Privacy Policy

Voyager Privacy Policy

Effective Date: 12-28-2023

At Voyager Therapeutics (“Voyager,” “we,” “our,” “us”), we know that you care about your personal information and how it is used, and we want you to trust that we use your personal information carefully. This Privacy Policy (“Policy”) will help you understand what personal information we collect through our website from which you linked to this policy (“Site”), why we collect it, and what we do with it.

This Policy does not apply to information that we collect in our clinical trials. If you are a clinical trial participant, your information may be regulated by other legal requirements and documentation, including any consent forms that you may agree to as part of those trials. Please review the section titled “Clinical Trial Data” below for additional information.

Information We Collect and Maintain About You

Personal information (or data) means any information that can be used to identify directly or indirectly a specific individual. Voyager controls the personal information that it collects from you through its website.

Personal information you give us directly. We collect personal information from you when you contact us through the website or by email, for example when you inquire about our development of gene therapies and pipeline or apply for a job with us. The information we collect from you may include basic contact information such as your name, title, email address, street address, and telephone number, as well as your marketing preferences and any other information that you choose to provide to us.

Personal information collected from third parties. From time to time, we may collect personal information from other sources, such as public databases or data brokers and aggregators.

Personal information we collect automatically. We further automatically collect certain information about you and your computer or other device when you use, access, or interact with our website or marketing content.

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our website on a particular time and day.

Cookies. Cookies are small text files that a website’s server stores in your web browser. Cookies allow companies to recognize your device and store user preferences and other information. For additional information about how Voyager uses cookies and similar technologies, see our Terms of Use.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with other online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our website or opened a specific email.

Third-party plugins. Our website may include plugins from other companies, including social media companies (e.g., LinkedIn and Twitter). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking. We also may partner with certain third parties to use online tracking technology to conduct personalization and analytics on or through the website, or for online advertising. For example, we may allow third parties to set pixels on the website.

How We Use Your Personal Information

We use the information that we collect (described in “Information We Collect and Maintain About You,” above) for a variety of purposes. Our legal bases for processing your information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we use your information include to:

Manage and improve our business
Process, complete, and fulfill your requested transactions
Provide customer service and respond to requests or inquiries
Communicate with you
Provide you with newsletters, articles, alerts, announcements, invitations, and other information about our business, product pipeline, health topics, and disease states
Tailor our marketing programs and campaigns
Conduct analytics and research
Use interest-based advertising (as described below)
Consider your qualifications for employment (if you apply for a job with us)
Comply with legal and/or regulatory requirements
Aggregate and deidentify information

With Whom and Why We Share Your Personal Information

We may share any of the information described in “Information We Collect and Maintain About You,” above, with other parties for a variety of purposes, as described below. Please note that we do not sell your personal information.

Service providers. Voyager uses service providers that perform services on our behalf and help us run our business, including web-hosting companies, mailing vendors, advisors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.

Other third parties. We may share your personal information with other third parties when necessary to fulfill your requests for services or information, to complete a transaction that you initiate, to meet the terms of any agreement that you have with us, or to manage our business.

Analytics. We partner with Google Analytics to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs from your device. You can learn about how Google Analytics uses data when you access our website here, and can opt out of being tracked by Google Analytics across all websites here.

Interest-based advertising. The website enables third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our website to target online ads to you. In addition, our third-party advertising networks might use information about your use of our website to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Privacy Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or for companies participating in the Digital Advertising Alliance by downloading their WebChoices or AppChoices tools here.

If you use the website through your mobile device, you may also opt out of interest-based advertising by adjusting the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads).

Although our website currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary to:

Comply with applicable law or a court order, subpoena, or other legal process
Investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party
Establish, protect, or exercise our legal rights or defend against legal claims
Facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets

Aggregated, Anonymized, or Deidentified Information. We may also share aggregated, anonymized, or deidentified information about users of the website. Such aggregated, anonymized, or deidentified information will not identify you personally.

Your Choices

If you have any questions concerning Voyager’s privacy practices or wish to access, correct, or delete personal information that Voyager has collected from you, please contact us by email at: Privacy@vygr.com.

If you wish to opt out of marketing emails you receive from us, you may do so by following the instructions in those emails or by contacting us at Privacy@vygr.com.

If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:

The right to access your personal information (including a data portability request);
The right to correct or amend any personal information we have on file about you;
The right to delete your personal information;
The right to limit the use of your “sensitive” personal information;
The right to opt-out of the sale or “sharing” of your personal information;
The right to opt-out of the use of your personal information for targeted advertising purposes;
The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
The right to restrict or opt-out of the use of your personal information for certain automated decision-making (including profiling in furtherance of decisions that produce legal or similarly significant effects);
The right to revoke your consent (to the extent applicable);
The right to confirm whether personal information about you is being processed;
The right to obtain a list of specific third parties (or categories of third parties) to which we have disclosed your personal information or any personal information; and
The right to lodge a complaint to your local data protection authority.

To exercise any of the rights listed above, please contact us by email at Privacy@vygr.com. Additionally, you may exercise your privacy rights by clicking on .

We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. We will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to Privacy@vygr.com with the subject line “Appeal of Decision Related to Privacy Rights Request.”

Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you. We may need to request specific information from you to help us confirm your identity and facilitate your exercise of your privacy rights.

You will not have to pay a fee to exercise your privacy rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

California Residents

If you are a resident of the state of California, please review our California Privacy Addendum at the end of this Privacy Policy for additional rights that may be applicable to you.

EEA and UK Residents

Residents of the European Economic Area (the “EEA”) and United Kingdom (“UK”) may exercise rights described in the “Your Choices” section, above, as permitted by relevant laws, by contacting our data protection officer (“DPO”) using the contact information below, in addition to using the contact methods described in the “Your Choices” section.

Data Protection Officer (“DPO”): Dr. Phil Griffiths LLM
DPO E-mail Address: sar@thedpo.co.uk
DPO Postal Address: The DPO Ltd, 3rd Floor, Capital Tower, Cardiff, UK CF10 3AZ

Art. 27 Representative E-mail Address: datarep@art27rep.com

Art. 27 Representative Postal Address: The DPO (FAO: Dr. Sian Perrington), Suite CDV 47286, 350 Chemin du Pré Neuf 38350 La Mure, France

Clinical Trial Data

As noted above, this Policy does not apply to information that we collect in our clinical trials.

We undertake clinical studies and we will use information from subjects’ medical records and other health data in order to improve healthcare. As a pharmaceutical organization, we have a legitimate interest in using information relating to your health for research studies, when you agree to take part in a research study. The personal information that we collect through clinical studies is governed by the informed consent that you agree to when you agree to participate in the clinical study. Please note that your rights to access, change or move your personal information that we collect through clinical studies are limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the personal information about you that we have already obtained. To safeguard your rights, we will use the minimum personally identifiable information possible.

External Links

This Privacy Policy does not address, and Voyager is not responsible for, the terms of use, information, or privacy practices of any third-party website or service to which our website links. The inclusion of a link on the Voyager website does not imply our endorsement of the linked site or service.

Data Security

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.

Data Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will actively review the personal information we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business, or consumer need for it to be retained.

International Transfers

We are based in the United States, so we or our service providers may transfer personal information we collect in the EEA and the UK to the United States. In such cases, Voyager or its service providers will take, in accordance with applicable legislation, all organizational and technical measures reasonably necessary to ensure an adequate level of protection of your personal information. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.

Children

We do not knowingly collect personal information from children under the age of 13 through our Site. If a parent or guardian becomes aware that his or her child has provided us with personal information through the Site, he or she should contact us as described above. We will take reasonable steps to delete such data from our database within a reasonable time.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Please check this Privacy Policy periodically for changes. If we make any changes, the updated Privacy Policy will be posted with a revised effective date. If we make a material change to the Policy, you will be provided with appropriate notice.

How to Contact Us

Should you have any questions or concerns about this Policy, you can contact us at:

Voyager Therapeutics, Inc.
Attn: Privacy Committee
75 Hayden Avenue
Lexington, MA 02421 USA

Privacy@vygr.com

CALIFORNIA PRIVACY ADDENDUM

Date Last Updated: 12/28/2023

If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) provide you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to update or correct your information; the right to opt-out of the sale or sharing of your personal information; the right to limit our use of your sensitive personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also visit our Privacy Policy above for additional information and rights that may be available to you.

This California Privacy Addendum also serves as our “Notice at Collection” for purposes of the CCPA.

Please note that information that we collect in our clinical trials, as well as information we process pursuant to federal law, may be exempt from the scope of the CCPA.

Collection of Personal Information

If you use the Site, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may have collected the following categories of personal information about you over the past 12 months:

Identifiers, such as your name, email address, postal address, and IP address
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, and bank account information
Characteristics of protected classifications under California or federal law, such as your age and gender
Commercial information, such as your transaction history
Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses
Geolocation data
Professional or employment-related information.

Inferences drawn from any of the information identified above

We collect the personal information listed above from the sources listed in our Privacy Policy, in the section titled “Information We Collect and Maintain About You.” We collect this personal information for the purposes described in our Privacy Policy, in the section titled “How We Use Your Personal Information.”

Disclosure, Sharing, or Sale of Personal Information

In the last 12 months, with your permission, we may have disclosed or “shared” the following categories of personal information subject to the CCPA:

Identifiers, such as your name, email address, postal address, and IP address
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, and bank account information
Characteristics of protected classifications under California or federal law, such as your age and gender
Commercial information, such as your transaction history
Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses
Geolocation data
Professional or employment-related information
Education information
Inferences drawn from any of the information identified above

We may have disclosed or shared any of the information listed above with the entities described in our Privacy Policy for the purposes described in our Privacy Policy. Please review the section titled “With Whom and Why We Share Your Information” for additional information.

We do not sell your personal information.

Your Rights

If we maintain personal information about you that is subject to the CCPA, you may exercise certain rights in connection with this data if you are a California resident.

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you
The categories of sources for the personal information we collected about you
The categories of personal information that we have disclosed for a business or commercial purpose
Our business or commercial purposes for collecting, selling, or sharing personal information
The categories of third parties with whom we share or disclose that personal information
The specific pieces of personal information we collected about you (i.e., a data portability request)

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/vendors to delete) your personal information from our records, unless an exception applies.

Right to Correct

California residents have the right to correct or amend the personal information we have on file (“Right to Correct”). You may correct or amend by using any of the methods described in the “Exercising Your Rights” section, below.

Right to Opt-Out of Sale or Sharing

The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their personal information (“Right to Opt Out”). We do not sell or share your personal information. We also do not have actual knowledge that we sell or share the personal information of California residents under the age of 16.

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides California residents with the right to limit the use of their “sensitive personal information” to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations.

We do not use your sensitive personal information for any purposes outside of those permitted by § 7027(m).

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights

If you are a California resident and wish to exercise any of the above rights, you may submit a request to us by email at Privacy@vygr.com or by mail at:

Voyager Therapeutics, Inc.
Attn: Privacy Committee
75 Hayden Avenue
Lexington, MA 02421

When you submit a request, we may ask you for information in order to verify your identity in order to comply with your request.

Authorized Agent

Shine the Light Law

In addition to the CCPA, California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information for these purposes.

Contact for More Information

If you wish to contact us regarding this California Privacy Addendum, you may do so through the following methods:

By email at Privacy@vygr.com
By mail at:

Voyager Therapeutics, Inc.
Attn: Privacy Committee
75 Hayden Avenue
Lexington, MA 02421

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