Data Controller, Data Protection Officer, and Representative
Interscope is the data controller of the Personal Information you provide through the Online Services.
Information Collection and Use
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
Below are the types of Personal Information that we might collect from you.
A. Information you provide
We and our Service Providers (defined below) collect information that you choose to provide to us when you use the Online Services by which you may be personally identified, including when you register to access the Online Services, sign up to receive emails or other communications, apply for a job, report a safety-related event related to one of our products (e.g., an adverse event, use during pregnancy or lactation, suspected interaction with other products, treatment errors such as overdose, usage outside the conditions in the label), or otherwise contact us with a question, comment, or request. This can include, but is not limited to: (a) your name, contact information, sex, and other registration information; (b) health information; (c) information you provide when submitting an employment application form; and (d) information you provide us when you contact us. If you report an experience or reaction involving one of our products, we may ask you for additional information, for example, to help us meet our reporting obligations under existing federal law. Any information collected about you from the Site can, from time to time, be associated with other identifying information we have about you.
If you are a medical professional and are using the Online Services for reasons other than reporting a product experience, you should make sure that you do not disclose identifiable information about your patients where not authorized by law.
B. Information automatically collected from you
We and our Service Providers (defined below) automatically collect certain technical information from your computer when you navigate through and interact with or as you use the Online Services that is about you but individually does not identify you, such as your Internet Protocol address, your browser type, your operating system, the pages you view through the Online Services, the pages you view immediately before and after you access the Online Services, the length of time that you spend using the Online Services, and the search terms you enter through the Online Services. This information allows us to recognize you and personalize your experience if you return to the Online Services using the same computer, and to improve the Online Services and the services we provide. We and our Service Providers (defined below) may collect this information using “cookies,” which are small text files that the Online Services save on your computer using your web browser and access when you return, web beacons, tracking pixels, or other technologies. From time to time, we may use or augment this information with information obtained by third parties.
C. Information from outside sources
In certain instances, we collect information about you from other sources, such as information about physicians or other health care professionals who register with the Online Services in order to verify their licensure status and identity.
Lawful Basis for Processing Your Personal Information
We have a lawful basis for our processing of your Personal Information, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, as required by law, and with your consent.
If you are in the European Union, the processing of your Personal Information is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
Legitimate Interests. We will process your Personal Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Information if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between us and you; detect and correct bugs and to improve our Online Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; perform employment screening and to manage our workforce, assets, and business; develop our product and services;
As Required by Law. We may also process your Personal Information when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
Special Categories of Information
We may process some Personal Information considered sensitive when necessary to carry out our obligations under the law or to protect our legitimate interests.
Some Personal Information processed by us may be considered sensitive, including personal data concerning your health. We processes this information only to the extent necessary to carry out our obligations under the law or to the extent necessary to protect our legitimate interests.
Use of Data
We use your Personal Information for various purposes described below, including to:
provide our Site to you;
provide you with information you request from us; • enforce our rights arising from contracts;
notify you about changes; and • provide you with notices about the Online Services
We use the information we collect about you or that you provide to us:
to present our Site and its contents to you;
providing you with products, services, or information you request, such as sending you investor information or processing your employment application;
creating customized offers, information, and services tailored to your interests and preferences;
sending you emails containing newsletters or other information that may be of interest to you;
providing you with information about the Online Services or required notices;
investigating safety-related events arising from the use of our products, provided that if you report to us a safety-related event through our forms set up for this purpose for patients or healthcare professionals, we will only use the data you provide through the forms to contact you and to comply with the applicable laws regarding this type of information;
customizing your experience when using the Online Services, such as by providing interactive or personalized elements through the Online Services and providing you with content based on your interests;
allowing us to improve the Online Services and the products and services we provide, such as by better tailoring our content to our users’ needs and preferences;
generating and analyzing statistics about your use of the Online Services; and
detecting, preventing, and responding to fraud, intellectual property infringement, violations of any terms of us, violations of law, or other misuse of the Online Services.
We also may combine or aggregate any of the information we collect through the Online Services or elsewhere for any of these purposes.
Disclosure of Personal Information
our subsidiaries and our affiliates;
our third-party service providers that we use to support our business;
to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and with your consent.
We do not sell or otherwise disclose any Personal Information, including your name, contact information, government identifier, or any other information associated with those data elements, we collect about or from you through the Online Services to any third parties without your consent, except as follows:
to our affiliates and companies and individuals that provide services to us and on our behalf (“Service Providers”) including, but not limited to, service providers such as background check vendors that evaluate your eligibility for employment opportunities to which you apply, data analysis firms, email and SMS vendors, web-hosting and development companies, and our webmasters, attorneys, auditors, and others who are hired to analyze the data collected through the Online Services, provided that such Service Providers are bound by contractual obligations to keep Personal Information confidential and shall only use the information to carry out the function being provided for us or on our behalf;
as required by law including, but not limited to, to comply with a subpoena or other legal process, regulatory requirement, judicial proceeding, or court order served on us, to comply with government reporting obligations such as disclosing information you submit about your personal experiences with one of our pharmaceutical products (investigational or marketed) to the Competent Authorities and the Federal Food and Drug Administration pursuant to federal regulations;
to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all or a portion of our assets.
We occasionally disclose aggregate or anonymized data that is not personally identifiable with third parties.
Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Information, restrict how it is used, transfer certain Personal Information to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Information about you. You also have the right to complain to a supervisory authority about our processing of your Personal Information.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Information.
Access and Update. You can review and change your Personal Information by logging into the Online Services. You may also notify us through the Contact Information of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Information under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Information is determined to be unlawful, or if we no longer need your Personal Information for processing but we have retained it as permitted by law.
Portability. To the extent the Personal Information you provide to us is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Information to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Information is based on your consent, you may withdraw your consent at any time. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Information.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee subject to a maximum set by applicable law.
Consent to Processing of Personal Information in the United States
We may process your Personal Information outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Information.
If you are a resident of the European Economic Area (“EEA”), in order to provide Online Services to you, we may send and store your information outside of the EEA, including to the United States. Accordingly, your information may be transferred outside the country where you reside or are located, which may not provide the same level protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in United States. In addition, we may transfer your information outside of the United States to our affiliates, business partners, and Service Providers located in other countries. By using the Online Services, you consent to such transfer to, and processing in, the United States and these other countries.
Links to Other Websites
We do not control the collection and use of your information collected by third parties.
The Online Services may contain tools, technology or links to websites provided by third parties. We do not control the collection and use of your information collected by third parties. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
We use tracking technology to customize and improve your user experience with our Site, services and offerings and for our advertising to you.
We often collect information about you by using cookies, tracking pixels and other technologies. We use this information to better understand, customize and improve user experience with our Site, services and offerings, as well as to manage our advertising. For example, we use web analytics services that use these technologies to gather information to help us understand how visitors engage with and navigate our Site, e.g., how and when pages in a site are visited and by how many visitors. We are also able to offer our visitors a more customized, relevant experience on our sites using these technologies by delivering content and functionality based on your preferences and interests. Cookies are files with small amount of data, which may include an anonymous unique identifier.
Depending on their purpose, some cookies will only operate for the length of a single browsing session, while others have a longer life span to ensure that they fulfill their longer-term purposes. Your web browser can be set to allow you to control whether you will accept cookies or reject cookies, to notify you each time a cookie is sent to your browser, or to delete cookies that have already been set. If your browser is set to reject cookies, certain aspects of the Site that are cookie-enabled will not recognize you when you return to the website, and some Site functionality may be lost. The “Help” section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies you may visit http://www.aboutcookies.org.
Do Not Track Disclosures
We currently do not honor do-not-track signals that may be sent by some browsers.
Notice to California Residents
Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Information to for their own direct marketing purposes.
Under California law, California residents may request a list of all Personal Information and the third parties to whom we have disclosed your Personal Information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and would like to receive such a list, please contact us at email@example.com. For any such request, include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state and zip code. Please provide enough information for us to determine if this applies to you. You must also attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.
If you do not want to receive emails from us at any time you may click on the relevant link in an email you receive from us or by contacting us.
With your consent, we may also use your information to contact you about our own goods and services that may be of interest to you. If you no longer wish to receive emails from us, you can do so at any time by clicking on the relevant link included along with the emails you receive from us or by letting us know at the contact information provided below.
Our Online Services are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Online Services. We will remove any information about a child under the age of 18 if we become aware of it.
The Site is not directed to, nor do we knowingly collect information from, children under the age of 18. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our Online Services confidential.
We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Site. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. Moreover, we are not responsible for the security of information you transmit to the Online Services over networks that we do not control, including the Internet and wireless networks.
Keep in mind that any passwords, ID numbers, or other special access numbers you might use to access any part of the Online Services are your responsibility, so you should safeguard them carefully. You should take steps to ensure that the computer you are using is adequately secured and protected against malicious software. Without adequate security measures (e.g., secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data on the Online Services could be disclosed to unauthorized third parties.
Data Retention Periods
We retain your Personal Information for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and to comply with other legal requirements
We will retain your Personal Information for the entire time that you keep your account open. After you close your account, we may retain your Personal Information:
for as long as necessary to comply with any legal requirement;
on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
If you wish to contact us, you must contact both us and our representative through the contact information below or through the “Contact Us” page on our Site.
We are not responsible for third party websites/content/services that we do not own or control.
Where the Site contains links to third-party websites/content/services that are not owned or controlled by us, we are not responsible for how these properties operate or treat your Personal Information so we recommend that you read the privacy policies and terms associated with these third party properties carefully.
MKT-0035 REV A