Privacy Notice

SUNOVION PHARMACEUTICALS INC. U.S. PRIVACY & COOKIE NOTICE

(Updated and Effective: March 15, 2021)

Sunovion Pharmaceuticals Inc. ("Sunovion" or "we") is aware of its users’ concerns about their privacy when visiting our site. This notice explains what information we collect about users, how we collect that information, what we use the information for, who we disclose information to, and how users can exercise their rights with regards to the information. This website privacy notice is intended and designed for the exclusive use of citizens and residents of the United States. If you are visiting this site as a European resident, please refer to the privacy statement on our Sunovion Pharmaceuticals Europe Ltd website. Age restrictions may also apply. Please read this Privacy & Cookie Notice carefully and fully before using or submitting information on any of our websites. BY USING THIS WEBSITE, YOU AGREE TO BE BOUND BY THE TERMS OF THIS NOTICE AND THE TERMS OF USE.

California Residents: For additional information relating to California residents, please click on the California Residents Section.

Our privacy notice is organized in the following sections. For immediate access to a particular section, click on the title and expand the contents.

What Data Do We Collect and How Do We Collect It?

Information You Provide: Certain areas of our websites and online resources allow you to submit information to us. We may collect information that either directly identifies you or could reasonably be used in combination with other publicly available information to identify you, including your name, contact information, email address, and other information in combination with such identifiers (“Personal Data”).

Information We Collect Automatically:
We also automatically collect other basic information about you which does not directly identify you but which may correspond with you, your browser, or a particular device. This may include your internet protocol (IP) address, your internet service provider (ISP), information about cookies in your browser, geographic location and your software and hardware attributes (e.g., browser and device type). We also automatically collect information about how you interact with our website, including the duration of your visit, the actions you take, the pages you view, the time spent on our site, the top search terms used, and the most effective ad traffic campaign drivers. We automatically collect information using the techniques described below:

Cookies. Our website may use a tracking technology called a “cookie.” A cookie is a small data file that a website can place on your computer's hard drive, where your internet browser files are kept. Cookies enable a site to “remember” the information a visitor has previously inputted, or in some cases, certain other sites that the user has visited. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. Further information concerning the use of third-party cookies on our site can be found below, in the section titled "Analytics and Marketing."

Web Beacons. On certain web pages or in emails we send to you, we may utilize a technology called a "web beacon" (also known as an "action tag" or "clear GIF technology"). We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.

Social Plugins.
This site may use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with others. When you visit our site, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the associated social media website (e.g., Facebook) before browsing on our website, the social plugin allows that social media website to receive information about your visit to particular pages on our website. The social plugin may collect this information for any such visitors who have logged into social networks, whether or not they specifically interact with the plugin on our website (e.g., by clicking "Like" or "Share"). The social plugin may also allow the social media website to share information about your activities on our website with other users of their social media website. For more information about the information shared via a particular social media plugin, you should refer to that social media site's privacy statement.

Our Response to Do Not Track Signals: Certain web browsers and other programs may be used to signal your preferences to Sunovion about how or whether Sunovion or third parties may collect information about your online activities. Currently, our websites and online resources do not respond to such signals.

How do we use your Personal Data?

We may use and disclose the information you provide to send you requested information or other information we think may be of interest to you (including marketing communications), respond to your inquiry, improve our website, verify your relationship with us, and take other actions that may be necessary to respond to your request or fulfill the terms of a contract we have with you. We also use this information within Sunovion to improve our products and communications, or to develop new products, services, and communication strategies.

Analytics and Marketing
We use certain services to analyze information we collect automatically about visitors to our sites. We use and disclose the information we automatically collect to learn more about how our website and online resources are used and to otherwise improve and administer the site. We also use and disclose this information to enable us to deliver information and advertisements tailored to your interests and preferences, based on your use of the site.

Certain services, such as Google Analytics and others, may be managed by service providers to Sunovion. They may use cookies and automatically collect additional information, including your IP address, about your visit to and use of our sites.

In addition, our sites use service providers, including ad networks and third-party vendors to engage in marketing initiatives and provide you with advertising and content (both on and off Sunovion’s sites) that may be of interest to you. These services use cookies and may automatically collect additional information, including your IP address, when you visit our sites. This information is used to tailor content and advertisements to your interests both on and off our sites.

Opting Out of Certain Analytics and Marketing Activities

TThe Digital Advertising Alliance maintains a website where consumers can opt-out from receiving interest-based advertising from some or all of the advertising companies participating in the program (www.AboutAds.info/). The Network Advertising Initiative also maintains an opt-out page (http://optout.networkadvertising.org) where consumers can opt-out of receiving interest-based advertisements from companies participating in that program.

You may find information about Google Analytics and Google's privacy notice by visiting Google's website here: https://www.google.com/policies/privacy/partners/. If you would like to opt-out of having your data used by these cookies, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/. This opt-out applies only to Google Analytics and will not affect the functioning of other forms of analytics.

In addition, most internet browsers allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it, or to automatically refuse all cookies. Please be aware that some functionality on some of our websites and online resources relies on the use of cookies and may not be available should you choose to refuse all cookies.

Combining Information:
Where permitted by law, we may combine the information we collect automatically with other information you share with us through this website. Where permitted by law, we may also combine information collected through our website and online resources with Sunovion’s offline records and information provided by third parties. We use this consolidated information to improve our website and online resources, enhance our marketing activities, better design our offerings, and facilitate other business functions.

Does Sunovion Share Your Information with Third Parties?

Sunovion may share your Personal Data as follows:

Affiliates: We may share the information we collect with our affiliates, including our parent company, our subsidiaries, and other affiliated entities.

Service Providers: We may disclose information to third parties who provide us with various business services, including monitoring and maintaining the website and preparing newsletters and mailings for the purposes described in this notice.

Business Partners: We may also share information with third parties with whom we are working to provide you with services or information.

Legal Purposes: We may also disclose information we collect in special cases, including when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interfering with our rights and property or those of any other person. We may also disclose information when we believe the law requires it and in any situation that involves threats to any person’s physical safety. We also disclose information where required by law, including when required by laws, court orders, or government regulations.

Transactions Involving Sunovion: If all or part of Sunovion is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no information that is transferred will be used or shared in a manner inconsistent with this notice without your consent. Your information may also be included among the assets affected by financing agreements undertaken by Sunovion. Your continued use of this website would, however, signify your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.

Aggregated Information: Sunovion may share aggregated or de-identified information about use of our sites for any lawful purpose, but such information will not identify you or any other individual personally.

California Residents

The following provisions apply to the Personal Data of California residents collected by Sunovion Pharmaceuticals Inc. These provisions supplement the other sections of this Privacy & Cookie Notice.

The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what Personal Data Sunovion collects about them, including whether it is being sold or disclosed to third parties. The CCPA also grants certain rights to California residents, including the right to delete their Personal Data (subject to certain exceptions) and the right to prevent Sunovion from selling their Personal Data. Sunovion Pharmaceuticals Inc. does not sell Personal Data about California Residents. Companies are also prohibited from retaliating or discriminating against consumers for exercising their rights under the CCPA.

CATEGORIES OF PERSONAL DATA THAT WE COLLECT AND DISCLOSE
All companies need to collect and share consumers’ Personal Data for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons. The below table provides the information required under the CCPA and applies to both Sunovion’s online and offline activities. Please review the Consumer Type below that applies to your relationship or interaction with Sunovion to learn about the categories of Personal Data we have collected about you in the preceding 12 months, along with the categories of third parties with whom we share the Personal Data. If you interact with Sunovion in more than one way, please review each Consumer Type below that applies to you in order to learn about the Personal Data we collect and how we use and share it in connection with each particular relationship.

Categories of Personal Data We Collect

CA Consumer Type

Third Parties to Whom We May Disclose Personal Data

Name, Contact Information and Identifiers: Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Website Visitors
Building Visitors
Patients/Consumers
Conference/Event/Meeting Attendees
Healthcare Professionals

Service providers
Data analytics providers
Operating systems and platforms
Government Entities

Network Activity Data: Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

Website Visitors

Internet Service providers
Data analytics providers
Operating systems and platforms
Other service providers

Biometric Information: Information in possession of or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment.

Patients/Consumers

Service providers

Medical Information: including an individual's physiological, biological, or behavioral characteristics (including DNA) to the extent it can be used to establish individual identity. Biometric information consists of, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template (such as a faceprint, a minutiae template, or a voiceprint) can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Patients/Consumers
Conference/Event/Meeting Attendees

Service providers
Government Entities

Professional and/or Educational Information: An individual’s professional, employment-related, education information, including academic information and records.

Healthcare Professionals
Patients/Consumers
Conference/Event/Meeting Attendees

Service providers
Government Entities

Profiles and Inferences: Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies).

Healthcare Professionals
Patients/Consumers

Service providers

Commercial Information: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Healthcare Professionals
Patients/Consumers

Service providers

Electronic and Sensory Data: Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call or profile photograph).

Patients/Consumers
Healthcare Professionals

Service providers

Protected Classifications: Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion.

Website Visitors
Patients/Consumers
Healthcare Professionals
Conference/Event/Meeting Attendees

Service providers

Written Signature:

Patients/Consumers
Healthcare Professionals
Business Visitors

Service providers

Individual Rights
You have the following rights under the CCPA with respect to your Personal Data:

  • Right to Notice. Before or at the time we collect Personal Data from you, you have the right to receive notice of the Personal Data to be collected and the purposes for which we use it. This Supplemental Notice is intended to satisfy this requirement.
  • Right to Know. You also have the right to request that we disclose to you the categories of Personal Data we have collected about you in the preceding 12 months, along with the categories of sources from which the Personal Data was collected, the purpose for collecting or selling the Personal Data, the categories of third parties with whom we shared the Personal Data, and the categories of third parties with whom we sold the Personal Data.
  • Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of Personal Data we have collected about you in the preceding 12 months.
  • Right to Deletion. You have the right to request that we delete the Personal Data we collect from you. However, in certain situations we are not required to delete your Personal Data, such as when the information is necessary in order to complete the transaction for which the Personal Data was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Data internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Opt-Out of the Sale of Personal Information. Sunovion does not sell your Personal Data
  • Right Not to be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.

You can exercise any of your rights by clicking here or calling 888-394-7377 (menu option #5).

Verification Process. We value the security and confidentiality of your Personal Data. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected Personal Data. We verify every request carefully. You may also authorize someone else to submit these requests on your behalf. To do so, you may designate directly with us another person who may act on your behalf by providing us with a notarized copy of power of attorney or ask the authorized agent to provide us with a copy of your written permission and a scanned copy of their own government-issued ID.

You have the right to be free from discrimination or retaliation for exercising any of rights under the CCPA. We may, however, charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Sunovion by your Personal Data. Further, we may offer you financial incentives in return for your Personal Data.

Will Sunovion Transfer Your Information Internationally?

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

Is the Website Intended for Children?

Our website and online resources are not intended for or directed towards children. We do not knowingly collect personally identifiable information from children under 16 years of age. If you have reason to believe that a child under 16 has provided us with personally identifiable information, please contact us at privacy@sunovion.com.

How Can You Control and Update Your Personal Information with Sunovion?

Sunovion wants to keep only accurate information about you. You may update your Personal Data and your preferences at any time. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. These contact options are typically available on our Sites or in the emails or texts we send. If you have any difficulty finding these tools or otherwise updating your data preferences, you may contact our Privacy Officer for assistance using the methods outlined below in the Contact Us Section.

Updating or Correcting Your Information: To update or correct your contact information, please complete this form.

How Does Sunovion Keep Your Information Secure?

We maintain reasonable technical, administrative and procedural measures to protect your information from unauthorized access or use. However, no website, server, or database is ever completely secure, error-free, or “hacker proof.” In particular, email sent using this website or another online resource may not be secure. Therefore, we cannot guarantee that your information will not be disclosed, misused, or lost by accident or by the unauthorized acts of others. You should take special care before deciding to send us information via email. If you create an account on Sunovion’s site, it is your responsibility to protect your access credentials from unauthorized access or use.

Is Sunovion Responsible For The Websites It Links To?

We do not endorse and are not responsible for the content of third-party websites or resources. Our This Privacy and Cookie Notice does not apply to any sites that are not affiliated with Sunovion, even if you access them via a link on our site. You should review the privacy policies of any third-party site before providing any information.

How Can You Contact Us?

If you have questions about this privacy and cookie notice, our data collection practices, or your rights, please complete this form, or write to:

Sunovion Pharmaceuticals Inc.
Attn: Data Protection Officer, Legal Affairs
84 Waterford Drive
Marlborough, MA 01752

or

call: +1-877-394-7377 and select (menu option #5)

What Else Do You Need to Know?

We reserve the right to amend this notice at our discretion. When changes are made, we will post the updated notice and the date of the revision. By continuing to use the Sunovion website after the posting of such changes, you accept the notice as modified.