Privacy Policy

Please read this Privacy Policy carefully. This Privacy Policy applies to the website Compeedusa.com, and, as and where available, mobile applications, all of which are owned and operated by Laboratoire HRA Pharma SAS, and any of its affiliated entities (collectively, “HRA Pharma”). We refer to this website and, when and as available, mobile applications (the “Apps”), collectively as the “Platform” and together with the information, goods and/or services made available to users of the Platform, relevant news, content, applications, and sponsored programs, advertising, email communications, and discussion forums (“Services”). References to “we” or “us” mean HRA Pharma including any company we control.

To protect your privacy and help you to make informed choices, this Privacy Policy explains our information practices, how you can choose how we use your data, and your rights regarding your data. If you do not agree with our policies or practices, regarding our treatment or use of your information, your choice is not to use the Compeedusa.com website.

HRA Pharma (“HRA Pharma,” “we”, “us” or “our”) respects the privacy of visitors to its websites and respects the interest that visitors to our websites have in understanding how we collect, use, and disclose their information through this website and all other websites, or online services which are linked to this Privacy Policy (collectively, the “Sites” or “Websites”).

In summary, we will only use your information:

  • To optimize our website performance; or
  • With your consent.

This is explained in more detail below.

By accessing or using this Site, and/or accepting our Terms of Use , you agree to this Privacy Policy. We may change this Privacy Policy from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you have any inquiries about this Privacy Policy or how we use your personal information, please contact us at dataprivacy@hra-pharma.com.

Privacy Quick Look

  • Anyone may browse our Website, Services and/or App, but you must provide personal information in order to register with the us and take full advantage of the Platform and its features.
  • We may contact you by email or SMS text, and by registering with us, you expressly consent to receiving email, or text messages from us.
  • When you visit or use the Platform, we set cookies on your Web browser so that we can recognize you and personalize our site to your preferences.
  • You can control the placement of cookies on your Web browser by your Web browser settings.

Contents

1. About us
2. Children Under the Age of 13
3. What information we collect and how we collect it
4. How we collect Personal Information
5. How and why we use Personal Information
6. How we share Personal Information
7. General Data Protection Regulation and the California Consumer Privacy Act of 2018
8. Data security
9. How long we keep Personal Information
10. Third party links
11. Accessing and correcting your information
12. Legal Disclosures
13. Changes to this policy or your data
14. Contacting Us

1. About Us

This website https://www.compeedusa.com is operated by HRA Pharma America, also referred to as the “Company”, “we”, “us” and “our”), a corporation organized under the laws of the state of New Jersey. We are a data controller.

Our offices are located at:

HRA Pharma America Inc.
36 Cattano Ave, Suite 400
Morristown, NJ 07960

You may contact us about any questions you have regarding this Privacy Policy at either our postal address above, or by e-mail directed to dataprivacy@hra-pharma.com.

2. Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may use or direct any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site, use any of its features, subscribe to our mailing list, use any of the interactive links or post anything on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use, or otherwise use the Platform. If we learn we have collected or received personal information from a child under 13 without verified parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, in connection with the access or use of this Site, please contact us at is dataprivacy@hra-pharma.com.

The Services provided by us through the Site and Platform include the provision of health care related information and associated products.

If you do choose to access the Platform and use the Services, you must agree to our Terms of Use which is the contract between us and you. By accepting our Terms of Use, you also confirm that you have read, understand, and accept this Privacy Policy. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States, where we are located. Except as may be otherwise be noted in this Privacy Policy, we are the data controller responsible for the processing of your personal information as described in this Privacy Policy.

3. What Information We Collect and How We Collect It

The type of information we collect depends on how you use the Site and our Services and how you interact with us. “Personal Information” means any data which can be associated with you as an individual, either directly or indirectly, and is collected on a voluntary basis from you.

The Personal Information we collect via the Site may include:

  • Identity information, such as your name, organization name and position, postal address, e-mail address, telephone number, biographical data, social media links, and/or any other identifier by which you may be contacted online or offline.
  • Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and/or platform, and other technology information relating to the devices you use to access the Site.
  • Usage data, which includes information about your use of the Site, and any communications we may receive from you.
  • Marketing and communications data, including your preferences in terms of receiving marketing and other communications from us.

The Site is not intended to store or transmit “special categories” of Personal Information, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information, or criminal convictions and offenses.

4. How We Collect Personal Information

We collect information from you in three different ways.

a) Personal Information you provide to us

If you subscribe (sign up) to our mailing list, inform us of your marketing and communications preferences, or post or submit any text, comments, photo, video, communication, information, submit customer care requests or inquiries, or other material (“User Content”) on or through the Site, you will provide us with your identity, contact information, and IP address. This data is collected through direct solicitation and your voluntary submissions. You will also provide us with Personal Information when you correspond with us. We may embed tracking codes in our regular daily email correspondence.

b) Personal Information we collect automatically as you navigate the Site

The Site presently does not, but reserves the right in the future, to use third party advertising providers to display advertisements based on your visits to the Site and other web sites you have visited, which allows targeted advertisements to be delivered to you for products and services about which you may be interested. The Site may also use a third party traffic measurement service to analyze how visitors use the Site, Third party advertising providers and advertisers (whose ads are displayed via the advertising provider) may use cookies, web beacons, embedded scripts (described below) or other similar mechanisms to automatically collect web site usage information, to, among other purposes, deliver advertisements, in which you might be interested, prevent you from seeing the same advertisements too many times, and to conduct research regarding the usefulness of certain advertisements to you. Cookies, web beacons and embedded scripts and other similar mechanisms used to collect web site usage information from advertising providers and advertisers, are governed by their respective privacy policy and not this Privacy Policy. We do not, however, share any Personal Information with these third parties in connection with the services they perform on the Site.

In addition, as you use the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyze user habits while visiting our Site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on our behalf. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

We may use any of the following cookies individually or in combination:

Cookie name What it is used for
Google Analytics website analytics and visitor tracking
Wordfence website security and access control
YouTube user viewing preferences

You can remove cookies from your computer through the browser settings. Please note however that doing so may affect, limit or degrade your ability to use of some features on the Site and other websites. Management of cookie settings varies from one browser to another, and the “Help” menu of your web browser should provide instructions how to manage cookies. For your convenience, the links below are to instructions provided by major web browsers relating to such management in those specific browsers:

 

c) Information You Provide to Third Parties. If you use the Site’s interactive features (where available) to communicate with other users, or to access a third-party site that is linked to the Site, the other user(s) or third-party site may provide us, directly or indirectly with your Personal Information. For example, another user may post your email address and name, or a third-party website may report a purchase you made from that site.

5. How and Why We Use Personal Information

a) You have given us permission to do so
If you subscribe to our mailing list, we will send you updates and marketing information that you have consented to receive. Similarly, if you contact us with a question or comment, we may need your contact, identity, technical and/or usage information to respond.

b) We have a legitimate interest (reasonable business purpose) for doing so
We will use your information for our legitimate business reasons, where doing so will not unduly affect your rights. As such:

  • We will use your identity, contact and usage information to keep our records up to date.
  • We will use your technical information to:
    • Make the Site available, to improve it, to conduct system maintenance, support, troubleshooting, reporting and to host data;
    • Ensure that the Site is secure;
    • Analyze how users interact with the Site;
    • Address technical issues you may experience with the Site.

We may also use any or all of the information above to administer and manage our business in general, which include engaging in “Know Your Customer” and anti-money laundering checks or other activities as required by law, regulation, or best business practices. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

c) We need to comply with a legal or regulatory obligations
In certain circumstances, we may need to retain or use your data to comply with laws or regulations to which we are or may become subject.

6. How We Share Personal Information

We may share your information with our trusted third-party service providers (including information technology providers such as website and mailing list hosts). We may provide your account information to companies that help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.
When we share your information with our service providers, we will take commercially reasonable steps to help ensure that your data is kept secure and used only in accordance with this notice.
We may share Personal Information when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government investigation or inquiry), to detect, investigate and defend against fraudulent or unlawful activity and violations of our Terms of Use , to enforce or apply our Terms of Use or other agreements, in the context of a Company reorganization, or to protect the rights, property, or safety of the Company, our employees, users, or others.

Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity and violations of our Terms of Use.

7. Data Security

The safety of your Personal Information is important to us, and we use various technical and organizational measures to secure it.

We employ commercially reasonable encryption (TLS technology), data security, and intrusion prevention technologies to protect and secure all personal information in our possession. Our data environment is monitored 24/7 for malicious activity and/or anomalous behavior either of which triggers our incidence response. However, the transmission of information via the Internet is not completely secure, and unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Although we take commercially reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You acknowledge and agree that you are solely responsible for maintaining the security and confidentiality of your account username and password.

8. How Long We Keep Personal Information

We will retain your Personal Information only for as long as it necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we processed the data and whether we those purposes may be achieved by another means, and the applicable legal requirements.

We will retain your Personal Information only for as long as it necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

9. Third Party Links

This Site may contain links to other websites whose information practices may be different than ours. Please consult all third-party Sites’ privacy notices. We have no control and disclaim any and all responsibility and liability in connection with information that is submitted to, or collected by, third parties.

10. Accessing or Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page, or by sending an email to us at dataprivacy@hra-pharma.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Use.

11. Legal Disclosures

We may need to share your data when we believe it is required by law or to help protect the rights and safety of you, us, or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, We will attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

13. Changes to this Privacy Policy or your data

We may amend this Privacy Policy from time to time. We will post any update to this Privacy Policy on the Site. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy, we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

14. Contacting Us

If you have general questions about your account or the Services, contact us at dataprivacy@hra-pharma.com. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at dataprivacy@hra-pharma.com or at the following address:

HRA Pharma Headquarters
Attn: Legal Dept
200 avenue de Paris
92320 Chatillon
France

Notice to California Residents/Your California Privacy Rights

California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year (e.g., responses to requests made in 2020 will contain information about 2019 sharing activities).

We do not share personally identifiable information about you to third party direct marketers. What we may share with third party direct marketers is a cryptographic hash value derived from your information. That hash value cannot be reasonably associated with your personal information.
California residents may request further information about our compliance with this law by sending a request to the address set forth in the Contact Us section below. You must include “California Privacy Rights” in the subject line, and your full name, email address, and postal address in your request.

Please note that under California law, businesses are only required to respond to a customer request once during any calendar year, and we are not required to respond to requests made by means other than through this physical mailing address.

California Consumer Privacy Act of 2018

This Privacy Notice for California Residents supplements the information contained in the Notice to California Residents/Your California Privacy Rights and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

You understand and agree that this CCPA supplemental notice incorporates the arbitration agreement provisions set forth in our Terms of Use, including a waiver of any rights to class-wide arbitration.

Information We Collect

The Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”), but does not include in particular,
Publicly available information from government records,
Deidentified or aggregated consumer information,

  • Information excluded from the CCPA’s scope, like: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the California Financial Information Privacy Act (FIPA); and Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, physical characteristics or description, address, telephone number, and payment card information. Some personal information included in this category may overlap with other categories. Yes
C. Internet or other similar Platform activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes
D. Geolocation data. Physical location or movements. Yes

Personal information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregated consumer information;
  • Digital images or photographs not used for identification;
  • Information excluded from the CCPA’s scope, for example: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

The Platform obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete, products or services you purchase, or information you choose to post or share.
  • Indirectly from you. For example, from observing your actions on the Platform.

Use of Personal Information

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

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
  • To provide, support, personalize, and develop our Platform, products, and services;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud;
  • 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 Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
  • 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 Platform users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose, but we do not sell your personal information to third parties. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Service providers, including customer service, payment processing, marketing and analytical services; and Data aggregators.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

A. Identifiers.
B. California Customer Records personal information categories.
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar Platform activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.

Sales of Personal Information
In the preceding twelve (12) months, Company has not sold the following categories of personal information:
A. Identifiers.
B. California Customer Records personal information categories.
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar Platform activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access , Data Portability , and Deletion Rights ) we will disclose to you:
The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
Our business or commercial purpose for collecting or selling that personal information;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you (also called a data portability request); and
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer request (see Exercising Access , Data Portability , and Deletion Rights), we will delete and direct our service providers to delete your personal information from our records, unless an exception applies.
Even if verifiable, we may nonetheless deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
You may exercise the access, data portability, and deletion rights described above by submitting a verifiable consumer request to us using one of the following options:

Calling us at 833-426-6733
Sending an email to dataprivacy@hra-pharma.com.
Using one of the on-line CCPA request forms linked below.

ON-LINE CCPA REQUEST FORMS

To exercise the right to access your personal information stored by us, you may submit a request to us by visiting:

ACCESS TO MY PERSONAL INFORMATION

To exercise the right to obtain a copy of your personal information stored by us, you may submit a request to us by visiting:

EXERCISE PERSONAL INFORMATION PORTABILITY 

To exercise the right to delete your personal information stored by us, you may submit a request to us by visiting:

DELETE MY PERSONAL INFORMATION 

Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your information to third parties. If you are 16 years of age or older, you have the right to direct us to not sell your personal information in the event our practices change in the future (the “right to opt-out”). For consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, we will not sell your information in the event our practices change in the future.
In order to exercise the right to opt-out of personal information sales by us, you (or someone legally authorized) may submit a request to us by visiting:

DO NOT SELL MY PERSONAL INFORMATION
As noted above, we do not sell your information to third parties. We will retain your opt-out request in the event our practices change in the future. Should your email address change, please submit a new request with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Verification Requirement for Requests
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access, data portability, or deletion 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.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We will acknowledge receipt of your request within 10 days and will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will notify and inform you of the reason and extension period in writing.
If we receive a request to opt-out from you, we will act upon that request within 15 days from the date we receive that request.
If you have an account with us, we will deliver our written response to that account electronically. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g., an excel spreadsheet that has been converted into a changed-locked pdf).
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. To make such a request, please send an email to dataprivacy@hra-pharma.com.

Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Platform and update the notice’s effective date. Your continued use of our Platform following the posting of changes signifies and constitutes your acceptance of such changes.

Notice to Nevada Residents/Your Nevada Privacy Rights

Under Nevada SB 220, Nevada residents have the right to opt out of the sale of their Covered Information (as such term is defined under Nevada law). As noted above, we will not sell your information. However, if you are a Nevada resident, you may submit a request to opt out of future sales by us by writing to us at dataprivacy@hra-pharma.com. We will maintain your request in the event our practices change in the future. Should your email address change, please submit a new request to dataprivacy@hra-pharma.com. with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.

Notice to European Residents/General Data Protection Regulation (GDPR)

More Information: https://gdpr.eu/
This Site is hosted on servers located in the United States. We endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR” and, as and where applicable, the California Consumer Protection Act of 2018) to which we may be subject.

The General Data Protection Regulation (“GDPR”) was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”). Its purpose is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the:

  • Right of access: Individuals can ask for a copy of the Personal Information retained about them and an explanation of how it is being used.
  • Right to rectification: Individuals have the right to correct, revise or remove any of the Personal Information retained about them at any time.
  • Right to be forgotten: Individuals can ask to delete their Personal Information. At your request, we will remove your contact information from the system, and we will not contact you again.
  • Right to restrict processing: If an individual believes, for example, that their Personal Information is inaccurate or collected unlawfully, the individual may request limited use of their Personal Information.
  • Right of portability: Individuals have the right to receive their Personal Information in a structured, commonly used and machine-readable format.
  • Right to object: Where an individual decides that they no longer wish to allow their Personal Information to be included in analytics or to receive direct marketing emails or other personalized (targeted) marketing content at any time, the individual may opt out of use of their data for these purposes.

If you are a data subject falling under the scope of the GDPR, you can exercise the above rights. Please note that these rights are not absolute, and limitations/exceptions may apply in some cases.

You also have the right to lodge a complaint with the National Information’s Commission, “Commission Nationale de l’Informatique et des Libertés” (“CNIL”), which is the French supervisory authority for data protection issues (www.cnil.fr). We would, however, be grateful if you would contact us in the first instance so we can endeavor to deal with your concerns direct.

In respect of transfers outside of the Company, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your Personal Information; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield, as applicable.

You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.

If you wish to exercise any of these rights, please contact us at dataprivacy@hra-pharma.com
or by postal mail by enclosing a copy of your ID card at:

HRA Pharma Headquarters
Attn: Legal Dept
200 avenue de Paris
92320 Chatillon
France

Contact Us

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection, storage, disclosure and use practices, please email or contact us at:

HRA Pharma Headquarters
Attn: Legal Dept
200 avenue de Paris
92320 Chatillon
France

1-833-426-6733; M-F, 8:00 a.m.-5:00 p.m. (Central), or email us at dataprivacy@hra-pharma.com.
Any personal information you provide to the above email or postal mail addresses will not be used to send you promotional materials, unless you request it.

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