Moderna's Privacy Statement
Effective March 2023
This Privacy Statement describes how Moderna Inc. and its worldwide affiliates (“Moderna”, “we”, “our” or “us”) describes how Moderna collects, stores, uses (“processes) your personal data when you:
use our website www.modernatx.com or any other Moderna website that links to this statement;
use any of our other digital services, such as an app provided by Moderna, that link or use this statement; or
engage with us through our call centers.
“Personal Data” means information associated with or used to directly or indirectly identify or contact a specific person. Such data can include your name, contact details, relationship with Moderna, etc.
Certain Personal Data, such as information about health or medical status (pursuant to all applicable laws) are characterized as sensitive (collectively, “Sensitive Personal Data”) and may be subject to stricter regulation and consent requirements than other information.
Moderna recognizes the importance of taking steps to protect the privacy of information we collect, and we are committed to respecting your privacy.
Carefully read this Privacy Statement to learn more about how we collect, use, disclose and store personal data provided and the steps we take to help protect the often-sensitive personal data provided from unauthorized use or disclosure. When you submit information to or through our sites or services, you consent to the collection, processing and retention of your information as described in this Privacy Statement.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY STATEMENT, THEN PLEASE DO NOT USE ANY OF THESE SERVICES.
We will handle your Personal Data in accordance with applicable law and in line with the following principles:
We will process Personal Data lawfully, fairly and in a transparent manner.
We will only collect Personal Data for a specified, explicit and legitimate purpose, and we will only use personal information for the purposes for which it was originally collected.
We will limit collection of Personal Data to the extent necessary in relation to the purpose for which they are processed.
We will make reasonable efforts to ensure that your Personal Data is accurate and, where necessary, kept up to date.
We will store Personal Data for no longer than is necessary for the purpose for which the Personal Data are processed.
Personal Data will only be processed in a manner that ensures appropriate security of the personal information.
Our privacy practices are described in greater detail in the remainder of this Privacy Statement.
Information We Collect
You may visit our website without affirmatively providing any information about yourself. If you choose to submit your information through the “Join our Mailing List” or the “Contact Us” features on our website or if you apply for a job opening with Moderna via the “Careers” section of our website, we may ask you to provide Personal Data, such as your name, address, telephone number and e-mail address, job title, company name, country, information about your job role and any other job-related information. You are not obligated to provide any Personal Data to Moderna, but your ability to use our website or its features and your ability to apply for an employment position may be limited if you do not.
If you call one of our call centers, we may ask you to provide Personal Data, such as your name, address, telephone number, e-mail address, country, and any other Personal Data relevant to the reason for your call. Where relevant to your call, we may process data concerning health.
“Cookies” are small files that the website places on your hard drive for identification purposes. These files are used for website registration and for customization of your next time visit to our website. For example, cookies will remember your preferred language and display. Cookies cannot read data off of your hard drive.
We use the following cookies on our website:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into your job applicant account.
Functionality cookies. These are used to recognize you when you return to our website and to embed functionality from third party services. This enables us to personalize our content for you, remember your preferences (for example, your choice of language) and to integrate useful services provided by third party providers into our website.
Analytics cookies. We use the Adobe Analytics and Google Analytics platform to collect certain analytical information to help us better understand activity on our website and improve our services and the quality of our website. This information includes the IP address, page requests, referring websites or ads, operating system and browser, and time spent on our website. We receive this data in an aggregated form. We use this information to help us understand how visitors engage with our website, measure the effectiveness of our advertising on third-party websites, and to improve our visitors’ experience. For more information about Adobe Analytics, please visit https://experienceleague.adobe.com/docs/analytics/technotes/privacy-overview.html. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.
You can refuse or accept cookies from this website at any time by activating the cookie settings in your browser. The “help” menu on most internet browsers contains information on how to disable cookies, or you can visit http://www.aboutcookies.org/how-to-control-cookies/. By not accepting cookies, some features on our website may not fully function, and you may not be able to access certain information on this website.
Personal Data From Third-Party Sources. We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, if you apply for an employment position with Moderna via our website, we may view your LinkedIn profile.
Aggregated Data. We may aggregate and/or de-identify any Personal Data that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
How We Use Personal Data
We may use Personal Data for the following purposes.
Our legitimate interests
We may process your Personal Data where it is necessary for our legitimate interest as a company, including to manage, promote and improve our business and manage our risk. For example, we may process your Personal Data to:
provide you with information you requested and/or to respond to your inquiries submitted via the website, email and/or phone,
facilitate our recruitment activities (such as processing employment applications, evaluating you as a job candidate for an employment activity, and monitoring our recruitment statistics),
analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read),
tailor the content we display on our website,
protect against, identify, investigate and respond to fraud, illegal activity (such as incidents of hacking or misuse of our website) and claims and other liabilities,
help us comply with our legal or regulatory obligations or our contractual obligations to the U.S. government as a government contractor,
maintain the privacy, security, safety or property of the website, and
communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect Personal Data from you.
We may be required by law or regulation to collect and process certain Personal Data about you. For example, we may be required to process certain personal data in relation to reporting of adverse events.
We may also process Personal Data in order to carry out scientific research in the public interest.
We may also seek, either directly or through our trusted third parties, your separate consent to process your Personal Data, for example, when you choose to receive Moderna news and updates from us, or for the use of non-essential cookies.
If we have sought your consent to process your Personal Data, you may subsequently withdraw it at any time by contacting us at the address listed in the “Your Privacy Rights” section below.
Where we process data concerning health, including for the purposes of handling reports of adverse events, we also ensure that we have an additional lawful basis as required by the GDPR. This will usually be because we need to do so for reasons of public interest in the area of public health or for scientific research.
Sharing of Personal data
We will not sell, share, or otherwise distribute your Personal Data to third parties except as provided in this Privacy Statement.
Affiliates and Service Providers. We may disclose your Personal Data to other Moderna affiliates worldwide that agree to treat it in accordance with this Privacy Statement. We may also transfer Personal Data to service providers who act for or on our behalf for further processing, such as evaluating the usefulness of this website, data management, technical support or recruiting data analysis. These service providers have contracted with us to only use the Personal Data for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, not to sell your Personal Data to other third parties, and not to disclose it to other third parties except as may be required by law, as permitted by us or as stated in this Privacy Statement.
Other Parties in Connection with a Corporate Transaction. We may also transfer Personal data we collected from you to a third party as part of a corporate business transaction such as a merger, acquisition, reorganization, joint venture, financing or sale of our assets.
Other Parties when Required by Applicable Law or As Necessary to Protect Moderna. We may disclose Personal Data to a third party to comply with legal and regulatory requirements, or to protect against fraud, illegal activity (such as responding to incidents of hacking or misuse of our website) and claims and other liabilities.
International Data Transfers
When we share Personal Data with a third party, such data transfers may include the transfer of Personal Data to other countries. Those countries may not have the same data protection laws as the country in which the Personal Data initially originated.
EEA and UK Persons Only
Moderna, in the US, will act as a data controller and will process your Personal Data, by determining purposes and means of its processing, as per the GDPR. Please be aware that your Personal Data will reside on Aquia’s servers including inside and outside of the European Union. We provide specific call centers for EEA and UK persons so that your call can be handled in the EEA or UK. Before transferring your Personal Data outside the EEA or UK, we will take steps to ensure that such data will be afforded the same level of protection as under applicable data protection laws within the EEA and UK. For data transfers outside the EEA or UK, we use, where required, applicable safeguards, including standard contractual clauses approved by the European Commission. A copy of these measures can be obtained by contacting us at the email address listed below.
Your Privacy Rights
You may have certain rights as a data subject under applicable law. For example, you may have the right to object to or request restriction of processing of your Personal Data and to request access to, rectification, erasure and portability of the Personal Data we hold about you, subject to certain exceptions prescribed by law. If you would like to receive further information regarding our use of your Personal Data, or if you would like to exercise your rights, please contact us at:
200 Technology Square
Cambridge, MA 02139 USA
We will attempt to provide any requested information and to make requested changes to the extent required by and permissible under applicable privacy laws and other laws and regulations. In any event, we will endeavor to respond to you as soon as possible to advise you of the outcome of your request.
You may file a complaint with the relevant supervisory authority if you consider that our processing of your Personal Data infringes applicable law. Contact details for all EU Supervisory Authorities can be found here.
Moderna uses commercially reasonable administrative, technical, personnel-related, and physical security measures designed to safeguard the Personal Data in our possession against loss, theft and unauthorized use, disclosure, or modification. Of course, despite these measures, we cannot guarantee perfect security of the networks, servers, and databases we operate or that are operated on our behalf. In particular, email sent to or from the website may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the website.
Your Personal Data will be retained by Moderna only for as long as necessary to fulfill the purpose(s) for which it was collected, depending on the purpose(s) for which the Personal Data was collected, the nature of the Personal Data, any contractual relationship that governs the retention of the Personal Data, and our legal or regulatory obligations. We will then destroy or anonymize your Personal Data, in accordance with applicable law.
In the event that we contact you, including via email, we will provide you with a method to opt out of or opt in to receiving further communications to the extent required by law. For example, you may elect to receive email updates about developments regarding Moderna’s products and/or services or about health-related specific topics (e.g. to receive email updates about methylmalonic acidemia (MMA) from Moderna) by completing the relevant “Join our Mailing List” electronic form on our website. If you decide, at any later time, that you no longer wish to receive such email communications from us, you may unsubscribe to any such contact list by using the relevant “Unsubscribe” link within the respective electronic communications channel, or by sending us an email entitled “Unsubscribe from email updates” at email@example.com
Our Children’s Statement
The Services are not intended for use by children. If you are under the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that a child under age 13 has provided Personal Information to or through the Services without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and subsequently we will dispose of such Personal Information in accordance with this Privacy Statement.
If you believe Moderna may have any information from or about a child under age 13, please contact our Privacy Office using the contact information at the end of this Privacy Statement.
CalOPPA Do-Not-Track Notice
We do not track our website users over time and across third party websites and therefore do not respond to Do Not Track (DNT) signals. Moderna does not authorize third parties to collect Personal Data directly from our users on our website, such as through the use of third party advertisements.
Links to Third Party Websites
As a convenience to our visitors, this website may contain links to other websites that we believe may offer useful information. Those links may include links to websites that may perform services for us. Please be aware that Moderna is not responsible for the privacy practices of such other websites and cannot guarantee the privacy standards of such other websites. We encourage our users to be aware when they leave our website and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by our website, and not to any linked, non-Moderna website.
Changes to Privacy Statement
Moderna reserves the right to change the terms of this Privacy Statement. If we make any material changes to this Privacy Statement, we will notify you in advance through the Services. If we decide to use Personal Information in a manner that is materially different from the uses described in this Privacy Statement or otherwise disclosed to you, you will have the choice to allow or disallow any additional uses or disclosures of your Personal Information. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Statement. The amended Privacy Statement supersedes all previous versions.
For Additional Information
If you have any questions about this Privacy Statement, or concerns about the practices of this website, or your dealings with this website or any privacy-related matter in general, please email us at firstname.lastname@example.org or contact us in writing at:
Attention: Global Ethics Compliance & Privacy Legal Department
200 Technology Square
Cambridge, MA 02139