Effective Date: January 22, 2020
1. What type of Personal Information do we collect?
“Personal Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location, or factors specific to physical, physiological, genetic, economic, cultural or social identity. We may collect and process the following Personal Information about you:
- Contact information, such as your name, email address, phone number, address, company affiliation, or job title;
- Access information, such as your log-in username and password details;
- Online and technical identifiers, such as your IP (Internet Protocol) address and cookies;
- Professional credentials, such as curriculum vitae/resume, work history, qualifications or any other type of information that may be included on a resume or curriculum vitae;
- Demographic and medical information;
- Communication and correspondence information, such as the content of communications you send us to report a problem or to submit a query, or your response to a survey for market research purposes;
- Financial and government identifying numbers, such as social security numbers; and
- Any other information that you provide to us that can be used to identify you.
2. How do we obtain your Personal Information?
We collect Personal Information from a number of sources, including:
- Directly from you, such as when you enquire about our products and services, contact us via the Site, apply for employment, ask to be a research study participant or a principal investigator in one of our trials, or in any way engage with us or our personnel;
- Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links in our emails;
- Through the use of social media platforms, such that if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
- Third party vendors, which may include those vendors, suppliers, contractors or business partners that provide services for us (e.g. market research vendors);
- Adverse event reporting reporters or subjects;
- Consumers and customers;
- Government officials; and
- Publicly available sources.
3. What are the legal bases for collecting and processing your Personal Information?
We collect and use your Personal Information with your consent for the specific purpose identified in the individual notice given at the point of collection or in order to manage or fulfill our contractual relationships. For example, in some circumstances, processing of your Personal Information is necessary to fulfill our or your (at your request) obligation in a commercial, employment or service contract. In addition, we may need to collect and process your Personal Information to comply with our legal obligations and/or fulfill our legitimate interests.
We are committed to collecting and processing your Personal Information in a lawful and transparent manner. For further details on the legal bases ACADIA assigns for particular data collection and use, please reference the below table.
4. How do we use your Personal Information?
Subject to applicable privacy laws, the Personal Information we collect from you may be used for the following business purposes:
- to perform or enter into a contract;
- to comply with applicable laws, regulations, codes, court order or other legal obligations (e.g., pharmacovigilance obligations, financial disclosure requirements);
- to send communications (including documents and electronic messages or alerts) regarding our products and services and related materials;
- to respond to and fulfill inquiries and requests;
- to provide our products or services offered through the Site;
- to perform website analytics and understand usage trends to personalize your access to the Site;
- to recruit study participants;
- to conduct research and development activities for our products and services;
- to conduct market research relating to our products and services;
- to provide patients assistance;
- fraud and security monitoring;
- to enforce these privacy principles and to protect our rights or property; or
- for any other administration of legal and/or business processes that are in ACADIA’s legitimate interest unless such use is prejudicial to your rights or your liberties.
5. Technical Information and Do Not Track Policy
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. ACADIA leverages third-party analytics and market performance tools in the administration of its consumer and professional websites. As a result, we have employed best practices and policies to respect browsers using the DNT signal. ACADIA respects this tag through applied policies in software developed for ACADIA as well as our use of tools to help provide better services and messaging to consumers and healthcare professionals. ACADIA assumes no liability for policies of or failure to comply with the DNT signal by our partners or vendors.
6. How will we share your Personal Information?
We will share your Personal Information within ACADIA, at your direction, as disclosed to you at the time of collection, or in the following circumstances:
- Services by Third Party Providers: We may provide your Personal Information to our service providers that help us run and manage our organization and process Personal Information solely on our behalf. The categories of service providers may include delivery services, financial institutions, clinical research organizations, central laboratories, clinical database companies, payroll and benefit companies, and specialty pharmacies, among others.
- Corporate Transaction: In the event ACADIA is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Information as part of that transaction.
- Third Party Collaborators: We may share your Personal Information with other companies with which we collaborate regarding particular products or services. These may include our co-promote partners for products that we jointly develop and/or market.
7. International Transfer of Personal Information
For those individuals located in the EEA or Switzerland, ACADIA and its controlled United States subsidiaries have certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks for the transfer of personal data from the EEA and Switzerland to the United States, as described in our Privacy Shield Notice. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and to view our certification, please visit www.privacyshield.gov.
8. Third Party Websites and Services
9. Legal Requirements
In order to comply with the law, you understand that we may not be permitted to comply with your request to amend or remove Personal Information that was provided to us by you or a healthcare provider regarding a consumer product complaint, an adverse event or reaction involving medicine, medical products or medical devices or required disclosures of your Personal Information as required by court order or other legal or regulatory process (“Legal Requirements”).
We implement technical and organizational measures designed to ensure your Personal Information is protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with our services. If you would like to know more about how we protect your Personal Information, you can contact our Data Protection Officer using the information listed below.
11. Retention of Personal Information
We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements. If you would like to know more about how long we keep your Personal Information, you can contact our Data Protection Officer using the information listed below.
12. Children’s Privacy
Our services are not directed to or intended for use by individuals under the age of 16, and we request that these individuals do not use this Site or provide us with any Personal Information. Consistent with the requirements of applicable laws and regulations, if we learn that we have received Personal Information directly from a child under age 16 without his or her parent or legal guardian’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.
For EU residents, if you wish to receive marketing-related emails from us, please tick the “I agree” box at the bottom of any marketing email. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any marketing email or by emailing us using the information in the section “Contact Us.” Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
14. How can you access your Personal Information?
You may request access and modifications to the Personal Information, other than information described under Legal Requirements, we maintain about you by contacting us using the contact information below. We will respond to your inquiry within 30 days. If you wish to exercise any of your rights (including the rights of individuals in the EEA discussed below) or advise us of any changes to your Personal Information, please contact our Data Protection Officer using the contact information provided below. Under the European Union’s General Data Protection Regulation (“GDPR”), a response to a Data Subject Access Request will be provided free of charge, unless the request is deemed to be manifestly unfounded, excessive or repetitive in character. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.
15. What are the special rights of individuals in the European Economic Area?
If you are located in the EEA and we maintain your Personal Information, you have the following additional rights (under the GDPR) with regard to your Personal Information. Note that some of these rights may not be exercisable if you are a patient.
- Right to be informed: You have the right to obtain from our Data Protection Officer confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, all necessary information to make the process transparent.
- Right to access and receive: You may request a copy of or access to the Personal Information we hold about you.
- Right to portability: You may request that we transfer your Personal Information to a third party in a machine-readable format.
- Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.
- Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it.
- Right to erase: You may have the right to request that we delete all or some of your Personal Information. This right may be limited if we have collected your Personal Information for research purposes.
- Right to withdraw consent: You have the right to withdraw any consent you have previously given to ACADIA at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.
- Right to complain: You have the right to lodge a complaint with your Supervisory Authority or with the Supervisory Authority where the alleged violation took place.
16. Special Notice to California Residents
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.
18. Contact Us