Posted on 08/24/2020
I. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on whether you are a customer, user, applicant or visitor, and the requirements of applicable law.
Information You Provide to Us.
- Enrollment. When you enroll in our Services, we may collect your name, email address, mailing address, phone number, date of birth, insurance information and other similar information.
- Clinical Trial Participation. In addition to Enrollment information, we may collect health information related to your medications, medical history, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history in connection with your participation in clinical trials and where we are required to by legal requirements (such as adverse event reporting requirements). We collect such information only where you have provided your consent to disclose that information to us, as required by law.
- Your Communications with Us. We collect personal information from you such as name and email address when you request or register for information about our Services, inquire about a product, request customer or technical support, apply for a job or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
- Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
- Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
Information Collected Automatically or From Others
- Automatic Data Collection. When you enroll in our Services, we may collect your name, email address, mailing address, phone number, date of birth, insurance information and other similar information.
- In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Our uses of these Technologies fall into the following general categories.
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
See below to understand your choices regarding these Technologies.
- Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
II. HOW WE USE YOUR INFORMATION.
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our agreement with you and/or provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Communicating with you about your account, activities on our Services and policy changes;
- Undertaking activities to verify or maintain the quality or safety of a service or device;
- Processing your financial information and other payment methods for products or Services purchased;
- Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;
- Processing applications and transactions; and
- Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Services or device or those of our Providers;
- Developing new products and Services;
- Ensuring internal quality control;
- Verifying your identity and preventing fraud;
- Debugging to identify and repair errors that impair existing intended functionality;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our terms and policies;
- Supporting public health initiatives, symposia, conferences, and scientific, educational and volunteer events; and
- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
- Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
Service Providers. We may share any personal information we collect about you with our third- party service providers. The categories of service providers (processors) to whom we entrust personal information include IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Affiliates. We may share personal information with our affiliated companies.
Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
B. Disclosures to Protect Us or Others.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
IV. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
V. YOUR CHOICES.
General. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Your Privacy Rights.
In accordance with applicable law, you may have the right to:
- Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
- Request Deletion of your personal information, subject to certain exceptions prescribed by law.
- Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please contact us as set forth below. If you are a job applicant, you may visit our portal to exercise your rights. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
VI. DATA RETENTION.
VII. SECURITY OF YOUR INFORMATION.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
VIII. CHILDREN’S INFORMATION.
The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
IX. OTHER PROVISIONS.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Currax has collected about them and whether Currax disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Currax
- Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
- Protected classification characteristics under California or Federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Inferences drawn from other personal information to create a profile about a consumer. Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- The category of third parties, information is disclosed to for a business purpose:
- Service providers
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, Currax does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. 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. To designate an authorized agent, contact us at email@example.com.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address and the nature of your relationship with Currax.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.
X. CONTACT US.
Currax Pharmaceuticals LLC
10 North Park Place, Suite 201
Morristown, New Jersey 07960