Boehringer Ingelheim US Privacy Policy Statement
Last Updated: April 11,
2024
A. Welcome
Thank you for visiting us. We have revised our Privacy
Statement (“Privacy Statement”) to make it clearer and more user-friendly and
transparent about how we process information we collect about you (“Personal
Data”). We respect and protect your privacy, and we are committed to the
transparent use of your Personal Data.
This Privacy Statement informs you of how we collect and
use your Personal Data when you use our websites or mobile applications, or
otherwise interact with us online or offline (collectively, the “Services”)
provided by Boehringer Ingelheim US (“Boehringer”). This Privacy Statement may
change from time to time as our websites and business evolve, and we will post
the updated notice on this page. If we make any material changes to this
Privacy Statement, we will notify you if we are required to do so by applicable
law.
B. Scope
This Privacy Statement applies to all Personal Data we
collect from U.S. consumers, such as U.S. individuals who visit our websites,
use our mobile applications, and otherwise use our Services. This Privacy
Statement does not apply to Boehringer employees, job applicants, or other
individuals with whom we interact in an employment-related capacity
(collectively, “Employees/Applicants”) or to individuals with whom we interact
in a business context, including healthcare professionals (collectively, “Business
Contacts”). Our Employee/Applicant Privacy Statement and our Consumer Health
Data Privacy Policy can be viewed at the below links:
• Employee/Applicant Privacy Statement
• Consumer Health Data Privacy Policy
C. What is Personal Data?
Personal Data means information that identifies, relates
to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular living person
or household. Personal Data does not include anonymized or publicly available
data, or any other categories of information that are excluded from the
definition of “Personal Data” under applicable U.S. privacy laws (“U.S. Privacy
Laws”). References to Personal Data in this Privacy Statement include “Sensitive
Personal Data,” as defined below, except where noted
otherwise.
We collect and have collected in the past twelve months the
following categories of Personal Data:
• Identifiers - Identifiers, such as
a real name, alias, postal address, unique personal identifier, online
identifier, internet protocol (IP) address, phone number, email address,
account name and login credentials, driver’s license number, or other
government-issued identifiers.
• Financial Information -
Financial information, including bank account number, credit or debit card
number, or other financial information.
• Health Insurance Information -
Health insurance information, including an individual’s insurance policy number
or subscriber identification number, any unique identifier used by a health
insurer to identify the individual, or any information in the individual’s
application and claims history.
• Protected Characteristics -
Characteristics of protected classifications under state or federal law, such
as race, gender, physical or mental disability, and religion.
• Commercial Information -
Commercial information, including records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies.
• Biometric Information -
Biometric 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.
• 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.
• Geolocation Data - An
individual’s approximate or precise geolocation data.
• Electronic and Sensory Data -
Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a
recording of a customer service call or profile photograph). This also includes
the contents of your messages, chats, or other communications that you send to
us or through the website.
• Professional Information - An
individual’s professional or employment-related information.
• Education Information - An
individual’s education information, including academic information and records.
• Inferences – Inferences drawn from
any of the categories of Personal Data listed in this Section C to create a
profile about a consumer reflecting the consumer’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
• Sensitive Personal Data - The
above categories include types of Personal Data that may be considered
“sensitive” in some jurisdictions such as biometric information, communications
or messages content, financial information, login credentials,
government-issued identifiers, health insurance and medical information, and
protected characteristics. Further, we collect the following categories of
health-related information: Individual health conditions, treatment, diseases,
or diagnosis; Social, psychological, behavioral, and medical interventions; Health-related
surgeries or procedures; Use or purchase of prescribed medication; Bodily
functions, vital signs, symptoms, or measurements related to health; Diagnoses
or diagnostic testing, treatment, or medication; Reproductive or sexual health
information; Biometric data; Genetic data; Precise location information that
could reasonably indicate a consumer's attempt to acquire or receive health
services or supplies; Data that identifies a Consumer seeking health care
services; Health-related data that have been derived or inferred from the
above
D. Purposes for Processing Personal Data
We collect, use, and disclose Personal Data (except for
Sensitive Personal Data) to:
• Respond to requests from you
• Better understand your needs and improve our websites,
products, and services
• Analyze the use of our Services, and to operate and
maintain our business
• Contact you, including providing you with information,
opportunities, updates, and special offers from Boehringer and our business
partners
• Prepare for and conduct research
• Monitor the safety and efficacy of our products or
services
• Monitor, investigate potential breaches of, and enforce
compliance with Boehringer policies and procedures and legal and regulatory
requirements
• Respond to and comply with legal process, such as civil,
criminal, judicial, or regulatory inquiries, investigations, subpoenas, or
summons
• Exercise or defend the legal rights of Boehringer and its
employees, affiliates, customers, contractors, agents, and others
• Comply with legal obligations, regulatory requirements,
and our own policies and procedures
E. Purposes for Processing Sensitive Personal Data
We collect, use, and disclose Sensitive Personal Data for
the below purposes:
• To perform the services or provide the goods reasonably
expected by an average consumer who requests those goods or services
• To prevent, detect, and investigate security incidents
that compromise the availability, authenticity, integrity, or confidentiality
of stored or transmitted Personal Data
• To resist malicious, deceptive, fraudulent, or illegal
actions directed at us and to prosecute those responsible for those actions
• To ensure the physical safety of natural persons
• To perform services on behalf of our business, such as
for maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying
customer information, processing payments, providing financing, providing
analytic services, providing storage, or providing similar services on behalf
of our business
• To verify or maintain the quality or safety of a product,
service, or device that is owned, manufactured, manufactured for, or controlled
by us, and to improve, upgrade, or enhance the service or device that is owned,
manufactured by, manufactured for, or controlled by us
• To collect or process Sensitive Personal Data where the
collection or processing is not for the purpose of inferring characteristics
about a consumer
Please note that we do not collect, use, or disclose
Sensitive Personal Data for purposes other than those specified in the
California Consumer Privacy Act (“CCPA”).
F. Sale, Sharing, & Targeted Advertising
We sell, share, and process Personal Data for purposes of
targeted advertising, and we have sold, shared, and processed Personal Data for
purposes of targeted advertising in the past twelve months, as described in the
below chart, as the terms “sale,” “share,” and “targeted advertising” are
defined by U.S. Privacy Laws. You have the right to opt out of the sale,
sharing, and/or processing of your Personal Data for targeted advertising. To
do so, you can click here or call us at
1-800-243-0127.
|
Category of Personal Data |
Disclosed to Which Categories of Third Parties |
|
Name, Contact Information, and Identifiers |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Protected Characteristics |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Commercial Information |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Biometric Information |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Network Activity Data |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Geolocation Data |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Electronic and Sensory Data |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Professional and Education Information |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Medical Information |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Inferences and Profiles |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
|
Sensitive Personal Information, Health Information,
Financial Information |
Boehringer's subsidiaries and affiliate companies;
providers; professional advisors; public and government entities |
We sell, share, and process Personal Data for purposes of
targeted advertising as described above to:
• Better understand your needs and improve our websites,
products, and services
• Analyze the use of our Services, and to operate and
maintain our business
• Contact you, including providing you with information,
opportunities, updates, and special offers from Boehringer and our business
partners
Please note that we do not have actual knowledge that we
sell or share the Personal Data of children under the age of sixteen.
G. Personal Data Retention and Minimization
Boehringer uses only the minimum amount of Personal Data
reasonably necessary to accomplish the purpose for which it was collected.
Further, we retain your Personal Data for as long as necessary to fulfill the
purposes for which they are collected or to satisfy a legal obligation imposed
on Boehringer. Personal Data that are no longer needed for the above purposes
will be deleted or deidentified. Whenever we deidentify Personal Data, we take
reasonable measures to ensure that the information cannot be associated with a
consumer or household, and we maintain and use the information in deidentified
form. We will not attempt to reidentify the information, except that we may
attempt to reidentify the information solely for the purpose of determining
whether our deidentification processes satisfy applicable legal requirements.
H. Sources from which We Collect Personal Data
We collect Personal Data directly from consumers. For
instance, you may disclose Personal Data to us to receive information,
opportunities, updates, or special offers from Boehringer and its business
partners. You can also ask us about our products or services, or someone can
ask for them for you. You may want to join one of our programs or be part of a
patient community that we support. Also, some Services offer interactive
content, like patient education and support. Users of the Services may provide Personal
Data to Boehringer to experience these features. We also collect Personal Data
from our vendors and from third parties when they disclose Personal Data to us,
as well as from joint marketing partners, publicly-available
sources, and social media.
Further, we collect Personal Data via cookies and similar
technologies on our Services. Websites use these technologies for different
reasons, such as to provide, improve, measure, personalize, or share online
services with you. We use cookies to improve website functionality,
performance, and other cookies to remember your preferences or to show relevant
content. You can review, modify, or revoke your consent to cookies by
customizing your preferences in the cookie preference center of our websites.
I. Disclosures of Personal Data
We disclose, and we have disclosed in the past twelve
months for a business purpose, the categories of Personal Data listed in
Section C to:
• Our parent company and affiliates
• Our vendors who process Personal Data to provide services
on our behalf
• Third party marketing partners who conduct online
targeted advertising
• Other third parties: With your consent or at your
direction; In connection with a sale, reorganization, joint venture, or other
similar business transaction; Government and regulatory bodies and courts to
comply with our legal and regulatory obligations, ensure compliance with the
requirements of our policies and procedures, or prevent fraud or physical harm
J. Protecting Personal Data
Boehringer implements technical, physical, and
administrative protections to keep Personal Data secure. However, despite these
protections, no organization, including Boehringer, can completely guarantee
that your Personal Data are not accessed by unauthorized people/bad actors. If
Boehringer becomes aware that Personal Data has been compromised, Boehringer
will promptly take steps to resolve the incident in accordance with applicable
laws and regulations.
K. Personal Data of Minors
Boehringer is committed to protecting the privacy of
children. Our Services are not geared toward children under the age of 18.
Further, for compliance with the Children’s Online Privacy Protection Act, we
do not collect Personal Data from children under 13 years old without the
express consent of the child’s parent or guardian. If you are the parent or
guardian of a child under 13 years old and you believe that we have collected
Personal Data about your child without your consent, please contact us immediately
at us.privacy@boehringer-ingelheim.com and we will promptly take steps to delete such
Personal Data from our systems.
L. Exercising Data Subject Rights
Depending on your place of residence, including California,
Connecticut, Colorado, Delaware, Indiana, Iowa, Montana,
New Jersey, New Hampshire, Oregon, Tennessee, Texas, Utah, and Virginia, you
may have some or all of the following rights (“Data Subject Rights”). You may
exercise your Data Subject Rights by any of the methods provided in the
“Contact Us” section, below.
You may also authorize an agent to make data subject
requests on your behalf. In such instances, authorized agents may use the same
methods as you to submit the requests on your behalf. To verify your identity
and protect your Personal Information, we may ask the requestor to provide
information that will enable us to verify your identity in order to comply with
your data subject request, such as asking your agent to provide proof of signed
permission from you, or asking you to confirm with us
directly that you provided the agent with permission to submit the request. In
some instances, we may decline to honor your request if an exception applies
under applicable law. We will respond to your request consistent with
applicable law.
• Right to Know or Confirm Processing. 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.
Additionally, you may have the right to confirm whether we are processing your
Personal Data. You also have the right to request that we disclose to you the
categories of Personal Data we have collected about you, the categories of
sources from which the Personal Data was collected, the business or commercial
purpose for collecting, selling, or sharing the Personal Data, and the
categories of third parties with whom we disclosed the Personal Data.
• Right of Access or Data Portability. You have the right to request that we disclose or provide
you with access to or a copy of the specific pieces of Personal Data we have
collected about you.
• 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 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, or for other reasons as allowed
under applicable law.
• Right to Correct. You
have the right to request that we correct your Personal Data if you believe it
is inaccurate or incomplete.
• Right to Opt Out of Sale,
Sharing, and Processing of Personal Data for Targeted Advertising. You have the right to opt out of the sale, sharing, and
processing of your Personal Data for targeted advertising. To do so, you can
click here or call us at 1-800-243-0127.
• Right to Opt Out of Profiling. Some U.S. Privacy Laws give consumers the right to opt
out of profiling of Personal Data that has legal or similarly significant
effects. Please note that we do not process Personal Data for profiling with
legal or similarly significant effects.
• Right to Revoke Your Consent.
Depending on your state of residence, your consent may be required in order for us to engage in certain processing activities.
If we have obtained your consent for this purpose, you have the right to revoke
it at any time.
• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or
retaliation for exercising any of your Data Subject Rights as described above.
We will not discriminate or retaliate against you for exercising your Data
Subject Rights.
If we deny your request to exercise a Data Subject Right,
you may have the right to appeal the decision with us, depending on your state
of residency. Please be sure to include information about your prior request so
that we may locate our earlier determination and appropriately respond to your
request. We will process your appeal in accordance with the U.S. Privacy Law
that applies to you.
M. Do Not Track & Opt-Out Preference Signals
We recognize opt-out preference signals that we are
required to recognize for compliance with applicable law. Where required by
U.S. Privacy Laws, we treat such opt-out preference signals as a valid request
to opt-out of sale, sharing, and processing for purposes of targeted
advertising, as applicable, for the browser or device through which the signal
is sent and any consumer profile we have associated with that browser or
device, including pseudonymous profiles. Further, if we know the identity of
the consumer from the opt-out preference signal, we will also treat the opt-out
preference signal as a valid request to opt out of sale and sharing for such
consumer. Consumers may use opt-out preference signals by downloading or
otherwise activating them for use on supported browsers and setting them to
send opt-out preference signals to websites they visit.
N. Other State-Specific Disclosures
• California Residents Under Age 18. If you are a resident
of California under the age of 18 and a registered user of our Services, you
may ask us to remove content or data that you have posted to the Services by
writing to us.privacy@boehringer-ingelheim.com. Please note that your request does not ensure complete or
comprehensive removal of the content or data, as, for example, some of your
content or data may have been reposted by another user.
• Disclosure About Direct Marketing for California
Residents. California Civil Code § 1798.83 permits California residents to
annually request certain information regarding our disclosure of personal
information to other entities for their direct marketing purposes in the
preceding calendar year. To make such a request, please send an email to us.privacy@boehringer-ingelheim.com with the subject “Shine the Light Request.”
• Financial Incentives for California Consumers. We do not
provide financial incentives to California consumers who allow us to collect,
retain, sell, or share their personal information. We will describe such
programs to you if and when we offer them to you.
• Disclosure for Nevada Consumers. We sell “Covered
Information” as defined under Nevada law, but we generally do not disclose or share “Personal Information” as defined under
Nevada law for commercial purposes. Under Nevada law, you have the right to
direct us to not sell your Covered Information to third parties, as defined
under Nevada law. To exercise this right, if applicable, you or your authorized
representative may contact us at us.privacy@boehringer-ingelheim.com.
O. Contact Us
If you have any questions about our Privacy Statement, want
to receive this Privacy Statement in a different format, or want to exercise
the data subject rights you have in connection with your Personal Data, you may
contact us via email at us.privacy@boehringer-ingelheim.com, via webform by clicking here, or via mail or phone
at the below contact information.
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