Privacy Policy

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.

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.

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:

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.

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.

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.

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.

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.

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.

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