Privacy Policy

Last Updated: November 21, 2023

Welcome to the website of Vesigen, Inc. (“Vesigen”, “we”, “us” and/or “our”). Vesigen is a company that specializes in developing therapeutic products directed to intracellular targets using a scalable and extracellular vesicle delivery technology. Our website (“Site”) allows you to easily access and use content, including resources and other information intended to help you learn about Vesigen’s research and information for investors.

This Privacy Policy explains what personal data we collect from you when you use our Site, how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms of Website https://www.vesigen.com/terms-of-use/. By providing us with your Personal Data when engaging with the Site, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Site.

INFORMATION WE COLLECT AND HOW WE USE IT:

SITE USERS
Information We Collect: When you participate engage with the Site, we collect information that, alone or in combination with other information, could be used to identify you.

Personal Data You Provide Us. We collect Personal Data that visitors to the Site send to us electronically, for example when completing any “free text” boxes in our forms (such as on our “Get in Touch” or “Contact Us” page, which requests your name, email, message subject, and message text), requesting information or subscribing to emailing lists.

Automatically Collected Data. When you use or interact with the Site, the following information is created and automatically logged in our systems:

  • Log Data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your IP address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies: Our Site uses cookies to operate and administer our Site and make it easier for you to use the Site during future visits and gather usage data on our Site. A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use our Site after having been notified of our use of cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use. Some cookies expire after a certain amount of time, or upon logging out (session cookies); others remain on your computer or terminal device for a longer period (persistent cookies). Our Site uses first party cookies (cookies set directly by Vesigen) as well as third party cookies.
  • Device Information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
  • Usage Information: Information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.
  • Analytics Data: We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/. To help us understand how you use our Site and to help us improve it, we automatically receive information about your interactions with our Site.

How We Use Site Personal Data:
As necessary for certain legitimate business interests, which include the following:

  • To authenticate users and provide access to the Site;
  • To respond to your inquiries and fulfill your requests for products, services, and information;
  • To provide, maintain and improve the content and functionality of the Site. For example, we regularly fix bugs or user experience issues that may be tied to particular user accounts. We use cookies to analyze how users interact with our Site, and that analysis can help us build a better Site;
  • If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing;
  • To prevent fraud or criminal activity, misuse of our products or services, and ensure the security of our IT systems, architecture and networks; and
  • To (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our Terms of Use; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law.

SHARING AND DISCLOSURE OF INFORMATION
We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account or when you voluntarily share information or content via the Services.

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, unless required by the law, as set forth below:

  • Vendors, Service Providers, and Research Partners: Providers of administrative services such as email communication (including appointment reminders, investment information you request through the Site) and Site support services; to assist us in meeting business operations needs and to perform certain services and functions; and analytics (for more details on the third parties that place cookies through the Site, please see the “Cookies” section below). For example, we use Google Analytics to understand how our Site is used. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of the Site or the App, or the public, or (d) protect against legal liability.
  • Consent: We may also disclose your information with your permission.

DATA RETENTION
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for regulatory reporting including to government entities who may oversee the safety and efficacy of Research, legal, tax, accounting or other purposes), whichever is the longer.

UPDATE YOUR INFORMATION
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us. We will address your request as required by applicable law. You may also request that we update your Personal Data by contacting us at info@vesigentx.com.

Do Not Track Signals: The Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

CHANGES TO THE PRIVACY POLICY
The Site, our Research, and our business may change from time to time. As a result, we may change this Privacy Policy at any time and when we do we will post an updated version on this page and change the Last Updated date above, unless another type of notice is required by the applicable law. You should consult this Privacy Policy regularly for any changes. By continuing to use the Site, or providing us with information after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

INTERNATIONAL USERS
Vesigen is based in the United States. If you are accessing our Site from or in the European Union or other regions with laws governing data collection and use, please note that your Personal Data will be transmitted to our servers in the United States as necessary to provide you with the information that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected.

CONTACT US
Please feel free to contact us if you have any questions about Vesigen’s Privacy Policy or the information practices of the Services.

You may contact us as follows: You may send an email to info@vesigentx.com or send mail to:

Vesigen, Inc.
Attention: Chief Operating Officer
790 Memorial Drive Suite 103
Cambridge, MA 02139