Privacy Notice

We want you to understand what personal information Freeline Therapeutics Limited and its group of companies (“Freeline,” “we,” “us”, “our”) may collect about you, and how we use that personal information in connection with our activities, communications, products, services, applications and websites. This Privacy Notice applies to all personal information collected and otherwise processed by Freeline.

We are committed to safeguarding your personal information (or personal data) in line with all applicable laws, including the UK Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR). Freeline is a ‘controller’ of your personal data for the purposes of data protection laws. This means that Freeline is responsible for deciding how we hold and use personal information about you, as described in the notice below.

This Privacy Notice explains:

• The ways we collect personal information
• The different types of personal information we collect
• How we use your personal information
• The lawful bases on which we use your personal information
• How long we retain your personal information
• With whom we may share your personal information and where we may transfer it internationally
• The steps we take to protect your personal information
• Your data subject rights regarding your personal information
• What to do if you do not wish for us to hold your personal information
• How cookies are applied and where to find further information

This privacy notice is subject to review and change, so please refer to it periodically.

If you have any questions, please get in touch using one of the methods set out in the Contact Us section below.

The ways we collect personal information

We collect personal information in a variety of ways. These include, but are not limited to:

• When you interact with this website, complete online forms, contact corporate mailboxes, use Freeline’s publicly available social media sites or otherwise interact directly with Freeline
• If you participate in clinical trials
• From contract research organisations and clinical trial investigators
• Through government agencies or publicly available records
• From industry and patient groups and associations
• From public sources

When adding content to online databases or social media sites, you are posting to public forums, and we may occasionally use and correlate this with information we hold on you.

The different types of personal information we collect

We collect the following types of personal information:

• Contact details such as your name, email address, mailing address and phone number
• Personal and demographic information, such your age, gender, ethnicity and marital status
• Information collected in connection with clinical trial management or associated research
• Financial information to complete a transaction such as payment for services
• Information that may be publicly available from sources such as public databases, social media platforms, and other third parties, which we may combine with personal information we already hold
• When you access our website via links in any marketing emails that we send you (such as newsletters), we will collect certain technical and activity information related to your usage of our website, such as your IP address, pages visited, time spent, links clicked, and this data will be linked with your email address. Sometimes, this involves the use of cookies (for more information on cookies see our Cookie Policy)
• Freeline does not knowingly collect children’s data. Please get in touch using one of the methods set out in the Contact Ussection below if you believe such information has been collected in error

For healthcare professionals, external experts, influencers or advisors, applicants, researchers, academics, industry specialists and consultants, we also may collect:

• Details of your qualifications, skills, experience, and employment history, including start and end dates, with previous employers (including details related to previous engagements with Freeline where relevant)
• Information about your nationality and entitlement to work
• Information related to reference checks, background vetting and any criminal record
• Equal opportunities monitoring information (e.g., including information about your ethnic origin)
• Professional and educational qualifications, accreditations, work experience, affiliations, publications and curriculum vitae (CVs)
• Due diligence information about your practice that is publicly available

Freeline may collect this information in a variety of ways. For example, information might be collected through application forms or CVs; obtained from your passport or other identity documents such as your driving licence; from correspondence with you; and through interviews, meetings or other assessments.

How we use your personal information

We may use your personal information to:

• Provide you with information and services, including in connection with publications, articles, collaborations, press releases and industry events
• Contact and interact with you, including to provide important notices and updates, such as changes to our terms and policies, security alerts and administrative messages
• Correspond with you about trials, your participation in them or related research
• Conduct recruitment processes
• Inform you of job opportunities, offers or rejections
• Manage general enquiries
• Ensure we can meet legal, regulatory and government body requirements and guidance, including complying with demands and requests made by regulators, government bodies, courts and law enforcement authorities
• Protect against, investigate, and take action against cybersecurity issues, fraud, suspicious events, or other illegal or harmful activities
• Conduct and improve our operations, including compiling statistics for analysis of our sites, business, products and services
• Manage grants, donations and corporate sponsorships
• Identify you as a key opinion leader or expert, influencer or advisor for scientific or medical engagement
• Profile you as a potential investor in Freeline

We will use personal information only for the original purposes under which it was collected (or which you have consented to), and we will take appropriate steps to keep that personal information accurate, complete and up to date.

The lawful bases on which we use your personal information

We operate under a variety of privacy laws, rules and regulations, most notably the UK GDPR which requires us to demonstrate a lawful basis when processing your personal information.

We process your personal information on the following lawful bases:

• Consent: where you have provided your consent for us to process your personal information for one or more specific purposes
• Contract: we may need to process your personal information in connection with a contract to which you are a party (for example, to offer or provide to you, or to obtain from you, products or services), or because you have asked us to take specific steps before entering into a contract with you
• Legal obligation: where the processing of your personal information is necessary for us to comply with a legal and/or regulatory obligation
• Public interest: where the processing of your personal information is necessary for us to perform a specific task in the public interest
• Legitimate interest: where we have a legitimate business interest in processing your personal information and, on evaluation, your interests and fundamental rights do not override those interests

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

How do we use sensitive personal information?

Special categories of particularly sensitive personal information include information about your health, racial or ethnic origin, sexual orientation, trade union membership or criminal history, and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations or exercise rights in connection with employment, such as in relation to employees with disabilities.
• Where it is needed in the public interest, such as for equal opportunities monitoring, or in relation to our occupational pension scheme.
• Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

How long we retain your personal information

Freeline retains your personal information for only as long as the period required by law and statutory prescription, unless there is a reason to extend the retention period because of business need, legal action, or associated investigations. Once a retention period has lapsed, Freeline takes appropriate steps to dispose of such personal information.

With whom we may share your personal information and where we may transfer it internationally

We may share your personal information with:

• Other legal entities in the Freeline group
• The following trusted third parties:
  • Our vendors, suppliers, agents and business partners, including technology service providers, clinical research organisations, consultants, healthcare professionals, and testing laboratories who work with us on clinical trials
  • Our professional advisors, including auditors, outside legal counsel, and financial advisors
  • Previous employers and background checking organisations
  • Regulators, government bodies, law enforcement authorities, and ethics committees
  • Other third parties in connection with operating any part of our business, or in connection with any mergers, acquisitions, dispositions, financings, reorganisations, or similar corporate activities

Your personal information may be transferred by Freeline and its trusted third parties to, and otherwise processed in, countries outside of your home country.  To the extent the data privacy laws in the countries to which your personal information is transferred may not be equivalent to, or as protective as, the laws in your home country, we will take appropriate steps, in accordance with applicable data protection and privacy laws, to maintain an adequate level of protection and security for your personal information when it is transferred outside of your home country.

The steps we take to protect your personal information

We adopt a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction in line with applicable data protection and privacy laws. We expect our third parties to adhere to the same requirements of data protection as stipulated in our contract terms with them.

Websites that Freeline does not own or control

We may provide links to websites or mobile applications that are not owned or controlled by Freeline. This privacy notice does not apply to those websites. If you choose to use those websites, please check the legal and privacy statements posted on each website or mobile application you access to understand their privacy practices.

Your data subject rights regarding your personal information

Freeline complies with data privacy laws such as the UK GDPR and UK Data Protection Act 2018. These laws and regulations provide data subjects with a number of rights over their personal information. Under these law and regulations, you may be entitled to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
• Request the transfer of your personal information to another party
• Withdraw your consent to the processing or your personal information (in circumstances where Freeline has previously obtained your consent)

If you would like to exercise your rights, please let us know by getting in touch with us as set out in the Contact Us section; if you would like to make a complaint, please refer to the Supervisory Authorities section for further information.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What to do if you do not wish for us to hold your personal information

Where you are given the option to share your personal information with us, you can always choose not to do so.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. This could mean that we may not be able to perform the actions necessary to achieve the purposes as set out in this notice or that you may be unable to make use of Freeline’s products or services.

Cookies and other technologies

This website uses technology called “cookies” which allow this website to recognise and respond to you as an individual.  For more information about our use of cookies, and your options for accepting or declining their use, please see our Cookie Policy.

Contact Us

Requests for information

If you have any questions specifically about this privacy notice or wish to make a data subject request, please email privacy@freeline.life and we will assist you.

Alternatively, you may reach out to us through Freeline’s Contact page.

Supervisory Authorities

Freeline welcomes all concerns, enquiries and requests about how we process personal information and aims to expedite each completely. If unsatisfied with responses, you have the right to submit a complaint to the UK supervisory authority that Freeline is registered with (Information Commissioner’s Office, ICO).