Privacy Statement

Updated: April 15, 2023

At Q32 Bio, we understand that you care about your personal privacy and the security of your personal data, and we take your privacy and data protection rights seriously. The below resources describe our policies and practices regarding how we collect and use your personal data. We recognize that this is an ongoing responsibility, so from time to time, we will update the below statements as we undertake new personal practices or adopt new privacy policies.

The purpose of this Privacy Statement is to explain the types of information we gather from people visiting the Q32 Bio website (the “Website”) and how we use, transfer, and secure their personal data. This Privacy Statement is incorporated into and is part of our Terms of Use available at https://www.q32bio.com/terms-of-use/. If you are accessing the Website, you agree to be bound by this Privacy Statement. If you do not agree to the terms of this Privacy Statement, then please do not use the Website.

We do not knowingly attempt to solicit or receive information from children, and our Website is not intended for use by anyone younger than the age of 18. If you believe someone under the age of 18 has provided Personal Information to us outside of the clinical trial context, please contact us at privacy@q32bio.com so we can take reasonable steps to investigate and delete their Personal Information.

1. WHO WE ARE

As used in this Privacy Statement, “Q32 Bio,” “we,” “us,” and “our” refer to Q32 Bio, Inc. and our subsidiaries, joint ventures, and other companies under a common control (“Affiliates”), and “you” or “users” refer to people who visit the Website.

Please refer to the “Contact Us” section below for a list of entities acting as data controllers and legal representatives for Q32 Bio.

2. DATA PROTECTION OFFICER

Q32 is headquartered in Massachusetts in the United States. Q32 Bio has appointed an internal data protection officer for you to contact if you have any questions or concerns about Q32 Bio’s personal data policies or practices. If you would like to update or delete your Personal Information, exercise the rights described in this Privacy Statement, or have any questions or concerns, please direct your inquiry as follows:

By Mail:	By Email:	By Phone:
Q32 Bio, Inc. Data Protection Officer 830 Winter Street, 2nd Floor Waltham, Massachusetts 02451 USA	privacy@q32bio.com	+1 781 999 0232

3. TYPES OF INFORMATION COLLECTED

If you visit the website or contact us by email or phone, we may collect the following types of information about you:

Personal Information (also called Personal Data), which may include information that can directly identify you, such as your name, mailing address, email address, telephone number, or information that could be used indirectly to identify you, such as an IP address, preferences, age, gender, occupation, etc.
Aggregate Information, which is information that cannot be used to identify an individual (such as frequency of visits to the Website and browser type).

4. HOW DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

Generally, our collection of Personal Information is limited to contact information, such as first and last name, job title, employer/company name, personal or work address, personal or work email, personal or work telephone number.

If you contact us via email, such as to seek information or assistance or if you send an email to our Media Contact or Business Development/Partnering Contact, we may also collect the contents of your email. We will use your Personal Information to provide support, operate and improve the Website, offer more relevant information and content, and respond to your inquiries, comments, and questions.
If you apply for a job with Q32 Bio through the Careers section of the Website, you will be asked to provide Personal Information, including but not limited to your name, email address, phone number, date of birth, SSN/government identification number, bank information, and other identifiers. We will use your Personal Information to process your job application and contact you about potential employment opportunities.

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share some or all of your Personal Information:

With our Affiliates, in which case we will require our Affiliates to honor this Privacy Statement.
With vendors or service providers we have engaged to help us with our business activities, such as Website maintenance and employee recruitment, in which case we will include language in our contracts with them to make sure they: (i) use your Personal Information only as necessary to provide services to us; and (ii) establish safeguards to protect the confidentiality of your information.
In connection with, during negotiation of, or as a result of any merger, financing, acquisition or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Statement. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.
If we believe in good faith that sharing your Personal Information is necessary (i) in connection with a legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on us; (iii) to protect or defend the rights or property of Q32 Bio or users of the Website; (iv) to investigate or assist in preventing any violation or potential violation of the law or this Privacy Statement; or (v) to comply with our obligations in contracts.

6. HOW DO WE COLLECT AND USE AGGREGATE INFORMATION?

Aggregate Information may be collected when you visit or use the Website, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction.

7. CALIFORNIA USERS

In accordance with the California Consumer Privacy Act (“CCPA”), this Privacy Statement provides you with required information regarding the Personal Information we collect from you and the purposes for doing so. Please see the above information for details about the Personal Information we collect, use, and share. In addition, under the CCPA, California residents have certain rights regarding their Personal Information, including the following:

Right to Know

You have the right to request the following information from Q32 Bio:

The categories of Personal Information we have collected about you.
The categories of sources from which the Personal Information was collected.
The business purpose for collecting the Personal Information.
The categories of third parties with whom we shared the Personal Information.
The specific pieces of Personal Information we collected about you.

Right to Request Deletion

Upon a verifiable request, made through one of the methods provided within the “Contact Us” section below, we will delete your Personal Information from our records and direct our service providers to do the same, to the extent required by the CCPA. Please note that Q32 Bio may be required or permitted by law to not remove (or allow removal of) your Personal Information.

Right to Be Free from Discrimination

Q32 Bio will not discriminate against you for exercising any of your rights under the CCPA.

Information We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is to make sure your Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We will respond to all legitimate requests within forty-five (45) days, or as permitted by the CCPA.

CCPA Contact Information

If you are a California resident and would like to exercise the rights described above, please contact us using the information in the “Contact Us” section below.

No Sale of Personal Information

Q32 Bio does not sell the Personal Information collected through the Website.

8. NEVADA USERS

Q32 Bio does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact us using the information in the “Contact Us” section below.

9. EUROPEAN USERS

If you are located within the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, this Privacy Statement provides you with required information regarding the Personal Data we collect from you and the purposes for doing so, along with additional required information regarding how to contact us and exercise your privacy rights under applicable laws.

Data Controller

The data controller is the entity responsible for determining how and why your personal data are processed. The controller of your personal data is Q32 Bio, Inc., located at 830 Winter Street, 2nd Floor, Waltham, MA 02451 USA. Please see the “Contact Us” section for additional contact details.

Purposes of Processing

The purposes of the processing are described Sections 4 and 5 of this Privacy Statement.

Lawful Basis for Processing

Generally, we process personal data on the basis that the processing is necessary for purposes of our legitimate interest in conducting our business in a manner typical in the US pharmaceutical industry, having taken into account any risks to your fundamental rights and freedoms (including your right to privacy). We also may process personal data on other bases permitted by applicable laws, such as when the processing is necessary for us to comply with our legal obligations.

Legitimate Interests

Our specific legitimate interests, such as improving the Website, providing you with support, processing and responding to any employment application, and responding to or managing business matters are described in Sections 4 and 5 of this Privacy Statement.

Categories of Personal Data

The categories of personal data that we process are described in Sections 3 and 4 of this Privacy Statement.

Recipients of Personal Data

The potential recipients of the personal data that we collect via the Website are described in Section 5 of this Privacy Statement.

Transfers of Personal Data Outside the EEA, UK, and Switzerland

Q32 Bio, Inc. is headquartered in the USA and the Website is hosted in the USA. When you contact us by email or use the Website, you are providing your personal data directly to the USA.

At this time, the laws of the USA have not been deemed by the European Commission to provide an adequate level of protection to personal data. When you email us, the fact that you have chosen to email us knowing that we are located in the USA will be understood to constitute your express consent to the transfer of the personal data in your email (including your email address) to the USA. Personal data submitted through the Careers portion of the Website is transferred to Greenhouse Software, Inc., a Q32 Bio service provider, on the basis of your consent.

Regardless of the differences in privacy laws of the United States versus those of EEA, UK, and Switzerland, Q32 Bio will safeguard your personal data as described in this Privacy Statement. If we transfer your personal data to a third party, we require the third party to commit contractually to process your personal data only in ways that are consistent with this Privacy Statement.

Retention Period

We delete personal data within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.

Your Personal Data Rights

You have the right to request access to your personal data, to have your personal data corrected, restricted, or deleted, and to object to our processing of your personal data. Your rights may be subject to various limitations under applicable laws. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us in any of the ways listed in the section “Contact Us.” Data portability rights are not relevant to the kinds of processing that we do.

Right to File a Complaint

You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

No Requirement or Obligation to Provide Personal Data

Users of the Website not under any statutory or contractual requirement or other obligation to provide personal data to Q32 Bio.

Data Protection Representative for European Economic Area

VeraSafe has been appointed as Q32 Bio’s representative in the European Union for data protection matters, pursuant to Article 27 of the EU General Data Protection Regulation. If you are in EU or EEA, VeraSafe can be contacted in addition to privacy@q32bio.com only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe as follows:

By Web:	By Phone:	By Mail:
Visit verisafe.com	+420 228 881 031	VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P

Data Protection Representative for United Kingdom

VeraSafe has been appointed as Q32 Bio’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the UK General Data Protection Regulation. If you are located within the UK, VeraSafe can be contacted in addition to or instead of privacy@q32bio.com only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe as follows:

By Web:	By Phone:	By Mail:
Visit verisafe.com	+44 (20) 4532 2003	VeraSafe Ireland Ltd. 37 Albert Embankment London SE1 7TL United Kingdom

This Privacy Statement only applies to personal data collected via the Website or via an inquiry to one of the email addresses listed on the Website. If you provide personal data to us through some other means, such as in connection with a clinical study sponsored by Q32 Bio, you will be provided with a separate notice about the collection, use, and transfer of your personal data. In that case, if you have any concerns about our processing of your personal data, please refer to the separate notice, which will contain important information and a designated contact person to address your questions or concerns. However, you may still reach us using the “Contact Us” section of this Privacy Statement.

10. SECURITY

Q32 Bio is committed to protecting the security of your Personal Information. We use and require third parties working with us to use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while Q32 Bio uses reasonable efforts to protect your Personal Information, Q32 Bio cannot guarantee its absolute security.

11. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

All users may review, update, correct, or delete their Personal Information by contacting us as described in the “Contact Us” section of this Privacy Statement, where the right to do so is provided by applicable law, including as described elsewhere in this Privacy Statement. We will use commercially reasonable efforts to honor your request, and in all events, we will comply with applicable laws relating to your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

12. THIRD-PARTY PAGES AND WEBSITES

The Website may contain links to websites that we believe may offer useful information. The privacy policies and procedures described herein do not apply to such websites or their content, or to any collection of your Personal Information after you click on links to such third-party websites.

13. CONTACT US

If you have any questions regarding this Privacy Statement, or to exercise your rights as described above, please contact us using any of the following methods:

By Mail:	By Email:	By Phone:
Q32 Bio, Inc. ATTN: Data Protection Officer 830 Winter Street, 2nd Floor Waltham, Massachusetts 02451 USA	privacy@q32bio.com	+1 781 999 0232

14. CHANGES TO THIS PRIVACY STATEMENT

We will notify you of any changes to our Privacy Statement by posting a new Privacy Statement on this page as indicated by changing the “Last Updated” date above. Any time you visit the Website, the current version will apply.