This Privacy Policy is intended for healthcare professionals with whom Celltrion USA currently works or wishes to work. If you are not a healthcare professional, or if you are interested in additional information about how we process and protect personal information, please access our User Privacy Policy here: https://www.celltrionconnect.com/hcp-privacy-policy.
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 healthcare professional, member of a healthcare organization or institution, pharmacist, government official, non-profit organization, or other non-patient individuals with whom we collaborate (collectively, “healthcare professional”, “you”, and “your”).
This policy applies to information we collect:
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?
As a healthcare provider, we engage with you and utilize your information for various purposes, including conducting clinical studies, collaborating on projects, engaging in commercial activities, carrying out scientific research, analyzing market trends, and enhancing our pharmaceutical products. The nature of your interactions with us, our collaborators, or external data sources may lead to the processing of different types of personal information. We have highlighted the primary categories of personal information we may collect from you, as well as any sensitive personal information, where relevant. We may collect the information listed below when you access our Sites for the purposes described in the “How Do We Use and Share Your Information?” section of this Policy.
| Category | Description |
|---|---|
| Contact Information | We may collect your full name, personal or professional mailing and email addresses, phone numbers, and other contact details about you, your organization, or employees. We use this information during interactions or communications with you, sharing news or materials, and inviting you to participate in our activities. |
| Identifiers | We may collect your full name, initials, date of birth, photographs, and government-issued identification (such as driving licenses, passports, professional licenses, or government ID numbers). This information is used to provide you with relevant information about our products or diseases and to verify your professional qualifications. |
| Financial Information | We may collect payment-related information, such as bank addresses or account details, tax information for business purposes, and information about you, your relatives, connections, suppliers, or third parties. This information is used for conflict-of-interest verification, due diligence, compliance with anti-bribery laws, and billing purposes during collaborations or service provisions. |
| Professional and Background Information | We may collect information on the city and country where you practice, date and nature of payments made to you or your organization, information related to your organization and staff, and information about payments and services provided to us. This information is generally made publicly available on our websites. |
| Categorization and Classification Data | We may use your personal information to classify, organize, rank, or create profiles relating to you as a healthcare professional. This includes data about your professional history, background, recognitions, and number of publications. |
| Publicly Available Information | We may obtain information about you from public sources, registries, or third-party databases for pharmacovigilance reporting purposes and personalizing interactions with you. |
| Multimedia Data | We may use media content, including personal information such as pictures, photographs, audio or video recordings, from events, programs, interviews, or other initiatives that we organize. |
| Information Technology-Related Data | We may collect data from your use of our Sites, including IP address, geolocation data, device information, browser, operating system, data captured through cookies and similar tracking technologies, and information about the date and time of your request. |
| Sensitive Data | In limited circumstances, we may collect health data, sensitive personal information, driver’s license numbers, social security numbers, or bank account numbers for identification, accessibility, safety, security, fraud prevention, or detection purposes. |
| Other Categories | For all other categories of data we collect through our Sites, please see our User Privacy Policy (https://www.celltrionconnect.com/hcp-privacy-policy). |
You have the choice to not provide us with personal information. However, doing so may hinder or prevent us from establishing a relationship with you, such as being unable to deliver the services you request or fulfilling a contract for services that we have with you.
HOW DO WE COLLECT YOUR INFORMATION?
In general, we may collect your personal data through various methods, both directly and indirectly. The following non-inclusive list outlines the main ways we collect information about you.
Direct collection of data may occur when you:
Indirect collection of data may occur through:
We may also collect data when you:
Data may be obtained from other sources, such as:
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 Sites, and to perform similar analytics. We may also use first-party and third-party cookies and similar technologies on the Sites in order to otherwise tailor our communications with you.
Other Third-Party Technologies
Some content or applications, including advertisements, on the Websites are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third-parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with behavioral advertising or other targeted content.
We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
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 Sites. 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
We maintain an opt-out feature for the collection of cookies. For additional information about how you can opt out of cookies, you may refer to https://allaboutcookies.org/how-to-manage-cookies. Additionally, some web browsers, such as DuckDuckGo, do not collect cookies by default. By declining cookies or using a browser that does not permit their collection, you may experience some degradation or inconvenience in your use of the Sites.
You can learn more about internet advertising practices and related consumer resources at the following resources:
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 YOUR INFORMATION?
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.
LAWFUL BASIS FOR USING YOUR INFORMATION
| Legal Basis for Processing Personal Data | Examples of Activities |
|---|---|
| Legitimate Business Interest |
|
| Contractual Relationship |
|
| Compliance with Applicable Laws |
|
| With Consent |
|
Note: Consent can be withdrawn at any time. In such cases, processing of personal information will cease, and reasonable measures will be employed to limit or prevent further use of the information, including archiving, blocking, encryption, de-identification, anonymization, or erasure techniques.
HOW DO WE PROTECT YOUR INFORMATION?
We have implemented measures reasonably designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure; however, we cannot guarantee that data transmission or storage is 100% secure. If you have reason to believe that your interaction with our Sites is no longer secure, please immediately notify us at [email protected].
Importantly, the safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We highly recommend you do not share this password with anyone nor use it to access any other service. We also urge you to never conduct financial transactions on our Sites using public WiFi, as this can easily be intercepted.
Unfortunately, no transmission of information via the internet is completely secure. Although we do our best to protect your personal and financial information, we cannot guarantee the security of information transmitted to our Sites. Any transmission of personal or financial information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
WITH WHOM DO WE DISCLOSE YOUR INFORMATION?
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. |
| Third-Parties | We may provide information about you to third-parties that may offer products and services specifically requested by you, including authorized representatives and healthcare 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 Sites; 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?
We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements. Your information might be handled through both manual and automated methods and kept in our internal database for a duration as may be required by local jurisdictions, adhering to local regulations. The information may be retained for the period necessary to fulfill our legitimate business objectives, legal or contractual responsibilities, the storage duration specified in your consent, or for the establishment, exercise, or defense of legal claims. Once your personal information is no longer required for these reasons, it will be permanently removed.
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.
YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
We are committed to informing you about your rights and how you can exercise them. Generally, the rights you possess depend on your local jurisdiction’s laws and the legal basis we use to process your personal information. There might be certain exceptions regarding both the list of rights you have and your ability to exercise them.
Below are the rights you may exercise with respect to your personal information. You have a right to:
To exercise any of the above rights, please use the “Contact Us” details provided at the end of this Policy. We honor such requests when we are required to do so under applicable law. We may ask you to verify your identity before fulfilling your request. We are obligated to ensure that information is retained and, when legally required, disclosed securely. As a result, we must confirm your identity before responding to any request to protect your privacy and that of others. You may need to provide identification documents to verify your identity and/or authority to act on another’s behalf. Once verified, original identification documents will be returned, photocopies destroyed, and electronic copies securely deleted.
If complying with such a request would cause us or our affiliates to breach obligations under applicable laws, regulations, or codes of practice, we might not be able to fulfill your request. However, you could still request that we block or restrict your personal information from further processing. Additionally, you might have the right to data portability to another data controller, which generally means you can ask us to transfer information you’ve given us to another company or provide it to you.
Additional rights we afford you include:
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.
The California Consumer Privacy Act and the California Privacy Rights Act together give 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 Company’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 Company’s services where personal information is not sold.
If you are a California resident, you can exercise these rights by submitting a request to [email protected]. When submitting the request, please indicate that you are exercising your 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 verifiable request to us at [email protected] 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
This Policy only applies to Healthcare Providers’ use of the Sites, and it does not apply to any third-party websites or applications.
The Sites 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 Sites, 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 Sites to the external third-party website. You can check the URL to confirm that you have left the Sites.
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 Sites.
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 Sites are intended for users located in the United States, any information you provide to us through use of the Sites may be stored, 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.
STATE PRIVACY RIGHTS
This section pertains exclusively to information gathered about consumers in California, Colorado, Connecticut, Iowa, Utah, and Virginia. It fulfills the information requirements outlined in the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively referred to as “CPRA”), the Colorado Privacy Act of 2021 (“CPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Iowa Consumer Data Protection Act of 2023 (“ICDPA”), the Utah Consumer Privacy Act of 2022 (“UCPA”), and the Virginia Consumer Data Protection Act of 2021 (“VCDPA”). We also include a brief paragraph about information collected from Nevada consumers, which can be found at the end of this section.
CONSUMERS IN CALIFORNIA, COLORADO, CONNECTICUT, IOWA, UTAH, AND VIRGINIA HAVE SPECIFIC RIGHTS REGARDING THEIR PERSONAL INFORMATION, WHICH VARY DEPENDING ON THE STATE. TO EXERCISE THESE RIGHTS, RESIDENTS OF THE AFOREMENTIONED STATES MAY SUBMIT A REQUEST VIA THE “CONTACT US” SECTION AT THE END OF THIS PRIVACY POLICY. PLEASE NOTE THE RIGHTS OUTLINED BELOW MAY BE SUBJECT TO LIMITATIONS UNDER APPLICABLE LAWS AND REGULATIONS.
Data Rights: In accordance with applicable law, you may request access to the specific pieces of Personal Information we have about you or request more information about our data processing practices. You may also request the deletion of your Personal Information or the correction of any inaccurate Personal Information we have. Additionally, you can opt-out of processing Personal Information for targeted advertising by adjusting your privacy settings on the Sites. However, please note that we and/or our Vendors may still track your use of our websites. You may also have the right to opt-out of Personal Information processing for profiling purposes that produce significant legal or similar effects. If you want to appeal our decision on your data subject request, you may contact us at the address listed in the ‘Contact Us’ section of this Policy or by emailing us at [email protected], enclosing a copy or specific reference to the decision you want to appeal. Upon receipt of a verifiable consumer request to correct inaccurate personal information or to delete personal information about you, we shall use commercially reasonable efforts to correct the inaccurate personal information or delete the requested personal information. We will respond to your appeal according to applicable law.
Verification Request: To make a data subject request, you must provide your first and last name, email address, city and state of residence, and which specific right(s) you want to exercise. We will verify your request by comparing the information you provide with any identifiable information we may have about you.
Non-Discrimination: We will not discriminate against you for exercising your data subject rights. However, some functionality and features of our services may change or no longer be available to you. Any difference in the services will be related to the value provided.
Authorized Agent: If you wish to appoint an authorized agent to make a request on your behalf, you must create, sign, and authenticate a letter that clearly identifies your agent and the purposes for which they are appointed. As an authorized agent, you must provide us with the verification request information, described above, about the consumer on whose behalf you are acting, along with your own first and last name, email address, and a signed and notarized letter from the consumer authorizing you as their agent. We may ask you to verify your identity or confirm with us that you have the consumer’s permission to make the request. In some cases, we may decline your request if an exception applies under applicable law. We will respond to your request in accordance with applicable law.
Users with Disabilities: We strive to make our services available to all users. If you need to receive the information contained in this document in a different format, please contact us using any method described in the ‘Contact Us’ section below.
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.
The California Consumer Privacy Act and the California Privacy Rights Act together give 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 Company’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 Company’s services where personal information is not sold.
If you are a California resident, you can exercise these rights by submitting a request to [email protected]. When submitting the request, please indicate that you are exercising your 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 verifiable request to us at [email protected] 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.
UPDATES AND CHANGES TO THIS POLICY
We may add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. Any such changes, updates, or modifications will be effective immediately upon posting. The date on which this Policy was last modified is identified at the beginning of 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 Sites, and from time to time, so that you are aware of any changes. Your continued use of the Sites 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 Sites.
CONTACT US
For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you.
By Postal Mail:
Celltrion USA, Inc.
Attn: US Compliance
1 Evertrust Plaza
Jersey City, NJ 07302
By Email:
[email protected]
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.