Effective Date: April 1, 2021.
This Privacy Statement applies to Boehringer Ingelheim USA Corporation and affiliates, subsidiaries and other operating companies within the United States, collectively “BI,” “We,” “Us,” or “Our.” Please read the following carefully. This Privacy Statement describes Our practices in connection with your Personal Information (as defined below) that We collect in the following ways:
• On Websites operated by Us, from which you are accessing this Privacy Statement, Our Apps and other software applications made available by Us for use online (collectively, the “Online Services”)
• On Social Media Pages and apps that link to this Privacy Statement
• In offline interactions you have with Us
In this Privacy Statement, We refer to Our Websites, Our Apps, Our Social Media Pages, and Our offline
activities collectively as the “Services.”
This Privacy Statement covers the following topics:
•
Personal Information
o How BI collects Personal Information
o Personal Information BI
collects
o How BI uses Personal Information
•
Marketing
•
Your Privacy Choices
•
Information BI Collects
through Our Online Services
o Automatic Collection of information
o How We use information
collected through Our Online Services
o Automatic Collection:
Opt-Out Choices
•
Security
•
Children’s Privacy
•
Additional Terms
•
Links to Other Sites
•
Mobile Apps
•
Website Tracking and Online
Behavioral Advertising
•
Data Processing
•
International Data Transfer
•
Data Retention
•
California Privacy Rights
•
Changes to the Privacy Statement
•
Contact Us
“Personal Information” means information that identifies you individually, such as your name, address, email address, or picture. In order to access certain features offered through Our Services, you may be asked to provide your Personal Information.
• Directly from individuals
• In connection with your use of Our Services
• From healthcare professionals
• From contract research organizations and clinical trial investigators
• From individuals enrolled in clinical trials
• From government agencies or public records
• From third party service providers, data brokers or business partners
• From industry and patient groups and associations
You may choose not to provide some of your personal information to Us, but this may prevent Us from providing Our Services to you, or limit Our ability to provide you with the level of service that you would otherwise expect from Us. From time to time, We may use or augment the personal data We have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, We may use such third party information to confirm or verify licensure of healthcare or veterinary professionals or to better understand your interests by associating demographic information with the information you have provided.
We may collect the following types of Personal Information:
· Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
· Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
· Health and medical information (such as information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency)
· Any information We collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing Our products, managing compassionate use and expanded access programs, and tracking adverse event reports
· Information regarding any parents or legal guardians
· Financial information to complete a transaction or determine eligibility for patient assistance programs
· Username and password that you may select in connection with establishing an account on Our websites or mobile apps
· Your photograph, social media handle or digital or electronic signature
· Publicly available information
· Internet activity, such as your browsing history, your search history, and information on your interaction with Our Services and advertisements;
· Information about your household including information about your pets
· Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, behavior, attitudes and abilities.
· Professional credentials, educational and professional history, institutional and government affiliations, and information included on a resume or curriculum vitae education and work history (such as work experience, education, and languages spoken)
If you disclose any Personal Information relating to other people to Us or to Our service providers in connection with the Services, you represent that you have the authority to do so and to permit Us to use the Personal Information in accordance with this Privacy Statement.
We may aggregate any personal information that We collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for Our own legitimate business purposes without restriction.
We use personal information in one or more of the following ways:
· To fulfill a request that you have made
· To respond to a question or comment
· To facilitate your use of the Services
· To advertise and market Our Services
· To send you communications such as newsletters, product updates and refill reminders
· To improve Our Services
· To manage Our clinical trials
· As necessary for Our Online Services to function properly
· As necessary to recognize you and allow you to log-on to certain pages and features for which you have registered
· To conduct market research and research about the use of the Services and Our products
· To meet legal, security, processing, and regulatory requirements
· To protect against fraud, suspicious or other illegal activities
· To conduct research including secondary and follow-on research
We may disclose your Personal Information in one or more of the following ways:
· We may disclose your Personal Information to Our corporate affiliates, subsidiaries and divisions. Any Personal Information provided to affiliated entities, subsidiaries or divisions will be treated in accordance with this Privacy Statement.
· We may retain other companies and individuals to perform services on Our behalf and We may collaborate with other companies and individuals with respect to particular Services. Examples of Service Providers include data analysis firms, credit card processing companies, customer service and support providers, email and SMS vendors, web hosting and development companies and fulfillment companies.
· These may include Our co-promote partners for Services that We jointly develop and/or market with other companies. Some Service Providers may collect personal data on Our behalf.
· With
Legal Authorities and in connection with legal
claims
· BI may disclose Personal Information to comply with applicable law and regulations, to comply with public and government authorities and, when necessary to protect and defend the rights or property of BI, or when necessary to protect the personal safety of individuals that interact with Our Services.
· We may provide Personal Information to a third party in connection with the sale, assignment or other transfer of the business of the websites or joint venture to which the information relates, in which case We will require any such buyer to agree to treat the information collected in accordance with this Privacy Statement.
We do not disclose your Personal Information to third parties for purposes of third-party marketing. We do not sell your Personal Information.
If We use your email address to send you email messages related to a product or service for which you have requested information or to send you marketing emails with products or services that We think you might like, you can always change your mind and ask Us to stop emailing you. You can do so by
following the link to “Unsubscribe” in Our emails or otherwise contacting Us.
If We use your phone number to call you or send you a text message in connection with a product or service for which you have signed up, you can change your mind and ask Us not to call you anymore. If you have received a text message from Us, you can unsubscribe by following the instructions within the text message, or by responding with the word, “Stop.”
If We use your mailing address to send you materials and information through the mail that you have requested or that We believe would be of interest, you can change your mind and ask Us to stop sending such materials to you by mail or telephone at the address or telephone number listed in the Contact Us section of this Privacy Statement.
Please note, even if you opt out of receiving marketing or commercial communications, We retain the right to send you non-marketing communications such as correspondence about your existing business relationship with Us or notifying you of updates to Our Privacy Notice or Terms of Use.
You may have certain rights and choices regarding Our processing of your personal data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:
· Know the categories and/or specific pieces of Personal Information collected about you, including whether your Personal Information is sold or disclosed, and with whom your personal information was shared.
· Access a copy of the Personal Information We retain about you.
· Request deletion of your Personal Information.
We reserve the right to verify your identity in connection with any requests regarding Personal Information to help ensure that We provide the information We maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, We may require and request additional information to verify that you are authorized to make that request.
We reserve the right to deny your request if We cannot verify your identify. Where We deny your request in whole or in part, We will endeavor to inform you of the denial, provide an explanation of Our actions, and the reasons for the denial.
We will not restrict or deny you access to Our Services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect Our ability to deliver the Services. For example, if you sign up to receive marketing communications by email, then ask BI to delete all of your information, We will be unable to send you marketing communications.
Automatic Collection of Information
BI also collects Information about how you interact with Our Online Services such as page views, unique views, what you click on the website, average time on the website or using Apps, browsers, operating systems and Internet Protocol (IP) Address.
This is passively collected, which means that it is collected without you having to do anything, using the following tracking technologies:
· Cookies
“Cookies” are small text files that are placed on your browser, either for the duration of your website session (called “session” cookies) or more permanently (called “persistent” cookies).
Anonymous identifiers are sometimes used in place of cookies on mobile devices which may not
support cookie technology. Sometimes We work with third parties who also place cookies on your device.
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, We do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies.
· Pixel Tags/Web Beacons and Web Logs
Pixel tags, also known as web beacons, function similarly to cookies. A pixel tag is an invisible, one pixel-sized piece of code which transmits certain information to Our servers. They are placed on key pages, tools and areas of the websites and Apps. When a visitor
requests/visits/clicks on anything that includes a pixel tag, the information about the visitor’s
action is recorded in a web log.
· Web Analytics
Web Analytics tracks how visitors interact with Our Online Services, including where they came from and what they did on a site. Web Analytics uses cookies and other tracking technologies to collect the following types of information about the Online Services: visits, page views, unique views, bounce rate, average time on site, language, visitor country location, browsers, operating systems, screen colors and resolutions, referring sites and top landing and exit pages.
We will use this information in one or more of the following ways:
· We use IP Address information to measure site traffic, to help Us to understand how people are using Our Online Services and to improve user experience.
· We use information collected in cookies and anonymous identifiers to help recognize repeat visitors, facilitate ongoing access to some Online Services and allow Us to understand how and when pages are visited and by how many people.
· We use pixel tags and web beacons to track a visitor’s usage across Our Online Services. This
information allows Us to further customize your website experience.
· We use pixel tags in Our HTML-based emails in order to determine if you opened and replied to or forwarded emails. This information is used in aggregate for research to improve site content and usability and may be used by Us to provide you with additional information.
· We use Web Analytics to track visitor data for the purpose of website optimization and to determine which audiences are visiting Our Online Services.
· We use information collected in cookies from Our websites to provide you with relevant advertising and product information that may be of interest after you leave Our website.
You may have choices about how your information is collected through tracking technologies.
For Our websites, you may opt to enable a feature on your browser that will erase cookies, block all cookies or warn you before cookies are stored or exchanged. Please be aware, however, that some parts of the websites may no longer function properly if cookies are disabled.
You may be able to disable pixel tags by changing your browser settings to omit images or through commercially available software packages.
For more information on opting out of tracking over time and across third party sites, please refer to the
“Website Tracking and Online Behavioral Advertising” section of this Privacy Statement, below. For more information on your choices that are specific to mobile applications, please refer to the “Mobile Apps” section of this Privacy Statement, below.
Third parties (including, but not limited to, software vendors, advertisers, ad servers, content providers, and services providers) may also use similar technologies by or through our Services or through their own websites. In connection therewith, such entities may collect information about you and your usage activity on this and other websites. We do not control these third parties and are not responsible for the actions of Our third party business partners. We encourage you to check their terms of use and privacy policies for such information.
BI takes reasonable measures to protect the information it processes against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these efforts, however, no organization, including BI, can fully eliminate risks or guarantee the security of personal
information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and We bear no liability for uses or disclosures of personal data or other data arising in connection with theft of the information or other malicious actions.
The websites and any accompanying services offered are not directed at children who are under 13 years of age. It is BI’s policy to require that individuals requesting information on Our products be 13 years of age or older.
Should We receive Personal Information from a person who We know is under 13, We will endeavor to delete such information from Our database. The information will not be used for any purpose without consent of a parent or guardian. If you believe that a person under 13 has provided Us with his or her Personal Information, please notify Us so that We can take reasonable steps to remove the information from Our database.
BI may offer apps, special programs, clinical trials, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the terms applicable to the Programs before interacting or participating in the Programs.
As a convenience to Our visitors and users, BI may offer links to a number of other sites that We believe may offer useful information. When you click on one of these links, you will be transferred from the BI website or App and be connected to the site of the organization or company that you selected. The BI
Privacy Statement is no longer applicable when you leave Our Online Services. Each of these linked sites maintains its own independent privacy policies and procedures, which you should consult before providing any of your Personal Information.
When you download or purchase an App, or make an in-app purchase, you do so through a third party mobile application online store. You may be required to register with the mobile app store and be logged on before you can download or purchase an App or make an in-app purchase of another product using the App. When downloading an App, or using an App with features through your mobile platform, the app provider will typically also collect certain device and app-related information.
Some Apps may send push notifications, or notices of interest sent out in the absence of a specific request, to your mobile device. If you decline to accept push notifications, you may not receive the most current updates and features of the App.
You have choices when it comes to how Apps function on your mobile device. You may be able to:
• Manage push notifications by using your built-in mobile device settings and controls
• Manage location information by using your built-in mobile device settings and controls
• Manage/restrict in-app purchases by using your built-in mobile device settings and controls
• Block navigation to the web by turning off network access on the device or turning off the browser
Access to or availability of controls may vary depending on your device.
We use information collected through cookies in order to provide you with relevant advertising and product information of interest after you leave Our website. You can opt-out of that tracking by going to the Network Advertising Initiative’s (NAI) website and opting out of tracking by advertising networks, which may include, but not be limited to Google DoubleClick, AdRoll, and BrightRoll. The NAI’s website can be found here. Please understand that if you decide to opt out, you will still receive advertising online, but it may not be relevant to your interests or targeted based on your internet browsing activity.
We do not currently respond to browsers’ Do Not Track signals with respect to Our Websites and Apps.
The information on websites and Apps is intended for use by U.S. residents only. Websites or Apps may contain information about products not available in other countries or regions of the world or that may be available under a different trademark or name. Other countries may have laws, regulatory requirements and medical practices that differ from those in the United States and may require different or additional information. Therefore, product information may not be appropriate for residents of other countries.
The Site is controlled and operated by Us from the United States and is not intended to subject Us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any
information you provide to Us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. We may need to send your personal information overseas as part of Our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that We take reasonable steps to ensure that your privacy is protected.
We retain personal information for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When We no longer need the personal information We collect, We either deidentify the information or securely destroy the information.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. BI does not distribute your personal information to outside parties for their direct marketing without your consent.
BI reserves the right to modify, add or remove portions of this Privacy Statement at its discretion. If We decide to change this Privacy Statement, We will post those changes at this site. Continued use of Our sites following any changes in Our Privacy Statement indicates your consent to the use of newly submitted information in accordance with the amended Privacy Statement.
If you have any questions about Our Privacy Statement, the Online Services or rights you have in connection with your personal information, you may contact Us using Our email us.privacy@boehringer- ingelheim.com or by mail at:
Boehringer Ingelheim USA Corporation 900 Ridgebury Road
Ridgefield, CT 06877
Phone: 1-800-243-0127
Boehringer Ingelheim Animal Health USA Inc. 3239 Satellite Blvd NW
Duluth, GA 30096
Phone: 1-800-325-9167
CL-NON-100035 (04/2021)