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GDPR Website Privacy Notice

June 13, 2018

What is the scope of this Privacy Notice?

This Privacy Notice is intended to let you know what Personal Data (as defined below) Sunovion Pharmaceuticals Europe Ltd, including our affiliated entities (referred to collectively as “Sunovion,” “we,” “our,” or “us”) may collect about you, how we collect your Personal Data, for what purposes we use your Personal Data, to whom we may disclose your Personal Data, and what rights you may have to limit our use of your Personal Data.

What Personal Data may we collect about you?

Through this website, and by information you provide directly to Sunovion, we may collect and process Personal Data, including data that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and which if combined with certain other information could be used to identify you.

The Personal Data we process about you includes the following categories of Personal Data:

  • Name;
  • Personal contact information (address, telephone, email address)
  • Health information
  • Demographic data
  • Online identifiers
  • IP address
  • 3rd party cookies
  • Geo-location data, as may be transmitted to us by your smart phone or other location-aware devices

We may collect Personal Data on your visit to our website through cookies, IP information, or other data provided by your web browser or device. We also collect data that you voluntarily provide to us through your interactions with our websites, or if you call, email, write to us.

We combine all of this data, together with data provided by third parties as set forth below, to offer you services and to otherwise facilitate the activities described in the following section.

How will we use your Personal Data?

Processing of your Personal Data includes where we may record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, dissemination, or otherwise make available, align or combine, restrict, erase, or destroy your Personal Data.

We may process your Personal Data for the following purposes:

  • To process and report adverse events.
  • To communicate product safety information to you.
  • To respond to your requests for information, products, or services.
  • For our company compliance and facility and network security purposes.
  • To authorize, grant, administer, monitor, and terminate access to or use of Sunovion systems, facilities, records, property, and infrastructure.
  • For internal investigations of possible misconduct or failure to comply with our policies and procedures.
  • To track your interactions (online and offline) with us.
  • To manage data subject requests.
  • To audit our programs and services for compliance purposes.
  • For legal proceedings and government investigations (such as pursuant to warrants, subpoenas, and court legal orders).
  • Where we have legal obligations to process the Personal Data.
  • For statistical analysis, including Google Analytics.
  • For website administration.

What is our legal basis for processing your Personal Data?

The applicable legal bases for our processing of your Personal Data include the following:

  • Based on your consent: In some cases, at the point at which you provide Personal Data, we may ask you for your consent to collect and process your Personal Data. If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described in the “how do you contact us” section below. Please note that if you withdraw your consent it will not affect any processing of your Personal Data that has already occurred. Where we process your Personal Data based on consent, we will provide more detailed information to you at the time when we obtain your consent.
  • Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your Personal Data to comply with a relevant law/regulation or to fulfill our obligations under a contract to which you are subject. Where we process your Personal Data to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations. Where we are processing your Personal Data to fulfill our obligations under a contract to which you are a party, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
  • Our legitimate interest: We may process your Personal Data based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services, scientific research, and educational opportunities. In addition to other rights you may have as described below, you have the right to object to such processing of your Personal Data. You can register your objection by contacting us as described in the “how do you contact us” section below.

Cookies and similar technologies that collect Personal Data

Cookies
This website may use a technology called a "cookie". A cookie is a small data file that a website can place on your computer’s hard drive, where your internet browser files are kept. A cookie saves you the trouble of reentering certain information in some registration areas because cookies can be used to enable a site to “remember” information a visitor has previously inputted. A cookie also helps deliver user-specific content to you and track how sections of the website are used. Cookies can be placed on your computer both by us and by third parties with whom we have a contractual relationship, such as web analytic services and advertising network services. With most Internet browsers or other software, you can change your browser settings to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please check your browser instructions to learn more about these functions. If you reject cookies, functionality of the site may be limited, and you may not be able to take advantage of many of the site's features.

Cookies used on this site

The following are names of cookies that are currently used on this site. Each cookie includes a short description of what the cookie does and its expiry time.

Cookie name

Description

Expiration

_ga

Google Analytics: This is used to monitor traffic levels, search queries and visits to this website. It is used to distinguish users.

2 years

_gat

Google Analytics: This is used to monitor traffic levels, search queries and visits to this website. It is used to throttle request rate.

1 minute

_gid

Google Analytics: This is used to monitor traffic levels, search queries and visits to this website. It is used to distinguish users.

24 hours

Do Not Track
There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that currently our websites and web-based resources do not respond to these signals from web browsers. At this time, there is no universally accepted standard for what a company should do when a DNT signal is detected.

Google Analytics
Google Analytics may be used to help make our website work better and to help us understand what parts of the website are being utilized. Google Analytics uses technical tools such as first-party cookies and JavaScript code to collect information about visitors. Google Analytics tracks how visitors interact with a website, including where they came from and what they did on a site. This information is used to administer and update the website. It also helps us to assess whether the visitors to the site match the expected site demographics and to determine how key audiences are navigating the content.

A. Opt-Out Provision:
Google analytics offers an opt-out provision for website visitors who do not want their data to be collected. You can receive more information about this option here: http://tools.google.com/dlpage/gaoptout.

B. Google's Use of Data:
Google and its wholly owned subsidiaries may retain and use, subject to the terms of its Privacy Policy (located at http://www.google.com/privacy.html, or such other URL as Google may provide from time to time), the information collected by Google Analytics.

Children’s Personal Data

This site is not intended for, or designed for, individuals under the age of 16. We do not knowingly collect Personal Data from any person under the age of 16.

How do we protect your Personal Data?

We use industry-standard administrative, technical, and physical safeguards to protect your Personal Data against loss, theft, misuse, unauthorized access, modification, disclosure, and destruction. We restrict access to your Personal Data to only those employees and third parties acting on our behalf who have a legitimate business need for such access. We will only transfer your Personal Data to third parties acting on our behalf where we have received written assurances that your Personal Data will be protected in a manner consistent with this Privacy Notice and our privacy policies and procedures.

How do we protect your Personal Data?

We use industry-standard administrative, technical, and physical safeguards to protect your Personal Data against loss, theft, misuse, unauthorized access, modification, disclosure, and destruction. We restrict access to your Personal Data to only those employees and third parties acting on our behalf who have a legitimate business need for such access. We will only transfer your Personal Data to third parties acting on our behalf where we have received written assurances that your Personal Data will be protected in a manner consistent with this Privacy Notice and our privacy policies and procedures.

How long do we retain your Personal Data?

Your Personal Data will be maintained for the duration of your relationship with us. We will store and retain the Personal Data we collect about you in accordance with our Corporate Record Retention Policy, after which it will be deleted. Please note that certain information could be retained for longer periods of time if we have continuing obligations to you or if required by local law.

With whom do we share your Personal Data?

We share your personal data with our service providers who facilitate the purposes described above. We disclose information to third parties who provide us with various business services, including monitoring and maintaining the website, for example. We also share Personal Data with third parties with whom we are working to provide you with other services or information.

We may also disclose information we collect to legal counsel, law enforcement, and other appropriate authorities in special cases, including: (i) when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person; or (ii) when we believe that it is required by applicable laws, court orders, or government regulations.

If all or part of Sunovion is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. Your information may also be included among the assets affected by financing agreements undertaken by Sunovion.

Will Sunovion transfer your information internationally?

Our website and online resources are owned and operated in the United States, and the information you provide may be accessible by our affiliates and vendors in other countries. If you are visiting this site from a country other than the United States, your information will cross an international boundary. The level of protection for your information in the United States may not be the same as the level of protection in your country. Your use of the website will result in the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

Links to Third Party Websites

As a convenience to our visitors, this website may contain links to other sites owned and operated by third parties that we believe may offer useful information. The policies and procedures we describe here do not apply to those sites. We are not responsible for the collection or use of Personal Data by or on any third party sites. Therefore, we disclaim any liability for any third party's use of Personal Data obtained through using the third party web site. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.

What are your rights?

You have the right to see and get a copy of your Personal Data, including an electronic copy, as well as to ask us to make any corrections to inaccurate or incomplete Personal Data we have about you. You can also request that we erase your Personal Data when it is no longer needed for the purposes for which you provided it, restrict how we process your Personal Data to certain limited purposes where erasure is not possible, or object to our processing of your Personal Data. In certain circumstances you may be able to request that we send a copy of your Personal Data to a third party of your choosing.

To exercise any of these rights, please contact us as set forth in the “how do you contact us” section below. You also have the right to lodge a complaint with the supervisory authority (see details under “remedies” below) where you believe that your rights have been violated.

What if we revise this Privacy Notice?

From time to time we may make changes to this Privacy Notice to reflect changes in our legal obligations or the ways in which we process your Personal Data. We will communicate to you any material changes to this Privacy Notice and such changes will become effective when they are communicated.

How do you contact us if you have any questions or concerns?

Please contact Sunovion Europe’s Data Protection Officer (DPO) using the below information to:

  • Ask questions;
  • File a concern or complaint;
  • Opt-out of a program or service; and/or
  • To exercise any of your rights listed above, including access, correction, portability, objection, restriction, and erasure.

Sunovion Europe

Email Address:
privacy@sunovion.com

Mailing Address:
First Floor, South Side
97-105 Victoria Street
London
SW1E 6QT
United Kingdom

What remedies do you have available?

For more information about your privacy and data protection rights, or if you are not able to resolve a problem directly with us and wish to make a complaint, please contact your country-specific data protection authority or Sunovion’s lead data protection supervisory authority:

Information Commissioner’s Office (ICO)
0303 123 11134
www.ico.org.uk