Actavis Specialty Pharmaceuticals Co. and Allergan Inc. (collectively, the “Company”)
This policy is effective as of September 25, 2015
1. Types of Personal Information
- Contact Information that allows us to communicate with you, such as your name, email address, mailing address, email address or phone numbers.
- Relationship Information that helps us understand your interests, including information about products, treatments and health conditions that are of interest to you.
- Transaction Information about how you interact with the Company, including purchases, inquiries, and information about how you use the Company’s websites and applications.
- Financial Account Information, such as your credit card number or Social Insurance Number (SIN), as needed to process payments and provide reimbursement services.
- Geo-location Information, as may be transmitted to us by your smart phone or other location-aware devices.
- Job Applicant Information, to process your job application, such as your Contact Information, resume, previous work experience, education, transcript, driver’s licence information, Social Insurance Number (SIN) or national identification number and information relating to references.
2. Identified Purposes
For clarity, “Personal Information” includes any factual or subjective information or record about an identifiable individual. The Company collects Personal Information only for the following purposes:
- To establish and maintain responsible commercial relations with our customers and suppliers in order to provide you with ongoing services
- To establish and maintain communications with you
- To understand your needs and recommend suitable products and services
- To conduct scientific research on the efficacy of our products
- To develop, enhance and market our products and services
- To manage personnel and employment matters
- To meet legal and regulatory requirements
3. ConsentWe will obtain your consent before we:
- Check your employment references
- Obtain a credit report
- Use your Personal Information in any other manner not listed in this policy
- Disclose your Personal Information to a third-party who is acting on our behalf as our agent, supplier or service provider. Such entities are required to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of the Company.
Children under the age of 13 should always get permission from their parents or guardians before providing Personal Information about themselves (such as name, email addresses, phone numbers, etc.) over the internet. The Company will not intentionally encourage any child to register on any of our websites. If a child has provided the Company with Personal Information, such child’s parents or guardian should contact the Company (see contact information at the end of this section).
You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this. However, you should be aware that your withdrawal of consent cannot affect information that has already been used by the Company.
4. How the Company Collects Personal Information
In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our websites, using any interactive features or applications, sign up to receive a newsletter or a rebate, participate in a loyalty program, or make a direct purchase, or apply for employment. We may collect additional information from third-party data suppliers who enhance our files or from social media sites such as Facebook, if you like our pages or join our communities.
5. How the Company Uses Personal Information
The Company may use your Personal Information for its business purposes, such as:
- To respond to your requests for information, products and services, including managing your online accounts with us and providing warranty service for certain products;
- To provide you with general health information (such as information on certain health conditions) as well as information about our products and services;
- To provide you with marketing communications and offers for products and services;
- To administer promotional or loyalty programs, such as sweepstakes, rewards and rebate programs;
- To determine if you are eligible for certain products, services or programs;
- If you have a business or professional relationship with the Company, to develop our business relationship with you;
- If you apply for a job via our career centre, to consider you for employment;
- For our research and development efforts;
- To anonymize data so that it is no longer Personal Information;
- For product safety, such as adverse event reporting or to communicate product safety information to you; and
- For other everyday business purposes, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance.
6. Why Personal Information Is Disclosed by the Company
The Company does not sell, share or otherwise distribute your Personal Information with third parties for their marketing purposes. The Company will share your Personal Information only in compliance with any obligations under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and, with respect to information obtained from residents of Canada, in a manner that complies with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) or applicable provincial legislation and other applicable laws. For example, we will share your Personal Information as follows:
- We may share your Personal Information with your consent or as you direct. For example, we may share information with your doctor as part of programs in which you agree to participate.
- We may share your Personal Information with our affiliated companies and product co-promotion partners, which may only use your Personal Information for the purposes listed herein.
- We may share your Personal Information with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions. For example, we may share your Personal Information with vendors who provide data processing or fulfillment services for us.
- We may also disclose Personal Information where needed to effect the sale or transfer of business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.
- We may also disclose Personal Information when requested under legal process or otherwise required by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.
For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud.
The Company uses Flash cookies (also known as Local Stored Objects), Microsoft Silverlight and similar technologies to personalize and enhance your online experience in compliance with Network Advertising Initiative standards. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. Flash cookies (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please see Adobe’s website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com. To manage Silverlight cookies, see Microsoft’s privacy statement at http://www.microsoft.com/getsilverlight/get-started/install/privacy.aspx or visit www.microsoft.com.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to the Company’s website and the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.
8. Tell-A-Friend Functions
The Company offers “tell-a-friend” functionality on our websites. If you choose to use this function, we will collect Personal Information for your friend. We will automatically send your friend a one-time email with the information you specified or inviting him or her to visit the site. The Company uses this information for the sole purpose of sending this one-time email and does not retain the information.
9. Your Choices
You can always limit the information you provide to the Company. You can also limit the communications that the Company sends to you by following a simple opt out process. Simply follow the instructions in our emails to opt out of receiving future marketing communications.
Please note that even if you opt out of promotional emails, we may still need to contact you with important transactional information about your account or your equipment. For example, even if you opt out of emails, we will still send you a confirmation when you purchase something from our website as well as product safety communications.
You can manage cookie preferences and opt out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.
You can opt out of being targeted by those third-party advertising companies that are NAI members online at www.networkadvertising.org/consumer/opt_out.asp.
10. Access and Correction
The Company respects your right to access and correct your Personal Information. You may update your Personal Information at any time by contacting us via email at IRemail@example.com, or directly by logging into your online account, should you have one. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.
11. Information Security
The Company has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard your Personal Information from unlawful use and unauthorized disclosure.
12. Notice to Residents of Countries outside the U.S.
The Company’s corporate head office is located in the United States of America. Your Personal Information may be accessed by or transferred to the United States or to our affiliates and data processors elsewhere in the world. By providing us with your Personal Information, you consent to this transfer to the U.S. which your country may not consider to provide for adequate privacy protections. We will always protect the privacy and security of your Personal Information as expressed in this policy, regardless of where it is processed or stored.
13. Privacy Policies of Third Parties
14. Children’s Privacy
The Company website and applications are not intended to attract children, and we do not knowingly collect any Personal Information of anyone under the age of 13. If you believe your child is using our website, please contact us at IRfirstname.lastname@example.org so we can investigate and delete any inappropriate information.
15. Forums, Product Reviews and Other Public Areas
Any portions of this policy are void to the extent they are prohibited by applicable law.
17. How to Contact Us
Attention: Legal Department
85 Enterprise Blvd, Suite 500
Markham, ON L6G 0B5
© 2015 Allergan. All Rights Reserved.