Privacy Policy
This “Privacy Policy” (“Policy”) describes the privacy practices of LogicBio Therapeutics, Inc. and our subsidiaries and affiliates (collectively, “LogicBio”, “we”, “us”, or “our”) and in particular how we collect, use, disclose and otherwise process personal information in connection with the websites that we own or control and which post or link to this Policy (collectively, the “Websites”), our products and services, and our online and offline activities and communications. This Policy also explains the rights and choices available to individuals (“you, “your”) with respect to their personal information in order to assist them in making informed decisions when using our website or otherwise interacting with us.
This Policy does not replace any consent form or other privacy notice that may separately be provided in connection with LogicBio’s use or sharing of personal information. LogicBio may provide additional privacy notices to individuals at the time we collect their data to highlight any specific conditions of data processing practices. For example, we provide a specific privacy notice to job applicants or clinical trial participants that describe our privacy practices in connection with recruitment or conducting clinical trials accordingly. This type of an “in-time” notice will govern how we may process the information you provide at that time for a specific purpose.
Individuals are recommended to read carefully this Policy before disclosing any personal information and/or filling in any electronic form posted on this website. By visiting our Websites or by providing us your personal information, you acknowledge that you have read and understood the terms of the collection, use and disclosure of your personal information as outlined in this Policy along with our Cookies Policy.
Table of Contents
Personal Information We Collect
Whose Personal Information We Collect
How We Collect Personal Information
How We Use Personal Information
Why we Process Personal Information
How We Share Personal Information
Your Choices regarding your Personal Information
Cookies and other technologies
Job Applicants
Children’s Privacy
Automated Decision Making
International Data Transfer
Security and Retention
Other Sites and Services
California Privacy Rights
Individuals in the European Economic Area, Switzerland and the UK
Changes to this Privacy Policy
Contact Us
Personal Information We Collect
The personal information we collect depend on the nature of the relationship you have with LogicBio and the requirements of applicable laws. We may collect the following categories of personal information about you including but not limited to:
- Health and medical information (such as information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with managing clinical trials, and conducting research in terms of our business activities
- Contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information)
- Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians)
- Professional or employment/education -related information of job applicants, such as educational and professional history, professional qualifications and credentials, work experience and institutional affiliations and other information of the type that may be included in a resume
- Payment-related information we need to pay for professional services, such as consulting, that individuals may provide to us (such as tax identification number and financial account information)
- Engagement data, such as information about the programs and activities in which you have participated
- Digital identifiers, such as your photograph, your public social media accounts or digital or electronic signature
- Publicly available information, including information posted on or collected from our social media channels (such as comments describing support for and experience with LogicBio products)
- Correspondence and other information you provide to us (such as in emails, on phone calls, in market research surveys, or in other correspondence with LogicBio or our service providers or business partners)
- Information collected automatically, using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, including:
- Device data that is collected automatically (such as IP Address, your device’s operating system, your Internet service provider and location, browser type and language, your unique device ID (persistent/non-persistent), and the website you visited before browsing to our Websites)
- Online activity data that is collected automatically (such as information about the website content you access and information about the date, time and duration of your visit)
This information may be collected by us, or by third parties acting as our service providers, over time and across third-party websites to the extent necessary and as permitted under applicable legislation.
Whose Personal Information We Collect
We collect personal information about the following types of individuals: employees, clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, users of our Websites, persons with whom we do business such as suppliers, contractors and consultants and other individuals who interact directly with LogicBio or our service providers or business partners.
How We Collect Personal Information
In most cases, we collect personal information directly from individuals (e.g., when you contact us via our website, when you submit as a job application or sign up for our newsletters). Although, sometimes we will obtain data about you from public or third-party data sources, including but not limited to:
- Your employer when we need to process personal information of our service providers’ personnel
- healthcare professionals
- contract research organizations and clinical trial investigators
- government agencies or public records
- third party service providers, data brokers or business partners
- industry and patient groups and associations
- social media or other public forums
- your computer or any other devices you use when visiting our website such as internet protocol (IP), domain name, internet service provider (ISP), data about date and time of your request and other information provided by tracking technologies (e.g., data collected from cookies and similar technologies as described in our Cookies Policy.
When you are asked to provide personal information, you may decline. But if you choose not to provide information that is necessary for us to provide the requested services or to perform our contractual relationship, we may not be able to provide you those services or comply with any contractual obligations.
How We Use Personal Information
To operate and improve our Websites, including to:
- Operate, maintain, administer and improve the Websites
- Better understand your needs and interests, and personalize your experience with the Websites
- Provide support and maintenance for our Websites
To communicate with you, including to:
- Provide you with patient education information, media or other materials
- Send you copies of our press releases or other information
- Send you surveys or other marketing communications
- Respond to your requests, questions and feedback in relation to our services; applications or studies
If you do not wish to receive unsolicited email messages from us, please contact us at privacy@logicbio.com.
To perform and administer clinical trials, research and product-improvement activities, when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including to:
- Staff and manage clinical trials, including by recruiting investigators and participants
- Track and respond to safety and product quality concerns
- Support public health initiatives, symposia, conferences, and scientific, educational and volunteer events
- Define and manage appropriate patient engagement activities, including travel assistance where available
- Identify and engage thought leaders and external experts
- Award scholarships, donations, and grants
- Attribute authorship to academic and promotional materials
- Provide disease-state education
To manage our business and provide our services, including to:
- Administer our business and services, including to carry out our obligations arising from any agreements entered into between you/your employer and us (e.g. handling billing and invoicing)
- Assess the individual suitability for job openings
- Manage access to our services
- Pay for services that physicians, researchers and other individuals may provide to us
To comply with law, as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety, where we may use personal information and disclose it, to the extent permitted, to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Websites, products and services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To comply with regulatory monitoring and reporting obligations, as we believe necessary or appropriate, such as those related to adverse events, product complaints, patient safety, and financial disclosures.
Why we process Personal Information
LogicBio processes personal information based on one or more of the following conditions:
Consent: If LogicBio relies on consent for the processing of personal information, we will provide transparent notice of the purposes for which we seek such consent prior to the time we collect your personal information. Where LogicBio relies on consent, you will be entitled to withdraw that consent at any time. If LogicBio wishes to process any special categories of personal information, such as health data, LogicBio will obtain your explicit consent for such processing.
Contractual Necessity: LogicBio processes personal information to fulfill our contracts with our business partners and service providers, such as for rendering payment or communicating with health care professionals or consultants.
Legal Obligation: LogicBio processes personal information as specifically required by applicable legal obligations, such as laws and regulations that require LogicBio to process personal information for purposes of obtaining medical research approvals and spend transparency disclosures.
Public Interest: LogicBio processes personal information for scientific or historical research purposes, or statistical purposes in the public interest, as authorized by applicable law. If LogicBio wishes to process any special categories of personal information, it may do so when necessary for scientific research purposes, medical diagnosis, or the protection of vital interests.
Legitimate Interests: LogicBio processes personal information subject to its own legitimate interests, such as to develop, administer and support research; to operate, evaluate and improve our business; to facilitate and manage patient advocacy and engagement programs; to promote scholarly research; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition. It may be also necessary for LogicBio to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the Terms of Use that govern the services we provide.
Compatible purposes: LogicBio may also process personal information for purposes that are compatible with those described above. Such purposes may include scientific research.
How We Share Personal Information
We may share personal information to the extent necessary and as permitted under applicable laws with:
Affiliates. We may share personal information with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may employ third party companies and individuals to perform services on our behalf, including:
- Contract research organizations that conduct clinical trials
- Data storage and analytics
- Customer service (including our medical information line)
- Technology services and support (including email and web hosting providers, email and text communications providers, mobile app developers)
- Event planning and travel organizations that help facilitate LogicBio programs
- Payment, shipping and fulfilment service providers
These service providers may have access to personal information in connection with performing services on our behalf and may use your information only as directed by LogicBio and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
Business partners and other professionals and organizations. We may disclose personal information to partners with whom we jointly develop products or services, in connection with the development and promotion of such products or services. We will ask for your consent before disclosing your information with our business partners where required by applicable law. We may also share personal information with health care professionals, researchers, academics, public health organizations, and publishers for purposes consistent with this Privacy Policy.
Professional advisors. We may disclose personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Your Choices regarding your Personal Information
You may have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to specific privacy related rights, including the right to:
· Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is disclosed, and with whom your
personal information was shared;
· Access a copy of the personal information we retain about you;
· Request deletion or transfer of your personal information;
· Correct or amend your personal information; and
· Object to certain uses of your personal information.
To exercise any of the above-mentioned rights you may contact us at: privacy@logicbio.com.
Withdrawal of consent. Where LogicBio relies on consent for the fair and lawful processing of personal information, the opportunity to consent will be provided prior to when the personal information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney. Where LogicBio relies on consent, you will be entitled to withdraw that consent at any time.
Marketing communications. If we intend to use your data for marketing purposes or if we intend to disclose your data to any third party for such purposes, we will, where required, ask for your consent. In the case of direct advertising of our services through electronic communications (e.g. email), we will take all steps required by applicable law, to offer you a method by which you can consent to the receipt of further advertising material. You may opt out of marketing-related emails by clicking the “Unsubscribe” link at the bottom of each such email, or by sending an email with the subject line “Unsubscribe” to privacy@logicbio.com. You may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Testimonials. If you gave us consent to post a testimonial on our Websites and/or or social media pages, but wish to update or delete it, please contact us at privacy@logicbio.com.
Choosing not to share personal information. Where we are required by law to collect personal information, or where we need personal information in order to provide you with our products or services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our products or services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means. We reserve the right to not to remove or amend information provided to us regarding an adverse drug event or any information that we are otherwise required to retain by law or regulation.
Cookies and other technologies
This website may collect information that could be potentially personally identifiable about your visits without you actively submitting such information. Unidentified information may be collected using various technologies, such as cookies. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit our Cookies Policy.
Cookie Policy
Cookies are small amounts of data that your web browser stores on your device at the request of certain websites. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains, so when you visit the website your browser may receive cookies from several sources.
By using the Site, you consent to the use of cookies. Web browsers may offer users of the Site the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of the Site may not work correctly.
Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences, and generally improve the user experience.
You can learn more about the cookies that the Site uses and manage your cookie preferences here:
Please note that LogicBio is not responsible for the cookie practices of third-party websites which may be linked to on this Site.
Job Applicants
When you visit the careers portion of our Websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to operate and improve our Websites, to communicate with you, and as otherwise necessary to comply with law or for compliance, fraud prevention, and safety purposes.
Children’s Privacy
Our Websites are not directed to, and we do not intend to or knowingly collect personal information from anyone under the age of 13 on our Websites. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information as soon as possible. We encourage parents with concerns to contact us at privacy@logicbio.com.
Automated Decision Making
LogicBio does not undertake through its website or in general decisions based solely on automated processing, including profiling, of an individual unless we inform you otherwise.
International Data Transfers
LogicBio is headquartered in the United States and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. In all situations, LogicBio takes reasonable steps to ensure that your privacy is protected. Such steps include, but are not limited to, implementing privacy, security, and contractual controls, as well as steps noted in this Privacy Policy, as required by applicable law.
LogicBio endeavors to obtain assurances from its service providers and affiliates that they will safeguard personal information consistent with this Policy. An example of appropriate assurances that may be provided by service providers and affiliates includes a contractual obligation that they provide at least the same level of protection as is required by privacy principles followed by LogicBio and set out in this Policy. Where LogicBio has knowledge that a service provider or affiliate is using or disclosing personal information in a manner contrary to this Policy, LogicBio will take appropriate steps to prevent or stop the use or disclosure.
Security and Data Retention
We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All information you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. LogicBio has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal information protected from unauthorised access, disclosure, alteration, and destruction.
We will retain your personal information for the time strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Data may be retained for a longer duration where applicable laws or regulations require, or allow LogicBio to do so. When your data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed; however, any personal information which you have provided to us for receiving LogicBio information, newsletters and event invitations will be kept until you notify us that you no longer wish to receive this information.
We may provide links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
California Privacy Rights
Notice to California Residents
If you are a California resident, this section supplements the information above regarding the collection, use, and disclosure of personal information that is covered by the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA gives California residents the right to know what personal information covered by the CCPA is collected about them, how it will be used and to whom it is disclosed as well as the right to request: (1) access to such personal information, (2) deletion of such personal information, and (3) that such personal information not be sold to the extent applicable under the CCPA.
The purpose of this notice is to describe our practices regarding the collection, use, disclosure, and sale of personal information covered by the CCPA and instructions for submitting CCPA data privacy requests. Some of the personal information that we collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws that apply to us.
The personal information we may collect from you will depend on the nature of our interaction with you. For further details as to the sources of personal information collected, see the “How We Collect Personal Information” section of this Policy. We collect this information for the purposes described in the “Why We process Personal Information” and “Cookies and other technologies” sections of this Policy. We disclose personal information as described in the “How We Share Personal Information” section of this Policy.
California Civil Code permits individual California residents to request certain information regarding LogicBio’s disclosure of personal information to third parties for the third parties’ direct marketing purposes. LogicBio does not provide your personal information to third parties for their use in direct marketing.
LogicBio does not sell personal information about California residents.
Your Rights
The CCPA provides you (as a California resident) with specific rights, subject to certain exceptions:
- Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.
- Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
- Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.
If you are a California resident and would like to exercise any of the above rights, please submit your request by post at LogicBio Therapeutics, Inc. 65 Hayden Ave, Lexington, MA 02421 or by email at privacy@logicbio.com. To process your request to exercise your Right to Know and Right to Deletion, we must be able to verify your identity to a reasonable degree of certainty. To verify your identity, we will ask you to provide your contact information and relevant identifiers based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.
You may designate an authorized agent to make a request to exercise your Right to Know or Right to Deletion on your behalf. When you use an authorized agent to submit such a request, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us.
If we are unable to comply with all or a portion of your data privacy request, we will explain the reasons for declining to comply with the request.
Individuals in the European Economic Area, Switzerland and the UK
If you are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), personal information about you may be protected by data protection laws in the EEA, Switzerland or UK, such as the European Union General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection and the UK Data Protection Act 2018 as amended and in force. LogicBio will comply with these data protection laws when it processes personal information about you as described in this Policy.
Transfers of your personal information may be made to entities located outside the European Economic Area, including entities located in the United States, for processing consistent with the purposes above. LogicBio will implement appropriate contractual measures to ensure that the relevant third parties outside the European Economic Area provide an adequate level of protection to your personal information as set out in this Privacy Policy and as required by applicable law.
For the processing of personal information relating to the European Economic Area, LogicBio has assigned a data protection officer responsible for overseeing our compliance with EU data protection law, whom you may contact at privacy@logicbio.com in case of any questions or concerns regarding the processing of your personal information.
If LogicBio’s processing of your personal information is covered by EU law you may also lodge a complaint with the corresponding data protection supervisory authority in your country of residence. You can find the relevant supervisory authority name and contact details here.
Changes to this Privacy Policy
We continually improving and adding new functionality and features to the Websites. Because of these ongoing improvements, changes in the law and the changing nature of technology, LogicBio’s data practices may change from time to time. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Websites. Any modifications to this Privacy Policy will be effective as of the “Effective Date” listed at the bottom of the Privacy Policy. Your continued use of the Websites, our products and services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Contact Us
Please direct any questions or comments about this Privacy Policy or privacy practices to privacy@logicbio.com. You may also write to us via postal mail at:
LogicBio Therapeutics, Inc.
65 Hayden Ave.
Lexington, MA 02421
For purposes of European data protection laws, LogicBio Therapeutics Inc. is the data controller: i.e., the company responsible for controlling the processing of personal information covered by this Privacy Policy. LogicBio’s Data Protection Officer can be reached at privacy@logicbio.com.
Effective Date as of May 11, 2021