you interact with the SOLAIRIA Websites. This may include information about how you use and interact with the SOLAIRIA Websites, including information about your device and internet usage information. We may combine personal information that we receive from various sources.

What Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information from or about you:

Identifiers, such as your name, email address, and your Internet Protocol (“IP”) address.
Internet and other electronic activity information, such as your Internet Protocol (IP) address, information about your device (like your operating system, browser type, and language), referring URLs (i.e., websites you navigate to our website from), access times, pages viewed, links clicked, use of our website’s interactive features, and other information about your interactions with the SOLAIRIA Websites.
Geolocation information, such as the non-precise location information we derive from your IP address.
Sensitive information, such as your health and medical history and other sensitive information you may include in a SOLAIRIA Study pre-screening questionnaire. Note that this information is generally collected on our behalf by entities with whom we contract to coordinate our research studies and recruit research participants (our “Research Vendors”).
Any other information you choose to provide us, such as information within communications to us.

How We Use Your Personal Information

We may use the personal information that we collect and maintain for the following purposes:

To provide services. We may use your personal information to provide services, such as responding to your requests, and communicating with you.
For internal business purposes. We may use your personal information to maintain and operate the SOLAIRIA Websites, including to understand how the SOLAIRIA Websites are used.
To determine your eligibility to participate in our studies. If you complete a pre-screening questionnaire, our Research Vendors will evaluate your personal information to determine whether you would be a good candidate for our research studies.
For legal, safety, or security reasons. We may use your personal information to detect, investigate, and prevent risk, fraudulent events, and other illegal activities, to manage legal claims, subpoenas, and requests in connection with investigations and dispute-resolution processes, as permitted or required by applicable law, and to protect the rights and property of Generate and others.
In connection with a corporate transaction. We may use your personal information if we acquire assets of another business or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.

We may also anonymize, de-identify, or aggregate your personal information to use for any purpose permitted by law.

How We Disclose Your Personal Information

We may disclose your personal information to the following parties, as follows:

Service providers. We may disclose your personal information to third parties that provide services to us, such as our Research Vendors, web hosting, data storage, business support, marketing, and other IT services providers. It is our policy to require our service providers to keep the information confidential and to not use the information outside of our business relationship.
Auditors and advisors. We may disclose your personal information to auditors for the performance of audit functions and with advisors to receive legal and other advice.
Our business partners. We may disclose your personal information to parties with whom we work or conduct research if, for example, we need to refer you to someone outside of Generate to answer your question.
Mergers, acquisitions, and bankruptcy. If Generate ever files for bankruptcy or merges with another company, or if Generate decides to buy, sell, or reorganize some part or all its business, Generate may disclose your personal information to parties involved in the transaction. It is Generate’s practice to seek appropriate protection for personal information disclosed in these types of transactions.
As required by law and other legal-related disclosures. We may disclose your personal information if we believe in good faith that disclosure is necessary: (a) to comply with the law, such as to report possible adverse events or to respond to legal process (e.g., court order, subpoena, search warrant) or other legal requirements of any governmental authority; (b) to protect the integrity of the SOLAIRIA Websites and our services; (c) to protect and defend our, your, or others’ rights, property, safety or interests; or (d) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the SOLAIRIA Websites and our services.

Cookies and Similar Technologies

We may collect information on the SOLAIRIA Websites by automated means such as through cookies, web beacons, log files, local storage and similar technology (collectively, “cookies”). We use these technologies to load the SOLAIRIA Websites, uniquely identify visitors, and store information or settings in/retrieve such information from the user’s browser/device. The categories of cookies we use generally fall into one of the following categories:

Necessary: We use first party cookies that are essential for the operation of our websites and enable their functionality, such as certain security, multimedia and load balancing features.
Statistics and Performance: These cookies allow us to count visits and traffic sources, and understand how you interact with the SOLAIRIA Websites, so we can measure and improve their performance. If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor its performance. We may use Google Analytics or comparable platforms in limited geographies to gather traffic information to allow us to improve our websites and apps and support their functionality. To prevent Google from receiving your user activity on websites and apps, see https://tools.google.com/dlpage/gaoptout.

Non-essential cookies can be declined. If you do not want us to collect any information through tracking technologies, you can set your web browser to reject certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. If you reject or block cookies from the SOLAIRIA Websites, the website may not function as intended.

Some browsers transmit “do-not-track” signals to websites. The SOLAIRIA Websites do not take steps to honour these“do-not-track” signals.

Retention of Your Personal Information

As a general matter, we may keep your personal information for as long as necessary to fulfill the purposes for which it was collected, such as for the period we carry out specific research and a reasonable period thereafter. If a law requires us to retain your personal information for a longer period of time, we will comply with that law. We may also retain your personal information as necessary to protect or resolve dispute, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Security of Your Personal Information

We maintain reasonable physical, technical, and administrative measures designed to protect your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. While we strive to protect your personal information from unauthorized access, use, or disclosure, Generate cannot and does not ensure or warrant the security of your information.

Links to Other Sites

The SOLAIRIA Websites contain links to third party websites or services that are not under our control. If you visit another website, we encourage you to review that website’s privacy policy to understand how that website operator will treat your information. Our Privacy Notice does not apply to those other websites, and nothing identified in those website’s privacy policies shall amend, modify, or supplement in any way this Privacy Notice.

Children’s Information

The SOLAIRIA Websites are intended for general audiences and are not directed to minors. We do not knowingly collect information from children under the age of 18 in connection with our website or other online services.

Updates to Privacy Notice

We reserve the right to update this Privacy Notice from time to time. In certain cases, we will attempt to notify you of updates prior to them taking effect. You are encouraged to review this Privacy Notice regularly to stay informed about our personal information practices and the choices available to you.

Contact Us

For general questions about our privacy practices, please contact us at:

Generate:Biomedicines
101 South Street, Suite 900 Somerville, MA 02143
United States info@generatebiomedicines.com

Please note that Adverse Events should not be reported to the above contact information.

Notice to California Residents

This section supplements the information and disclosures contained above. It applies only to California residents about whom we collect personal information as a business under the California Consumer Privacy Act (“CCPA”). Below describes our practices with respect to personal information over the past 12 months:

Generate has collected the categories of personal information listed in “What Personal Information We Collect” above. The purposes for which Generate has collected personal information and the sources of that information are respectively described in “How We Collect Your Information” and “How We Use Your Personal Information” above.
Generate has disclosed personal information for a business purpose to the categories of third parties listed in the “How We Disclose Your Personal Information” section above.
Generate has not “shared” your personal information for the purposes of targeted advertising or “sold” personal information. We do not knowingly sell the personal information of minors under the age of 16.

California residents also have the following privacy rights under the CCPA, which are subject to certain legal exceptions and exemptions:

Right to know and access: You have the right to access and obtain a copy of the personal information we have collected about you.
Right to correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
Right to delete: You have the right to request that we delete the personal information that we have collected about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
Right to opt out of sale/sharing: You have the right to opt out of the sale or sharing of your information. We do not currently sell or share your personal information.
Right to nondiscrimination: You have the right to not be discriminated against for exercising these rights.

To exercise your CCPA rights, contact us at info@generatebiomedicines.com or (888) 547-1235. 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 you are the individual about whom we collected personal information. We may request additional information about you to verify your identity. We will only use the personal information 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 be able to use an authorized agent to submit a rights request on your behalf. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, 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.

Additional Notice for Non-U.S. Visitors

Depending on where you live, (such as the European Economic Area (“EEA”) or United Kingdom (“UK”), the following disclosures may apply to you and supplement the remainder of this Privacy Notice.

Data Controller. Generate is the entity responsible for the processing of your personal information as the controller. In some cases, we may make decisions on how your personal information is processed, together with other entities. In these situations, we are jointly responsible for the lawfulness of the specific processing activities as joint controllers and will notify you as necessary.

Legal Bases for Processing. We process personal information for the purposes identified above, based on the following legal bases:

Purpose of use	Personal information processed	Legal bases
Provide our services	Identifiers	Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. Our legitimate interests in responding to your questions and providing the SOLAIRIA Websites and related information. Your consent, when appropriate.
Internal business purposes	All categories.	Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. Compliance with a legal or statutory obligation to which we are subject. Our legitimate interest in operating our business.
Determine your eligibility to participate in our studies	Identifiers, sensitive information, and other information you may provide to us	Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. Compliance with a legal or statutory obligation to which we are subject. Our legitimate interest in identifying and enrolling research participants. Your consent, when appropriate.
Research, development, and improvement of our services	All categories.	Our legitimate interest in improving our services and SOLAIRIA Websites. Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. Compliance with a legal or statutory obligation to which we are subject. Your consent, when appropriate.
Legal, safety, or security reasons	All categories.	Compliance with a legal or statutory obligation to which we are subject. Our legitimate interests in complying with our legal obligations, enforcing our policies, and protecting rights, property, and safety of our company and others. Establishment, exercise or defence of legal claims. Protection of vital interests. Your consent, when appropriate.
Ensure compliance with contractual obligations	All categories.	Our legitimate interest in ensuring compliance with the contractual terms you entered into with us, including investigating and enforcing those terms if necessary.
In connection with a corporate transaction	All categories.	The legitimate interest we and other participating entities have in completing corporate transactions. Your consent, when appropriate.

Your Data Protection Rights. Subject to applicable data protection laws, you may have the following rights concerning your personal information:

Right to Access. You have the right to obtain confirmation from us whether we are processing your personal information and related information, as well as the right to obtain a copy of your personal information undergoing processing.
Right to Data Portability. You may receive your personal information that you have provided to us in a structured, commonly used and machine-readable format.
Right to Rectification. You have the right to request the rectification of inaccurate personal information and to have incomplete data completed.
Right to Objection. You have the right to object to the processing of your personal information in certain cases, including regarding direct marketing.
Right to Restrict Processing. You may request that we restrict the processing of your personal information in certain cases.
Right to Erasure. You may request that we erase your personal information in certain cases.
Right to Lodge a Complaint. You have the right to lodge a complaint with
a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.
Right to Refuse or Withdraw Consent. In case we ask for your consent to process your personal information, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The lawfulness of any processing of your personal information that occurred prior to the withdrawal of your consent will not be affected.
Right to Not Be Subject to Automated Decision-making. You have the right to not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.

You may exercise these rights by contacting us as specified below. Data protection officer. You can contact our data protection officer at Generatebiomedicines.dpo@mydata-trust.info and/or using contact details specified below.

EU/UK representative. Generate has designated MyData-TRUST as its representative in the EU. You can contact the relevant EU representative at Generatebiomedicines.dpr.eu@mydata-trust.info. Generate has designated MyData-TRUST as its representative in the UK. You can contact the relevant UK representative at Generatebiomedicines.dpr.uk@mydata-trust.info.

International Transfers of your Personal Information

We are based in the United States. We may transfer your information to our business partners and service providers that are located in countries other than where you live. By using the SOLAIRIA Websites or otherwise providing personal information to us, you understand that your personal information will be processed in the U.S. and the countries where our services providers are located. These countries may protect your personal information differently (including less) than where you are located. Where applicable, we will ensure that any recipient country of personal information from the EU, UK, or Switzerland is either recognized by the EU/UK/Switzerland authorities as having an equivalent level of data protection, or we will make sure that your personal information is adequately protected by using appropriate safeguards, like EU Standard Contractual Clauses.

In some cases, the transfer may be based on derogations provided by the EU GDPR/UK GDPR/FADP because the transfer is necessary for important reasons of public interest. Other derogations also exceptionally apply.