Privacy Notice

LEO PHARMA INC.

Last Updated on July 1^st, 2024

 

This Privacy Notice describes how LEO Pharma Inc. (“LEO” or “Company”) collects, uses, and discloses, and otherwise processes your personal information in connection with this website and any of our other websites, mobile applications, or online services that link to this Privacy Notice (collectively referred to as the “Sites”). LEO is committed to maintaining the privacy and security of your personal information. Please carefully read this Privacy Notice.

 

Sources of Personal Information

We may obtain personal information from the following categories of sources:

 

Information you choose to provide to us. We may collect personal information from you when you voluntarily provide it to us through our Sites or otherwise share with us. For example, this can include information you provide when completing online form; from information you provide when you agree to take part in a LEO meeting, event or clinical study; from information you provide with regard to medical, safety or product quality information; or information you provide in relation to services for which you register or purchase.

 

Information we collect automatically. We may automatically collect personal information about you, such as site usage information or information about your computer or mobile device, when you access our Sites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, and access times and information about your use of, and actions on, our Sites. We collect this information about you by placing cookies on our Sites. Please refer to the section Cookies and Other Technologies below for more details.

 

Information we obtain from third-party service providers. We may obtain demographic data from a third-party service provider to use for marketing analytics. We may also obtain personal information from publicly available registers and third-party providers that specialize in the provision of personal and professional information about healthcare professionals who have agreed to have such data shared with pharmaceutical companies.

 

Information we obtain from social networking Sites. We may maintain pages on social networking sites (each a “SNS”), such as Facebook, LinkedIn, Twitter, Google, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy notice applies.

 

Our Sites may include interfaces that allow you to connect with SNS. If you connect to a SNS through our Sites, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Privacy Notice. You can revoke our future access to the information you provide to us through a SNS at any time by amending the appropriate settings within your account settings on the applicable SNS.

 

Personal Information We Collect

LEO collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We may collect or obtain the following categories of personal information about healthcare professionals, patients, caregivers, website visitors or others who choose to share their personal information with us. Please see How We Use Personal Information for more information about why we collect the categories of information below.

 

Category	Examples of Information We Collect
Personal and Business Contact Information	First and last name, postal address, phone number and email address (together “Contact Information”), age, gender, insurance information.
Health-Related Information	Patient medical condition, treatment and prescription details.
Education Information	Academic background
Professional Credentials	License number, NPI number, professional or employment-related information, areas of practice, professional affiliations.
Financial Information	Social Security number, tax ID, bank account number, and other financial information.
Feedback and Correspondence	Information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Sites, receive customer support or otherwise correspond with us.
Commercial Information	Preferences related to receiving our marketing communications and other transactional data pertaining to our products.
Internet or Other Similar Network Activity	Information about how Sites visitors browse or search our Sites, for our brand, or for our products, including Internet Protocol addresses and device identifiers. See Cookies and Other Technologies below.

 

Cookies and Other Technologies

 

How We Use Tracking Technologies

In an ongoing effort to improve the Sites and our services, we automatically collect certain information when you visit the Sites and/or use the services. We may automatically collect information using the following automatic data collection technologies:

 

• Cookies. A “cookie” is a text file that Sites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Such information includes without limitation, your IP address, Internet service provider, device identifier, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Sites you visit, number of links you click while on the Sites, search terms, operating system, website traffic and related statistics, keywords, key word searches and/or other data concerning your use of the Sites and/or the services. By virtue of their operation, cookies fall under the following categories:
  • Strictly Necessary Cookies. These cookies are required for the operation of our Sites. These cookies cannot be switched off. You can set your browser to block these cookies, but as a result, some parts of our Sites will not work as designed.
  • Functionality Cookie. These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you from having to re-select your preferences every time you visit our Sites.
  • Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered may include the number of visitors to our Sites, the Sites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather demographic information and to monitor the level of activity on our Sites.
• JavaScript Tags. JavaScript tags, also known as pixels, trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist). We may use JavaScript tags to help us tailor and optimize our Sites and provide you relevant LEO advertisements outside of our Sites. The information we collect using pixel tags is not linked to our users’ personal information.
• Web beacons. Web beacons, also known as “clear gif” technology, are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web site users. Unlike cookies, which can be stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We may use web beacons to help us manage information on the Sites by tracking what information is effective.

 

We also may use these technologies to collect information about your online activities over time and across third-party Sites or other online services (behavioral tracking). The information we collect automatically is statistical data and may not include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.

 

Information on Google Analytics

We may use Google Analytics, a vendor’s service that uses cookies, web beacons, pixels, and/or similar technology, to collect and store information about you. You can learn more about Google Analytics’ privacy policy and ways to opt out from Google Analytics tracking at https://tools.google.com/dlpage/gaoptout. For more information on the use of personal data by Google Inc. please visit the Google privacy policy.

 

Disabling Cookies

You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our Sites may not work properly.

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://allaboutcookies.org/.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital advertising Alliance: https://optout.aboutads.info/?c=2&lang=EN
  • Network Advertising Initiative: https://optout.networkadvertising.org/?c=1.

 

How We Use Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop our Sites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, to confirm and communicate with you about appointments and products, and to prevent transactional fraud.
• To process grant applications.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Sites experience and to deliver content and product and service offerings relevant to your interests.
• To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop, improve and promote our Sites, products, and services.
• To assist coordinating insurance coverage for LEO products.
• To communicate with you about patient assistance programs or other topics related to LEO products.
• To comply with applicable laws, respond to lawful requests from government authorities and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred; or
• Any other purpose consistent with consent that you may provide.

 

In addition to these purposes, we may collect and process personal information of healthcare professionals, for the following purposes:

• To administer and manage professional and scientific activities (e.g., clinical research; medical information requests; safety and product quality concerns; use of and access to our products; professional meetings; market research surveys; awarding of grants);
• To promote our products and services, including communicating with you by electronic mail;
• To create a professional profile to enable us to better communicate with you and address your questions or concerns; and
• To comply with financial transparency and reporting obligations.

 

Sharing of Personal Information with Third Parties

In the 12 months preceding the date of this Privacy Notice, we may have shared personal information with the following categories of third parties:

• Service Providers. We may engage companies and individuals to administer and provide services on our behalf (including, but not limited to, training, customer support, website hosting, email delivery and database management services, contract research organizations, congress and event organizers, shipping and fulfillment providers). These third parties use personal information as directed by us and in a manner consistent with this Privacy Notice. Under applicable law, we are permitted to disclose personal information to service providers in accordance with written contracts, which require our service providers not to retain, use, or disclose that personal information for any purpose other than for the specific purpose of performing services under the contracts, or as otherwise permitted by applicable law, within the context of the direct business relationship between us and the service providers.
• Affiliates. We may disclose your personal information to our affiliates or subsidiaries for purposes consistent with this Privacy Notice.
• Professional Advisors. We may share your personal information to professional advisors such as lawyers, auditors and insurers, where necessary in the course of professional services that they render to us.

In addition, we may share personal information with government or law enforcement agencies or private parties as required by law or reasonably necessary to avoid harm. We also may share your personal information, at your request, to business partners that provide services selected by you.

 

Your Rights and Choices About Your Personal Information

 

Your Privacy Rights

LEO strives to keep your personal information accurate. We will provide you with access to your personal information, including making reasonable efforts to provide you with online access to your information for you to update in the event that any information we hold is inaccurate. You may also make a request to correct or update your personal information by contacting us directly. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make updates or corrections.

Residents of certain US States may be entitled to specific privacy rights. Depending on the law of your state of residence, you may have the following rights, subject to certain exceptions:

• Right to Know. You have the right to know the categories of personal information we have collected from you or the specific information we have collected; the sources from which the personal information is collected; your personal information we have sold or disclosed for a business purpose; the third parties to which your personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information.
• Right to Correction. You may request that we correct any inaccurate personal information we maintain about you.
• Right to Deletion. You may request that we delete any personal information about you.
• Right to Access Specific Pieces of Personal Information and Data Portability. You may ask to obtain the specific pieces of personal information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.
• Right to Opt-Out of Sale/Share of Your Personal Information. You may have the right to opt out of the sale, share, or use of your personal information for targeted advertising purposes, as such terms are defined under applicable privacy laws. You may exercise this right through the Your Privacy Choices link at the footer of every page on our Sites.
• Right to Revoke Consent for or Limit the Use of Your Sensitive Personal Information. You may have the right to revoke your consent for certain processing activities with respect to your sensitive personal information and/or the right to instruct us to limit the use and disclosure of your sensitive personal information to specific business purposes defined by law.
  • We may sell/share your sensitive personal information, as such terms are defined under applicable privacy laws. Our collection of certain forms of browser data via cookies may constitute sensitive personal information. You can limit our collection, use, and disclosure of this information by rejecting the use of cookies in our cookie banner pop up.
  • You may request that we limit the processing of your sensitive personal information by emailing us at us.privacy@leo-pharma.com, using our web contact page, or calling us on our toll-free number +1 877 494 4536.

 

Exercising Your Privacy Rights

You or your authorized agent may make a verifiable consumer request related to your personal information. You also may make a verifiable consumer request on behalf of your minor child.

To exercise your rights described above, please submit a verifiable consumer request to us by:

• Emailing us at us.privacy@leo-pharma.com
• Using our web contact page
• Calling us on our toll-free number +1 877 494 4536

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

 

Applicable law may require or permit us to decline your request. We will provide a response with the required information free of charge within 45 days of receiving a verifiable request (with an additional extension of 45 days if reasonably necessary). If we decline your request, we will inform you of such decision, subject to legal restrictions.

 

Opt-Out Preference Signal

Some web browsers or devices offer settings where you may pre-set a signal to Sites that you do not want to have your online activity and behavior tracked, sold, shared, or otherwise used for targeted advertising purposes. If you have indicated such a preference via an opt-out preference signal, we will do our best to honor it.

 

Non-Discrimination Disclosure

We will not discriminate against you for exercising any of your privacy rights.

 

Appeals

You may have a right to appeal a decision we make relating to requests to exercises your rights under applicable local law. To appeal a decision, please contact us at us.privacy@leo-pharma.com

 

Notice Concerning Processing of Consumer Health Data for Washington and Nevada consumers

This section applies to residents of Washington and Nevada. To know more about your rights regarding your Consumer Health Data, please visit our Consumer Health Data Privacy Policy.

 

More About Your Privacy

 

External Sites

The Sites may contain links to other Sites, including, but not limited to, investor relations sites, job applicant information gathering, assessment, and testing sites. These third-party sites have their own measures to secure and protect your information. This Privacy Notice and related Terms of Use do not apply to these third-party sites.

 

Security

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

 

Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from the Sites may not be secure, and you should therefore take special care in deciding what information you send to us via email. Therefore, you acknowledge and agree that we assume no liability regarding the theft, loss, alteration, or misuse of personal or other information or content, including, without limitation, such information that has been provided to third parties or other users, or with regards to the failure of a third party to abide by the agreement between us and such third party.

 

Website Communications

If you register on the Sites, we may send you certain notifications, advertisements, promotions, and other information, including but not limited to, service-related notices or notices regarding a change to any of our policies. You can opt-out of receiving certain communications from LEO, its successors, affiliated companies and/or its agents, including emails, postal mail, SMS, and phone calls relating to our products, Services, and programs, and/or disease awareness information. We may provide various ways to opt-out, which may include opt-out boxes on materials sent by regular mail and unsubscribe functions in emails. You cannot, however, opt-out of receiving transactional communications from LEO related to your account.

 

Changes to This Privacy Notice

This Privacy Notice is effective as of the date stated at the top of this Privacy Notice. We may change this Privacy Notice from time to time. Please be aware that, to the extent permitted by applicable law, our use of your information is governed by the Privacy Notice in effect at the time we collect the information. If you visit the Sites and/or use the Services after a change to this Privacy Notice is posted on the Sites, you will be bound by such change. Please refer back to this Privacy Notice on a regular basis.

 

Important Notices to Non-U.S. Residents

The Sites and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Sites, and/or the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States.

 

Children’s Privacy

As we are committed to protecting the privacy of children, we do not knowingly collect or sell personal information from anyone who is, to our knowledge, under the age of 16. If you are under the age of 16, please do not provide any personal information through the Sites, and/or the Services. LEO does not knowingly collect any personal information from children. Please do not allow children under the age of 16 to provide any personal information, ask questions, or submit information via the Sites. If you become aware that a child under 16 has provided personal information to LEO, please contact us as described in the How to Contact Us section, so that we can delete the information.

 

Retention of Information

We retain personal information as required or permitted by applicable laws and regulations and to fulfill the purposes described in our Privacy Notice. These purposes may include archival purposes, scientific research, statistical purposes, or other legitimate interests or business purposes consistent with this Privacy Notice.

When determining the appropriate retention period for personal information, we take into account various criteria, such as the amount, nature, and sensitivity of the personal information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your personal information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our Sites and Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

 

How to Contact Us

If you have any questions regarding this Privacy Notice, please contact us by emailing us at us.privacy@leo-pharma.com or using our web contact page. You can also write us at:

LEO Pharma Inc.
7 Giralda Farms – 2nd Floor
Madison, NJ 07940
USA