Tenaya Therapeutics Privacy Policy

Effective Date: February 6, 2022

Tenaya Therapeutics, Inc (collectively, “we,” “us,” or “our”) values the privacy of individuals who use our website (www.tenayatherapeutics.com) (the “Site”).  This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Information from users of the Site.  As used in this Privacy Policy, “Personal Information” means any information that: (i) can reasonably be used to identify an individual or information relating to an identified or identifiable individual and (ii) is collected by us or on our behalf via the Site.  By using the Site, you agree to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.  Beyond this Privacy Policy, your use of the Site is also subject to our Terms of Service.

Information We Collect
We may collect and receive a variety of information from you or about you or your devices from various sources, as described below.

A. Information You Provide to Us

  • Communications. If you contact us directly, we may receive additional Personal Information about you. For example, when you apply to participate in clinical trial, we may receive your name, email address, phone number, and any additional information you choose to provide. If you subscribe to our newsletter, we will receive your email address.
  • Investor Portal. If you fill out information on the Site via the investor portal (the “Investor Portal”), we may receive additional Personal Information about you. For example, if you request to receive alerts for business updates or make a partnering or media request through the Investor Portal, we may receive your name, email address, phone, company, postal address, the content of your message, date and time of your message, and other information you may directly provide to us.
  • Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform, we will collect the information you make available to us through such third-party platforms.

B. Information We Collect When You Use the Site

  • Usage Information. To help us understand how you use the Site and to help us improve it, we automatically receive information about your interactions with the Site, such as the pages or other content you view, the searches you conduct, and the dates and times of your visits.
  • Device information. We may collect information about the device and software you use to access the Site, including IP address, web browser type, operating system version, and device identifiers (including unique device identifiers and MAC addresses).
  • Location Information. When you use the Site, we may infer your general location information. For example, your IP address may indicate your general geographic region.
  • Cookies and Related Technologies.  We use cookies, beacons, invisible tags, and similar technologies (collectively, “Cookies”) to collect information about your browsing activities and to distinguish you from other users of the Site. You can find more information about our use of Cookies in our Cookie Policy.

C. Information We Receive from Third Parties

You may post photos, comments, or reviews on our pages available through third-party platforms. If you do so, we and other users on those third-party platforms may be able to view Personal Information you make available through these third-party platforms. We may also obtain Personal Information from third parties and sources other than the Site, such as third-party service providers who host and build the Site, and combine it with other Personal Information we have about you.

How We Use Your Information

We use the Personal Information we collect:

  • To provide, update, maintain, and enhance the Site;
  • To test and develop new products, services, and features;
  • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you;
  • To communicate with you, provide you with updates and other information relating to the Site, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • To conduct benchmarking, analytics, and industry analysis;
  • To de-identify and aggregate information collected through the Site and use it for our business purposes;
  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;
  • To process your job application; and
  • For other purposes for which we provide specific notice at the time the Personal Information is collected.

Legal Bases For Processing European Information

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis”, including as set forth below.

  • Consent. We may process your Personal Information where you have consented to certain processing of your Personal Information. For example, we may process your Personal Information to send you marketing communications or to use Cookies where you have consented to such use.
  • Contractual Necessity. We may process your Personal Information where required to provide you with the Site. For example, we may need to process your Personal Information to respond to your inquiries or requests.
  • Compliance with a Legal Obligation. We may process your Personal Information where we have a legal obligation to do so. For example, we may process your Personal Information to comply with tax, labor and accounting obligations.
  • Legitimate Interests. We may process your Personal Information where we or a third party have a legitimate interest in processing your Personal Information. Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Site. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

How We Share The Information We Collect

We do not share or otherwise disclose the Personal Information we collect from you except as described below or otherwise disclosed to you at the time of the collection.

  • Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Site.
  • Partners and Affiliates. We may share any information with our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.
  • Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.
  • Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own Cookies on the Site and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies.
  • Analytics Partners. 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 about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • Aggregated or Anonymized Data. We may share or use aggregated or anonymized data for our business purposes.
  • As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through the Site.
  • Merger, Sale, or Other Asset Transfers. We may disclose and transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
  • Consent. We may also disclose Personal Information from or about you or your devices with your permission.

Your Rights And Choices

  • Opt-Out. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
  • Do Not Track. Your browser may allow you to transmit a “Do Not Track” signal to online services. However, there is no accepted standard on what a “Do Not Track” signal means or how to respond to them, and like many other online services, we do not alter any of our online practices when such signals are received.
  • Withhold Information. You may not to provide us with your Personal Information when requested. However, if you choose not to do so, some features of the Site may not work as intended or you may not be able to use the Site if that information is necessary to provide you with our services or if we are legally required to collect it.
  • Your European Privacy Rights. If you are located in the EEA or the UK, you have the rights described below.
    • You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. You also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
    • You may withdraw consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge. We will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdrew your consent.

    You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Third Parties

The Site may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices, policies or other content of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. If you have any questions about how these other sites use your Personal Information, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.

Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

Security

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.

International Visitors

The Site is hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing. We may transfer Personal Information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, as needed to perform our services that you have requested from us, or with your consent. Also, we may transfer your Personal Information from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including Personal Information, on or to the Site, you consent to such transfer, storage, and processing.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age (“Minors”), and no part of the Site is directed to children. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, please alert us at privacy@tenayathera.com.

Changes To This Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through the Site, we will attempt to notify you through the Site, by email, or by other means.

How To Contact Us

For question or complaints regarding our use of your information or this Privacy Policy, please contact us at privacy@tenayathera.com or via post:

Tenaya Therapeutics, Inc
171 Oyster Point Blvd., Suite 500
South San Francisco, CA 94080