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PLEASE
READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION
AND YOUR RELATED CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND
CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR SITE.
OUR
SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES AND IS NOT INTENDED FOR
USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN
ECONOMIC AREA.
INTRODUCTION
Celltrion
USA, Inc. (referred to as “Celltrion USA,” “we,” “us,” and
“our”) is committed to protecting the privacy and security of the
personal information we collect, use, share, and otherwise process as part of
our business. We also believe in transparency, and we are committed to
informing you about how we treat the data we collect and process.
When
Does this Policy Apply? This
Privacy Policy (the “Policy”) describes our practices and how we may use
information about you (“Personal Information”) in your role as a health
care professional, member of a health care organization or institution, pharmacist,
government official, non-profit organization, or other non-patient individuals
with whom we collaborate (collectively, “health care professional”, “you”,
and “your”).
This
policy applies to information we collect:
•
On the Websites operated by us from which
you are accessing this Privacy Policy;
•
In email, text, and other electronic
messages between you and the Celltrion USA;
It does
not apply to information collected by:
•
Us
offline or through any other means, including on any other website operated by
Celltrion USA or any third-party (including our affiliates and subsidiaries);
• Any
software application made available by us for use on or through smartphones or
devices; or
• Any
third-party (including our affiliates and subsidiaries), including through any
application or content (including advertising) that may link to or be
accessible from or through the Sites.
Please
read this policy carefully to understand our policies and practices regarding
your information and how we will treat it. If you do not agree with our
policies and practices, please refrain from using our Site. By accessing or
using the Sites, you agree and consent to this Privacy Policy. This policy may
change from time to time. Updates to this policy will made apparent to you by
the “Last Updated” date listed at the top of this policy. It is your
responsibility to monitor for changes to this policy. Your continued use of
these Websites after we make changes is deemed to be acceptance of those
changes, so please check the policy periodically for updates.
WHAT
INFORMATION DO WE COLLECT?
We may
collect the information listed below for the purposes described in the “How
Do We Use and Share Your Information?” section of this Policy.
|
Description |
|
|
Name, Contact Information, and Identifiers |
Identifiers such as a real name, alias,
postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, username, social security
number, tax ID, driver’s license number, state or national identification
card number, passport number, or other similar identifiers. |
|
Customer and Other Records |
Paper and electronic customer records
containing personal data, such as name, signature, physical characteristics
or description, address, telephone number, insurance policy number,
education, employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical
information, or health insurance information |
|
Protected Classifications |
Characteristics of protected classifications
under applicable state or federal law such as race, ethnicity, sex,
gender, age, national origin, disability, and citizenship status. |
|
Purchase History and Tendencies |
Commercial information, including records of
products or services considered, purchased, or owned. |
|
Biometric Information |
Physiological, biological or behavioral
characteristics that can be used alone or in combination with each other to
establish individual identity, including DNA, fingerprint, diagnostic or lab
results, imagery of the face from which an identifier template can be
extracted, and sleep, health, or exercise data that contain identifying
information. |
|
Usage Data |
Internet or
other electronic network activity information, including, but not limited to,
browsing history, search history, and information regarding a resident’s
interaction with an internet website, application, or advertisement. |
|
Geolocation Data |
Precise geographic location information
about a particular individual or device. |
|
Audio/Visual |
Audio, electronic, or visual recordings, or
similar information. |
|
Professional or Employment-Related
Information |
Work experience, name, phone number, email
address, performance evaluations. |
|
Education Information |
Information that is not publicly available
personally identifiable information as defined in the federal Family
Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part
99). |
|
Sensitive Information |
As defined under applicable local law, such
as certain characteristics of protected classifications, precise geolocation,
account login credential and passwords, health information, and financial
information. |
|
Communications and Questions |
Comments, content, questions, or other
information that you choose to provide |
|
Cookies and Similar Technologies |
Please see the “Cookies and Similar
Technologies” section of this Policy for more information. |
|
Profiles
and Inferences |
Inferences
drawn from any of the information identified above to create a profile about a
resident reflecting the resident’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes. |
Cookies
and Similar Technologies
First and
Third-Party Cookies
A “cookie” is
a small file created by a web server that can be stored on your device (if you
allow) for use either during a particular browsing session (a “session” cookie)
or a future browsing session (a “persistent” or “permanent” cookie). “Session”
cookies are temporarily stored on your hard drive and only last until they
expire at the end of your browsing session. “Persistent” or “permanent” cookies
may remain stored on your hard drive until they expire or are deleted by you.
Local shared objects (or “flash cookies) may be used to collect and store
information about your preferences and navigation to, from, and on the site.
First-party cookies are set by the website you’re visiting, and they can only
be read by that site. Third-party cookies are set by a party other than that website.
Other Similar
Technologies
In
addition to cookies, there are other automatic data collection technologies,
such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel
gifs), and navigational data collection (log files, server logs, etc.) that can
be used to collect data as users navigate through and interact with a website.
For example, web beacons are tiny graphics with unique identifiers that are
used to understand browsing activity. In addition, UTM codes are strings that
can appear in a URL when you move from one web page or website to another. The
string can represent information about browsing, such as which advertisement,
page, or publisher sent the user to the receiving website.
What
Cookies and Similar Technologies Are in Use and Why Do We Use Them?
We use
first-party and third-party cookies and similar technologies for purposes such
as to improve Site functionality, to measure and track how users interact with
the Site, and to perform similar analytics. We may also use first-party and
third-party cookies and similar technologies on the Site in order to otherwise
tailor our communications with you.
Other
Third-Party Technologies
Some third
parties may use automated data collection technologies to collect information
about you when you browse the Internet. The information they collect about your
online browsing activities over time and across different websites and other
online services may be associated with your personal information and used to
provide you with targeted content. We do not control these third parties’
technologies or how they may be used. If you have any questions about targeted
content, you should contact the responsible party directly or consult their
privacy policies.
Choices About
Cookies
Most web
browsers are set by default to accept cookies. If you do not wish to receive
cookies, you may set your browser to refuse all or some types of cookies or to
alert you when cookies are being sent by website tracking technologies and
advertising. These settings may affect your enjoyment of the full functionality
of the Site. In addition, adjusting the cookie settings may not fully delete
all of the cookies that have already been created. To delete them, visit your
web browser settings after you have changed your cookie settings. Additional
information is provided below about how to disable cookies or manage the cookie
settings for some of the leading web browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
and https://support.apple.com/en-us/HT201265
For more information about how to
modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about
internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work, or http://www.networkadvertising.org/choices. To learn how you can manage your
Flash cookie settings, visit the Flash player settings page on Adobe’s website
at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html.
How do we use the information described in this Policy? To
the extent permitted by applicable law, we may use the information described in
the “What Information Do We Collect?” section above for purposes listed
below.
●
Provide you with services, content, customer service, and
functionality;
●
Manage your access to and use of our services;
●
Honor our terms of service and contracts;
●
Process and complete
payments and other transactions;
●
Operate
and improve our operations, business, services, and the Site;
●
Develop new products and services;
●
Improve our customer service;
●
Communicate with you and respond to your feedback, requests,
questions, or inquiries;
●
Manage our relationship with you;
●
Maintain our databases and back-ups, including records of our
communications with you;
●
Ensure the privacy and security of our Site, and services;
●
Detect fraud and prevent loss;
●
Support and improve the Site, including evaluations of
functionality and features;
●
Promote our services;
●
Contact you about other products and services;
●
Invite you to participate in surveys or to personalize your
experience with our services;
●
Analyze use of the Site, and our services and prepare aggregate
traffic information;
●
Provide you with a more personal and interactive experience on the
Site;
●
Determine and track user interests, trends, needs, and
preferences;
●
General business support purposes, including but not limited to
procurement, financial and fiscal management, risk and compliance management,
and external reporting;
●
Facilitate corporate mergers, acquisitions, reorganizations,
dissolutions, or other transfers;
●
Accomplish any other purpose related to and/or ancillary to any of
the purposes and uses described in this Policy for which your information was
provided to us;
●
Accomplish another purpose described to you when you provide the
information, for which you have consented, or for which we have a legal basis
under law;
●
Comply with federal, state, or local laws;
●
Comply with a civil,
governmental, or regulatory inquiry, order, subpoena, summons, or process;
●
Cooperate with law enforcement agencies;
●
Exercise or defend legal rights or claims; and
●
Create, use, retain, or disclose de-identified or aggregated data.
How do we disclose or share the information described in this
Policy? To
the extent permitted by applicable law, we may share the information described
in the “What Information Do We Collect?” section above for purposes
listed below.
|
Category |
Description |
|
Affiliates |
We may
share your information with our subsidiaries and affiliates and with their
respective officers, directors, employees, and agents. |
|
Acquisitions
and Similar Transactions |
We may disclose your information
in the event of a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of our company assets. If our
business is acquired by or merged with another company, your information may
be transferred to the new owners. |
|
Disclosures
with Your Consent |
We may ask
if you would like us to share your information with other unaffiliated third
parties who are not described elsewhere in this Policy. We will only disclose
your information in this context with your consent. |
|
Legal
Obligations and Rights (Subpoenas, Court Orders, and Warrants) |
We may
disclose information in response to subpoenas, warrants, court orders or
other legal process, or to comply with relevant laws. We may also share
information in order to establish or exercise our legal rights or claims; to
defend against a legal claim; and to investigate, prevent, or take action
regarding possible illegal activities, suspected fraud, safety of person or
property, or a violation of our contracts. |
|
|
We may provide information about you to
third parties that may offer products and services specifically requested by
you, including authorized representatives and health care providers. |
|
Service
Providers |
We may share information with
our service providers that need access to information to provide operational
or other support services on our behalf (e.g., for managing or hosting
services and/or underpinning technology for the Services we are providing). Among other things, service providers
help us to administer the Site; support our operations; provide technical
support; send communications to you; provide payment processing; and assist
with other legitimate purposes permitted by law. |
|
Professional
Advisors |
We may share
your information with our and our affiliates’ insurers, auditors, and
professional advisors, including attorneys and accountants, that need access
to your information to provide operational or other support services on our
behalf. |
|
Deidentified
or Aggregated
Data |
We may
disclose aggregated information or de-identified information that does not
identify any specific individual, such as groupings of demographic data or
customer preferences. |
HOW
LONG DO WE STORE AND USE YOUR INFORMATION?
At our sole discretion, we may delete your information if we believe it is incomplete,
inaccurate, or that our continued storage of it is contrary to our objectives
or legal obligations. When we delete data, it will be removed from our active
servers and databases, but it may remain in our archives when it is not
practical or possible to delete it.
To
the extent permitted by law, we may retain and use anonymous, de-identified, or
aggregated information for performance reporting, benchmarking, and analytic
purposes and for operational improvement.
HOW
DO WE PROTECT YOUR INFORMATION?
We have put
security measures in place to protect the personal information that you share
with us from being accidentally lost, used, altered, disclosed, or accessed in an
unauthorized manner. From time to time, we review our security procedures to
consider appropriate new technologies and methods.
If a data breach compromises
your personal information, we will notify you and any applicable regulator when
we are required to do so by applicable law.
Please use
the “Contact Us” details provided at the end of this Policy to exercise your
rights and choices under this Policy. We honor such requests when we are required to do so
under applicable law.
Email Opt-Out. We may send you emails about our services and other updates. If you no
longer wish to receive communications from us via email, you may opt-out by
clicking the “unsubscribe” link at the bottom of our emails, if applicable, or
by submitting a request via the “Contact Us” details at the end of this Policy
and providing
your name and email address so that we may identify you in the opt-out process.
Once we receive your instruction, we will promptly take corrective action. Please note
that registered users cannot opt out of receiving transactional e-mails related
to their account.
Accuracy and
Updating Your Information. Our goal is to keep your information accurate, current,
and complete. If any of the information you have provided to us changes, please
let us know via the “Contact Us” details at the end of this Policy. For
instance, if your email address changes, you may wish to let us know so that we
can communicate with you. If you become aware of inaccurate personal
information about you, you may want to update your information. We are not responsible
for any losses arising from any inaccurate, inauthentic, deficient or
incomplete personal data that you provide to us.
Complaints. If you believe your rights relating to your personal
information have been violated, please contact us via the “Contact Us” details
provided at the end of this Policy.
California
Residents. Under California Civil Code Section 1798.83, California residents
who provide personal information in obtaining products or services for
personal, family, or household use may be entitled to request and obtain from
us once per calendar year information about the information we shared, if any,
with other businesses for direct marketing uses. Please be aware that not all
information sharing is covered by the “Shine the Light” requirements and only
information on covered sharing, if any, will be included in our response.
CPRA gives residents of California the right to opt-out of their
personal information being sold to third-parties, the sharing of their personal
information for behavioral advertising, and to limit the use of their sensitive
personal information. This may include the Celltrion USA’s disclosure of
personal information with our clients for certain services. The opt-out right
has some exemptions such as sharing of information with necessary service
providers will remain unaffected and opt-out requests will not affect the
Celltrion USA’s services where personal information is not sold.
If you are a California resident, you can exercise these rights by
submitting a request to privacy_usa@celltrionhc.com. When submitting the request,
please indicate that you are exercising your California right to opt-out of the
sale or sharing of your personal information or limiting the use of your
sensitive personal information, as it will help us to honor your request.
Nevada
Residents. You may submit a verified
request to us at privacy_usa@celltrionhc.com to request
that we not make any sale (as defined under Nevada law) of any covered
information (as defined under Nevada law) that we have collected or will
collect about you. Please provide your name and contact information in your request.
We will respond to your request in accordance with Nevada law.
THIRD-PARTY SITES AND SERVICES
The
Site may contain
links to, and media or other content from, third parties.
These links are to external resources and third parties that
have their own privacy policies. Because of the dynamic media capabilities
of the Site, it may not
be clear to you which links are to external, third-party resources. If you
click on an embedded third-party link, you will be redirected away from the Site to
the external third-party website. You can check the URL to confirm that you
have left the Site.
We cannot and do not (1) guarantee
the adequacy of the privacy or security practices employed by or the content
and media provided by any third parties or their websites, (2) control third
parties’ independent collection or use or your information, or (3) endorse any
third-party information, products, services or websites that may be reached
through embedded links on the Site.
Any information provided by you or
automatically collected from you by a third party will be governed by that
party’s privacy policy and terms of use. If you are unsure whether a website is
controlled, affiliated, or managed by us, you should review the privacy policy
and practices applicable to each linked website.
Cross Border Transfers
While the Site is intended for
users located in the United States, any information you provide to us through
use of the Site may be stored and processed, transferred between and accessed
from the United States and other countries that may not guarantee the same
level of protection of personal information as the one in which you reside.
However, we will handle your personal information in accordance with this
Policy regardless of where your personal information is stored/accessed.
CHILDREN
UNDER THE AGE OF 18
THIS
SITE IS NOT INTENDED FOR CHILDREN UNDER 18 YEARS OF AGE. NO ONE UNDER AGE 18
MAY ACCESS, USE THE SERVICES OF, OR OTHERWISE PROVIDE ANY INFORMATION THROUGH
THIS SITE.
The Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Protection
Act (“CCPA”), as well as other data privacy regulations restrict the
collection, use, or disclosure of personal information from and about children
on the Internet. Our Site and services are not directed to children aged 18 or
younger, nor do we knowingly collect information from or about children under
the age of 18. No one under the age of 18 may access, browse, or use the Site
or provide any information to or on the Site. If you are under 18, please do
not use or provide any information on the Site (including, for example, your
name, telephone number, email address, or username). If we learn that we have
collected or received personal information from a child under the age of 18, we
will take steps to stop collecting that information and delete it. If you
believe we might have any information from or about a child under the age of
18, please contact us via the “Contact Us” details provided at the end of this
Policy.
BY ACCESSING THIS SITE, YOU REPRESENT YOU ARE AT LEAST 18 YEARS OF
AGE.
For more information about COPPA,
please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. For more information about
CCPA’s requirement for a child’s consent to data collection, please see the
State of California CCPA website, located at: https://oag.ca.gov/privacy/ccpa.
UPDATES AND CHANGES TO THIS POLICY
You are expected to, and you acknowledge and agree that it is your
responsibility to, carefully review this Policy prior to
using the Site, and from time to time, so that you are aware of any
changes. Your continued use of the Site after the “Last Updated”
date will constitute your acceptance of and agreement to such
changes and to our collection and sharing of your information
according to the terms of the then-current Policy. If you do not agree with
this Policy and our practices, you should not use the Site.
CONTACT US
By Postal Mail: Celltrion
USA, Inc.
Attn:
US Compliance
1 Evertrust Plaza
Jersey City, NJ 07302
By Email: privacy_usa@celltrionhc.com
We will never ask you for credit card information via email. Please
do not include credit card or other sensitive financial information in your
emails to us.
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