Privacy Policy

Effective May 21, 2020

Wave Life Sciences Ltd. and its affiliated companies (collectively, “Wave,” “we,” “us,” and “our”) are committed to respecting your privacy. This Privacy Policy explains how Wave collects and uses information from and about you as part of our business activities, including information we collect online through our websites, by email, and through other digital services and products we operate and that link to this Privacy Policy (collectively, “Wave Sites” or “Sites”), and offline, such as through trade shows and conferences, by telephone, and through other offline means.

This Privacy Policy describes the information we collect and how we collect it, how we use and share it, and the rights and choices you have in relation to your information.

Wave may also collect or receive information through special programs, such as clinical trials, that are subject to program-specific privacy notices and/or consent forms that we provide when you participate in those programs. Those notices and/or consent forms explain how any information we collect or receive through those programs will be handled. In those cases, the program-specific privacy notice and/or consent form will govern how we process the information we collect, instead of this Privacy Policy.

Contents

The Information We Collect and How We Collect It

The types of personal information that Wave collects, including through the Wave Sites and offline, depends on the nature of our relationship with you and the context of your interaction with us. This Section describes the personal information we collect and how we collect it. For purposes of this Privacy Policy, “personal information” means information that identifies you or that could reasonably be used to identify you.

Information You Provide

Wave collects personal information when you voluntarily provide it to us, such as when you submit it through the Wave Sites, email us, communicate with us by phone, or interact with us in person, such as at trade shows, conferences, and investor events. The types of personal information we collect through these methods include:

  • contact information such as your name, address, phone number, and email address;
  • information about your employment such as your employer, title, and business contact information;
  • professional credentials, educational and professional history, institutional and government affiliations, certificates and licenses, background checks, other information included on your resume or curriculum vitae, information about your race and gender that we collect for compliance with government regulations and record-keeping guidelines, your veteran and disability status, and candidate account credentials (including email address and password) that we collect when you inquire about or apply for a job with us;
  • health or medical information (such as information about medical conditions, diagnoses, and treatments, genetic information, and family medical history) that you may share with us when we recruit for research, provide patient support and advocacy programs, distribute and market our products, manage expanded access programs, and track adverse event reports;
  • information about your preferences regarding communications from Wave; and
  • any other information or content that you provide to us when you contact us by email or by phone, complete forms on the Wave Sites, or interact with us in person.
Information We Receive from Third-Party Sources

We may also receive personal information of the types listed above from third-party sources, including your company, government agencies, public records, our service providers and business partners, industry and patient groups and associations, social media or other public forums, and recruiters.

We may combine the information we receive from third-party sources with information that you provide and/or that we collect automatically when you use the Wave Sites.

Information We Collect Automatically through the Wave Sites

We collect certain information automatically when you visit and use the Wave Sites. This information may include the following:

  • the Internet Protocol (“IP”) address of your computer, which may reveal your approximate location;
  • information that can be used to recognize your device, including information such as your browser type and version;
  • the dates and times of your visits to our Sites, the pages you visit, and other information about your interactions with our Sites;
  • URLs that refer visitors to our Sites;
  • search terms used to reach our Sites; and
  • if you use a mobile device to access and use the Sites, mobile-specific information in including: device or advertising ID, device type, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your mobile operating system, the platform used to access or Wave Site (e.g., Apple, Google, Windows), and approximate location information.

We may collect some of this information through tracking technologies such as cookies and web beacons. For more information please see the How We Use Cookies and Other Tracking Technologies section of this Privacy Policy.

How We Use Your Information

Wave uses the information we collect for the following purposes:

  • to respond to your inquiries and otherwise communicate with you about our products and services;
  • to provide and deliver resources you request, such as webinars, presentations, and publications;
  • to offer and provide information, including marketing information, invitations to participate in surveys, or notifications about special programs or promotions regarding our products and services and similar or related products and services;
  • to improve, develop, and evaluate our products, services, materials, and programs, and for other related internal business purposes;
  • to administer our business, the Sites, and our services consistent with our Terms of Use and applicable laws, rules, regulations and our other legal obligations;
  • to develop and execute investor relationship management activities, including the delivery of investor presentations and informational materials;
  • to administer and analyze questionnaires, surveys and market research;
  • to staff, facilitate, conduct, and manage clinical trials;
  • to track and respond to safety and product quality concerns (including product recalls);
  • to comply with regulatory monitoring and reporting obligations;
  • to facilitate and arrange travel and other logistics for trade shows, conferences, and scientific and other events;
  • to monitor user traffic patterns and preferences on the Wave Sites for site improvement, analytics and optimization;
  • to make the Wave Sites easier to use and to navigate, and to personalize the content provided on Wave Sites by anticipating the information and services that may be of interest to you;
  • to comply with legal or regulatory requirements, judicial process, and our company policies (including due diligence and contracting activities);
  • to secure the Wave Sites and protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of the Wave Sites), and claims and other liabilities, including by enforcing our Terms of Use;
  • to manage, facilitate, and improve our recruitment activities, including by processing employment applications, evaluating job candidates, and monitoring and analyzing recruitment and hiring statistics;
  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding; and
  • any other purpose that you may authorize or direct at the time we collect you personal information.

How We Share Your Information

To accomplish the purposes set out above, we may share your personal information with third parties. We do not sell or rent personal information to third parties for their own marketing purposes. The third parties with whom we may share your personal information include:

  • our affiliated companies;
  • service providers that perform services on our behalf;
  • regulatory authorities, including in connection with monitoring, review and approval of our studies, products and services, and adverse event reporting;
  • business partners with whom we jointly develop products or services;
  • physicians, health care providers, and other health care professionals;
  • researchers, academics, and public health organizations;
  • other third parties as necessary to (a) protect or defend our interests and the legal rights or property; (b) protect the rights, interest and safety and security of the Sites, our organization, or members of the public; (c) protect against fraud, and (d) investigate and prosecute users who engage in behavior that is illegal or harmful to others or to others’ property;
  • a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding; and
  • with such other parties, or for such other purposes, as you may authorize or direct at the time we collect the information.

How We Use Cookies and Other Tracking Technologies

We may also collect information about your use of Wave Sites through tracking technologies such as cookies and web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” is a transparent graphic image placed on a Web site, e-mail or advertisement that enables the monitoring of things such as user activity and site traffic. To learn more about cookies and other tracking technologies, including how to disable them, you can visit http://www.allaboutcookies.org/.

We and third-parties with whom we work use cookies and web beacons on the Wave Sites to improve user experience, to help remember your preferences and allow us to bring you the content and features that are likely to be of interest to you, including on the basis of “clickstream” data that shows your previous activities on Wave Sites, and to analyze the use of our Sites and to improve Site functionality.

One of the ways we do this is through the use of Google Analytics. For more information about how Google Analytics uses and processes data, please visit https://www.google.com/policies/privacy/partners/.  In addition to the standard Google Analytics implementation, the Wave Sites may use additional Google Analytics features, including but not limited to Demographics and Interest Reporting, which may collect non-identifiable demographic information, including your age and gender, and your interests. We do not connect identifiable information with non-identifiable information collected through these means.  You may opt out of the collection of this information by visiting: https://tools.google.com/dlpage/gaoptout/.

We and our third-party service providers and business partners may use cookies and web beacons to collect information about your online activities over time and across our Sites and third-party websites or online services third-party websites.

Minors

Wave does not knowingly collect or use any personal information directly from children on Wave Sites (Wave defines “children” as minors younger than 18). We do not knowingly collect information from children through the Wave Sites. If you are a parent and believe that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address the issue.

Your Choices

We provide you with certain choices regarding your personal information. For example, you can choose not to give us the personal information we request, as described in the “Information You Provide” section of this Privacy Policy. However, in some cases, if you decide not to provide the personal information we request, we will not be able to provide the service or information you requested.

Other examples of your choices include:

  • You can browse our website without registering or directly submitting any personal information to us. We may collect some limited information automatically, as described above.
  • You can unsubscribe from receiving marketing or other commercial emails by sending an email to [email protected] or by following the instructions included in the marketing emails you receive from us. Please note that even if you opt out of receiving such communications, we may still send you non-marketing communications (such as product safety information).
  • You may change your browser settings or take other steps to block, manage, or delete cookies. Our Sites do not currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause our websites and applications not to work as intended and some features may not be available.

International Data Transfers

The Sites are operated from the United States, and therefore if you are visiting the Sites from a country other than the United States, your interactions with the Sites and with us will necessarily result in the transfer of information across international borders. In addition, information we collect in other contexts may be shared with our affiliates and other third parties that are located in other countries in accordance with this Privacy Policy.

The level of legal protection for Personal Information is not the same in all countries, and the laws in other countries may not provide the same level of protection for personal information as those in your country. By using this Sites and providing your information to us, you understand and agree that your Personal Information will be stored and processed in the United States and in any country to which we may transfer your information in the course of our business operations.

Data Security

Wave maintains information security safeguards that are reasonably designed to protect your Personal Information from unauthorized access, use, and alteration. Please note however that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the security of your personal information. PLEASE DO NOT SEND SENSITIVE HEALTH OTHER SIMILAR INFORMATION TO US VIA THE Wave SITES.

Links to Third-Party Websites

Wave Sites may contain links to other third-party websites. These websites are not subject to this Privacy Policy. These websites are not controlled by Wave and Wave is not responsible for their content or their privacy policies, which may differ from ours. We have not reviewed and make no representations about the accuracy of information on third-party websites, or about their information handling practices. Visits you make to these websites are at your own risk, and we encourage you to review their privacy policies.

Additional Information for Individuals Located in the European Economic Area and the United Kingdom

This section of the Privacy Policy applies to residents of the European Economic Area (EEA) and the United Kingdom whose personal data is covered by the General Data Protection Regulation (GDPR) or the UK Data Protection Act.

Responsible Data Controller and Local Representative

For information collected through the Wave Sites, Wave Life Sciences USA, Inc. is the data controller with respect to your personal information. In other cases, the affiliate with whom you interact will be the data controller, either on its own or jointly with Wave Life Sciences, Ltd. A list of our affiliates and their contact information appears below.

Legal Bases for Processing

The legal basis that we rely on under GDPR and the UK Data Protection Act to use your personal information will depend on the specific purpose for which Wave is processing your personal information. Those legal bases are described below.

  • Our Legitimate Interests. In some cases, Wave relies on its legitimate interests to process your personal information, consistent with your rights and appropriate to the context, including as necessary to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage clinical trials and other 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. We may also process your personal information as necessary to protect against criminal offenses, and to maintain a safe workplace for staff.
  • Consent. In some cases, Wave may ask for your consent to collect and use your personal information. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “How to Contact Us” section below. If you have consented to a particular purpose for our use of your personal information, then we may rely on your consent until you withdraw it. Please note that the withdrawal of consent will not affect processing that has already occurred, and may affect our ability to provide products, services or communications to you that are subject to the relevant consent.
  • Performance of a Contract. In some instances, the use of your personal information may be necessary in order to perform a contract to which you are subject. You may not be able to opt-out of this use, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
  • Compliance with a Legal Obligation and Protection of Individuals. We may process personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
Your Rights and Choices

Individuals located in the EEA and the UK have certain rights, which may only apply in certain circumstances and are subject to certain exemptions.

  • You have the right to see and get a copy of personal information about you that Wave holds, subject to certain exemptions.
  • You have the right as to ask us to make corrections to inaccurate or incomplete personal information about you.
  • You may have the right to receive data you have provided to us in a machine-readable format and to transmit that data to another controller in certain circumstances.
  • You may also request the erasure of your personal information or the restriction of its processing, or object to the processing of personal information about you in certain circumstances and with certain exceptions.
  • You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
  • You have the right to complain to the relevant Data Protection Authority (an independent public authority unique to each EU country) where you think we have not used your personal information in accordance with data protection law.

You may exercise these rights free of charge unless the request is unfounded or excessive, for instance because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by applicable law. Before Wave is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request.

To exercise your rights, please contact us using the information provided in the How to Contact Us section of this Privacy Policy.

Data Retention

We may retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to adhere to our policies, and for any period as legally required or permitted by applicable law.

Transfers to Third Countries

We may transfer personal information collected in the EEA or the UK to other countries that the European Commission has determined ensure an adequate level of protection for personal information, as well as to countries that have not been deemed to provide an adequate level of protection for personal information.  When a country to which we transfer personal information has not been deemed to provide an adequate level of protection, these transfers may be based on standard contractual clauses approved by the European Commission, the EU-US Privacy Shield, Binding Corporate Rules, or your consent, or may proceed as otherwise permitted by applicable EEA requirements, for example where the transfer is necessary for important reasons of public interest (such as adverse event reporting). For more information about these transfers please contact us through the How to Contact Us section below.

How to Contact Us

To contact us with questions or concerns about this Privacy Policy, or to exercise any rights you may have under applicable law, please contact our Privacy Office by emailing us at [email protected]. You may also send a letter to the following address:

Wave Life Sciences USA, Inc.
Attn: Privacy Office
733 Concord Ave.
Cambridge, MA 02138
USA

Wave is committed to resolving your privacy concerns and any complaints. In all communications to Wave, please include your email address, and provide the web site address, mobile application, and/or other context in which we collected your personal information, along with a detailed explanation of your request. We may need to further confirm your identity in order to process certain requests.

Wave Entities Covered by this Privacy Policy

This Privacy Policy covers the following Wave entities:

  • Wave Life Sciences, Ltd., located at 7 Straits View #12-00, Marina One East Tower, Singapore
  • Wave Life Sciences USA, Inc., located at 733 Concord Ave., Cambridge, MA 02138, USA.
  • Wave Life Sciences Japan, Inc., located at 2438 Miyanoura-cho Kagoshima-shi Kagoshima pref. 891-1394, Japan
  • Wave Life Sciences Ireland Limited, located at 1 Spencer Dock, North Wall Quay Dublin 1, Ireland
  • Wave Life Sciences UK Limited, located at 1 Chamberlain Square CS, Birmingham, B3 3AX United Kingdom

Changes to this Privacy Policy

We reserve the right to change the terms of this Privacy Policy at any time. Any changes to this Privacy Policy will be reflected on this page with a new effective date. We will continue to use and/or disclose information in accordance with the policy in effect at the time the data was collected. Wave encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Wave Sites after we post changes is deemed to be acceptance to those changes.