Privacy Policy
Last Updated: May, 18th 2023
Dompé U.S Inc. (“Dompé U.S.”) is the United States subsidiary of Dompé farmaceutici S.p.A. an Italian biopharmaceutical research and manufacturing company. This privacy policy describes how Dompé U.S. (as well as any additional subsidiary, affiliate or branch Dompé U.S. may subsequently form in the U.S.) collects, uses, processes, combines and discloses, if applicable, different types of information in the regular course of its business (the “Privacy Policy”). This Privacy Policy governs the use of all Dompé U.S. owned and or operated applications, platforms, websites or mobile websites which reference or link to this specific Dompé U.S. Privacy Policy (the Dompé owned or operated websites and mobile websites are collectively, the “Websites”). This Privacy Policy also governs Dompé U.S.’ offline offerings and or any services we provide, including but not limited to clinical trials, and or interactions with consumers, patients, and health care professionals (collectively, the “Services”). This Privacy Policy also explains your ability to control certain uses or disclosures of your information, your rights, and or choices. If you provide us with the information of anyone other than yourself (such as a patient or family member), you are responsible for obtaining valid consent and complying with all applicable data and privacy laws before you do so. Please review this Privacy Policy carefully. To the extent not prohibited by applicable law, by using the Websites, Services, applications, or platforms you are agreeing to the terms and conditions of this Privacy Policy.
QUICK GUIDE TO CONTENTS
1. INFORMATION WE COLLECT
1.1. Information You Provide
1.2. Information Automatically Collected
1.3. Information Collected from Other Sources
1.4. Notice Regarding Third-Party Websites, Social Media Platforms and Software Development Kits.
1.5. Combination of Information
2. OUR INFORMATION USE
2.1. Use By or For Dompé
2.2. Interest-Based Advertising
3. INFORMATION WE SHARE WITH OTHERS
4. YOUR CHOICES AND OPT-OUTS
4.1. Cookies, Tracking Options, and California Do Not Track Disclosures
4.2. Interest-Based Advertising Choices
4.3. Unsubscribing from Our Marketing Communications
4.4. Updating Your Information
4.5. Your GDPR Rights
5. CHILDREN'S PRIVACY
6. DATA RETENTION AND SECURITY
7. INTERNATIONAL TRANSFER
8. REVISIONS TO THIS PRIVACY POLICY
9. HOW TO CONTACT US
10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
1. INFORMATION WE COLLECT
There are several ways we may obtain different types of information about or from you, including: (1.1) information you provide to us directly; (1.2) information that we automatically collect; and (1.3) information we collect from third parties. This includes data that is de-identified or that identifies you personally whether directly (i.e., your name) or indirectly (i.e., information about your online use).
1.1 Information You Provide
The categories of information we collect depend on whether you are a visitor of our Websites, platforms or applications, a health care professional, a patient, and or a participant in a clinical trial, and the requirements of applicable law.
Your Interactions with Dompé. Dompé collects information from you when you choose to share it with us through our, or when you register online through the Websites, and or the platforms or applications we offer for instance to request information from us, sign up for our email lists, request patient or professional support, or otherwise communicate with or contact us online, via email or over the phone.
When Websites, platform or application visitors elect to sign up to hear or engage with us the information we collect may include first and last name, reason for contacting us, zip code, email, and in some cases other contact information including a telephone number.
When HCPs sign up to receive information via email in one of our Websites, platforms, or applications, and or via our Services, we may collect the information detailed below under Medical Affairs below.
In connection with your participation in clinical trials and where we are required to by law or regulations (such as adverse event reporting requirements), we may collect driver’s license, passport number, tax identification number, and health information related to your medications, medical history medical insurance details, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history. We collect and use such information only after you have provided your prior written consent to disclose that information to us, and only in compliance with applicable law. Any clinical trial or study personal data will be coded to ensure that your identity will remain confidential. To maintain confidentiality, access to personal data that could identify you directly will be restricted to the persons performing the study or persons allowed access by law, and otherwise in pseudonymized form. All clinical or study personal data will be treated in compliance with applicable law.
We also collect information in the regular course of our business for the following purposes:
Commercial. We may collect various information from visitors to our page, our vendors, partners, and HCPs. Such information may be in connection with Services provided by us for marketing purposes for instance, or in connection with services provided to us by third parties. Examples of information we collect in a commercial context include but are not limited to, as applicable, your entity name, first name, last name, age, gender, home or business address, home or business phone and fax number, medical specialization, email address, professional qualifications, license number, scientific society membership number, institution, practice name, national provider identifier aka NPI, and in some cases banking information.
Regulatory and Pharmacovigilance Requirements. We are also obligated to collect certain personal information to comply with regulatory and pharmacovigilance requirements, including information relating to any adverse effects you may have experienced when using our products.
Medical Affairs. We may collect various types of information from HCPs who wish to hear about or company or product(s), and or as part of scientific exchange activities with such HCPs and or consulting activities, including but not limited to first name, last name, age, gender, home and practice address, fax and phone number(s), medical specialization, email address, professional qualifications sometimes in the form of curriculum vitaes (“CVs”), license numbers and scientific society membership numbers, institution or employer name, practice name, NPI, banking information, images, videos, likeness, voice recordings. We may also collect and store investigator, sponsor, contract research organization (“CRO”), and institutional employee contact information, including names, addresses, phone, fax numbers and email addresses.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we may collect personal information from individuals who interact with or express an interest in Dompé U.S. and/or our products or Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Surveys. We or third parties on our behalf 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 or third parties on our behalf 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.
Patient Enrollment Form. When you elect to be enrolled in Dompé U.S.’ patient support program Dompé CONNECT to Care (“DC2C”) you consent to provide and authorize your health plans, health care providers, healthcare clearinghouses, and their business associates, such as Dompé U.S.’ specialty pharmacy and or pharmacy hub (“Covered Entities,” as such term is defined under the Health Insurance Portability and Accountability Act) to share your personal, demographic, contact, and health and treatment information with Dompé U.S. and or certain third parties working with or for Dompé U.S. to provide you Services related to your prescription for a Dompé U.S. product. Dompé U.S. only receives such information if you have chosen to enroll in the DC2C program by signing the enrollment form.
In Response to Your Inquiries or Requests. Wherever you write Dompé U.S. an email or letter, and or contact us or a third party engaged by us to answer and triage emails or phone calls on our behalf for any reason, we may collect personal and contact information or other types of information depending on the nature of your inquiry. Please note that some phone calls may be recorded and that we may keep a copy of the recording for quality assurance or other reasons. We will always inform you that a call is being recorded when the call begins so you may choose to continue with or end the call.
Employment. Whenever you partake in our recruitment efforts and or apply to Dompé U.S. for employment, and or internships, we may collect your personal and demographic information, contact information, and CV information, and other types of information as applicable. The privacy notice that governs our recruiting activities is located here.
1.2 Information Automatically Collected
Whenever you visit or interact with the Websites, platforms or applications we own or offer, we, as well as any of our third-party service providers, may use a variety of technologies such as Cookies (defined below), web beacons, pixel tags, log files, local shared objects (flash cookies), HTML5 Cookies, or other technologies to automatically or passively collect certain information about your online activity.
Please note that we may automatically collect the following information about you:
Computer or Device Information. We may automatically collect your Internet Protocol (“IP”) address, MAC Address, mobile carrier, or other unique identifier or information from the computer, mobile device, tablet or other device that you use to access the Websites, platforms or applications, including but not limited to your browser type, device type, operating system, software version, phone model, phone operating system, and the domain name from which you accessed the Websites.
Usage Information. We may collect information about your use of the Websites, platforms or applications, including for instance, the date and time you visit the Websites, the areas or pages of the Websites that you visit, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, other click-stream or site usage data, emails that you open, forward or click-through to our Websites, and other Dompé U.S. owned platforms or applications you may visit.
Location Information. We collect general information about where traffic on our Websites is coming from around the world. This is used at an aggregate level that does not identify individual users to create reports to better understand our engagement with visitors to the Websites. Location information at an individual level may be used for narrowly tailored efforts for our products or research activities.
Our Third-Party Service Providers. We, as well as third parties that provide content, advertising, or other functionality on the Websites, applications or platforms may use Cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with us through the Websites, applications, or platforms.
Use of Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools, including Google® Analytics, to better understand who and how people are using the Websites, application or platforms, and how to improve the effectiveness of these, and related content. These tools may use technology such as Cookies, web beacons, pixel tags, log files, Flash Cookies, HTML5 Cookies, or other technologies to automatically collect and store certain information. They may also combine information they collect from your interaction with the Websites with information they collect from other sources.
Cookies. "Cookies” are small text files that are stored on users' computers by the websites they visit. They are used to make websites work and operate more efficiently and to provide information to the website owners. The Websites use Technical Cookies, Google Analytics Cookies and Third-Party Cookies, all of which are detailed below.
Technical Cookies - These are installed by the owner of a website, and can be divided into browser or session Cookies, enabling a correct browsing experience and use of the Websites (for instance, they help define a browsing session or select the Website language or font size).
Google® Analytics Cookies
Usage of a visitor’s IP address by Google Analytics Cookies
Each computer and device connected to the Internet is assigned a unique IP address, in numbers. Since such numbers are typically bundle-assigned to countries, an IP address can be used to identify the country, province and city from which a computer is connecting. Google Analytics retrieves the IP addresses of the Dompé U.S. Website visitors to provide an indication of their geographic location. This method is called “IP geolocation”. Google Analytics does not report information about the visitor actual IP addresses. The use of IP masking allows Google Analytics to communicate information using only a part of the IP address for geolocation. Google may disclose information to third parties where required by law or where such third parties process information on Google’s behalf.
Browser add-on for deactivating Google Analytics Cookies
You can disable Google Analytics using a browser add-on component; it tells the JavaScript code from Google Analytics (ga.js) to specify that the information about the Website visit should not be sent to Google Analytics. The browser add-on does not prevent information from being sent to the Website itself. In addition, most browsers allow some control of most Cookies through the browser settings. If a user doesn’t wish to receive Cookies of any type on their computer, the privacy protection level of the browser can be elevated using the appropriate option. However, some areas of the Websites may not function properly if Cookies are denied.
Third-Party-Cookies
These Cookies are installed by third parties through the Websites. With regard to these Cookies, the Website owner and editor are just technical intermediaries and cannot define the procedures and purposes of the operation of said Cookies. For information on the third-party Cookies in use, refer to the websites of the third-party website suppliers. You can accept or reject Cookies by changing your browser security settings. You’ll find instructions on how to set up the most common browsers below.
1.3. Information Collected From other Sources
We may acquire information from other sources as follows:
From third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, information from public databases or data aggregators (which may include information to validate or update the information we collect from or about you).
From our partners and service providers (including, for example, business partners or vendors, analytics vendors, and search information providers).
From third-party log-in services or social networking sites you use to access our Websites, platforms, applications, and or any of our Services. This information includes any information you have made public via your privacy settings, such as your name, location, gender, birth date, email, or contacts. This supplemental information allows us to verify information you have provided to us and to enhance our ability to provide you with information about our business, product(s), and Services.
We may use this information to help us maintain the accuracy of the information we collect, to enable us to render our Services to you, target our communications so that we can inform you of products, services or other offers that you have identified or we determine may be of interest to you, and or for internal business analysis or other business purposes.
1.4. Notice Regarding Third-Party Websites, Social Media Platforms, Application Programming Interfaces and Software Development Kits.
The Websites, applications, or platforms may contain links to or from third party services, websites, applications, application programming interfaces (“APIs”), social media platforms, software development kits (“SDKs”) (“Third Party Sites”). We encourage our users to read the privacy policies of each Third Party Site with which they interact carefully. Dompé U.S does not endorse, screen or approve, is not responsible for and specifically disclaims liability for the privacy practices or content of such Third Party Sites. Visiting these other Third Party Sites is at your own risk.
Our Websites, applications, platforms or Services may include publicly accessible Third Party Site blogs, forums, social media pages, and private messaging features. By using such Third Party Site features you assume the risk that the personal information provided by you may be viewed and used by such Third Party Sites for any number of purposes over which Dompé U.S. exercises no control. In addition, social media buttons from Third Party Sites like Facebook®, Twitter®, and LinkedIn® (that might include widgets such as the “share this” button or other interactive mini-programs) may be integrated into our Websites, platforms or applications. These Third Party Site features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. These social media features may either be hosted by a Third Party Site or be hosted directly on our Websites, platforms, or applications. Your interactions with these features apart from your visit to our Websites, platforms, or applications are governed by the privacy policy of the Third Party Sites that offer such platforms, blogs, forums, social media pages, and or private messaging features, so we recommend that you read the privacy policies applicable to such Third Party Sites.
Our Services, Websites, platforms or applications may use APIs and SDKs which may allow third parties including analytics and advertising partners to collect certain information from you for various purposes over which Dompé U.S. exercises no control including but not limited to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us at: privacy@dompe.com.
1.5. Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Websites, platforms or applications, as well as information collected offline, from Third Party Sites and from third party sources.
2. OUR INFORMATION USE
2.1. Use by or for Dompé U.S.
Dompé may use the information we collect from and about you for any of the following purposes:
To render Services to you, verify your information, respond to your inquiries, contact and or communicate with you directly or indirectly through third parties when necessary or when you request that we do so;
To review the usage and operations of our Websites, platforms, applications and conduct analyses or research to develop, enhance, demonstrate, maintain the quality and safety of and or improve our or our parent company’s content, products, and Services;
To advertise on the Websites, platforms or applications and or to tailor any promotional content or advertisement and send such advertisement directly to you via mail or email, or across Third Party Sites;
To contact you, including directly or indirectly through third parties, by any means you have consented to or that are otherwise permissible, with information, newsletters from or about Dompé U.S. or the products it distributes on behalf of Dompé U.S.’ affiliates, and or to request information from you relating to your use of our products and Services;
To use your data in an aggregated non-specific format for analytical and demographic purposes;
To address problems with and to protect the security or integrity of the Website, our platforms, applications, and our business, including by debugging to identify and repair errors that impair existing intended functionality, and to defend and prosecute those responsible for any malicious, deceptive, fraudulent, or illegal activity;
In connection with the DC2C patient program, provided that you have signed our enrollment form we will receive the information contained in the enrollment form that you or your physician will fill out, and will use it only for the purposes listed in the form which are as follows:
To establish eligibility for DC2C benefits.
To communicate with you and or with Covered Entities about your medical care and coverage.
To facilitate, assess, support or improve the provision of Dompé U.S. products, supplies, or Services provided by Dompé U.S. or through a third party, including, but not limited to our access hub(s) or specialty pharmacy(ies).
To enroll you in patient or product support programs offered by Dompé U.S. or other entities for which you may be eligible based on your health information, including but not limited to any Dompé U.S. product patient support program, and or certain nursing support services, if available.
To use and share your information to send you or cause third parties to send you communications and or information regarding your experience with access to and use of Dompé U.S. products or Services. Such communications may include survey and other market or clinical research invitations, as well as marketing communications.
For business related activities such as contact options, planning, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We or our parent company may use personal information to create non-identifiable information to be used alone or in the aggregate together with information obtained from other sources to help us deliver existing products or Services or develop new ones or for public health, research, analytics.
For any other purposes disclosed at the time you provide your information.
For any purposes for which you have consented or directed us to use it.
As otherwise required by law, for instance to comply with regulatory, pharmacovigilance or other legal requirements, including to investigate, track, and/or report on adverse events or effects resulting from your use of our product(s) or Services, and
As otherwise permitted by law.
2.2. Interest-Based Advertising
We may use third parties to measure and target advertisements for us about our products and Services that are tailored to your online interests, this is commonly referred to as targeted or interest-based advertising. We allow these third-party companies to use Cookies, web beacons, pixel tags and similar technologies to track and collect certain data and other information about your online activity. This information is used to display advertisements for Dompé U.S. on the Websites, platforms or applications, and or across Third Party Sites that you visit.
For information on your choices with respect to targeted or interest-based ads, see the “Interest Based Advertising Choices” paragraph of the Your Choices and Opt-Outs section below.
3. INFORMATION WE SHARE WITH OTHERS
Except as provided below, we will not disclose, sell, or rent any of your information to any third parties. We may share the information we collect from and about you with the following parties:
Affiliates: We may share your information with Dompé U.S. affiliates and subsidiaries for business, operational, promotional and marketing purposes, Dompé farmaceutici S.p.A., our parent company, in Italy may process the information for administrative, marketing, and organizational purposes as Data Controller (as defined under art. 4 of the EU General Data Protection Regulation n. 2016/679, as may be updated from time to time ("GDPR")), in order to coordinate and supervise the activity carried out by its subsidiaries, including Dompé U.S. and other Dompé farmaceutici S.p.A. subsidiaries. Dompé farmaceutici S.p.A. will act in compliance with the obligations set forth under the GDPR, and or any other laws applicable to it.
Business Partners: Dompé U.S. may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. When we partner with another business, Dompé U.S. requires our business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which Dompé U.S. provided them.
Service Providers: We may share your information with third party service providers that provide business, professional or IT and or other technical support functions to us, help us operate our business and the Websites, platforms or applications, and or provide analytics, customer service, support or administer activities on our behalf whether on our ours or their operating systems.
Legal, Regulatory and Pharmacovigilance Requirements; Safety: We may access and disclose your information with government entities or agencies to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, regulatory and pharmacovigilance requirements, as permitted or otherwise required by law. We may need to give access to or disclose your information to protect the security of our Websites, applications, platform servers, network systems, and databases. We also may disclose your information as necessary, if we believe it is necessary to protect our legal rights, or the rights of any third party.
Sale or Transfer of Business or Assets and or Joint Venture: If we are involved in a joint venture, 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. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Websites in a manner that is consistent with this Privacy Policy.
Aggregate or De-Identified Non-Personal Information: We may also share aggregate, or de-identified non-personal information with third parties for their marketing or analytics uses.
Advertising Partners, Internet Service, Data Analytics and Social Network Providers: Through our Services Websites, platforms, or applications, 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 Third Party Sites) for purposes of delivering targeted advertisements to you when you visit Third Party Sites 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 through our Websites, platforms, or applications 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 in the Your Choices and Opt-Outs section. In certain U.S. states, the sharing of the information in this section, including but not limited to identifiers, and or IP or network information with third parties like online advertising networks analytics provider and social networks, may be considered a sale, and you may have additional rights to set preferences and exercise a right to opt-out. See the “Additional U.S. State Privacy Disclosures” section to find out more.
Other: We may also share your information as disclosed to you at the time of collection or disclosure, and or share it with third parties to whom you or your agents have authorized us or directed us to disclose it.
4. YOUR CHOICES AND OPT-OUTS
4.1. Cookies, Tracking Options and California Do Not Track Disclosures
Certain parts of our Websites require Cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline Cookies, but by doing so, you may not be able to use certain features of the Websites or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on controlling your tracking preferences and or see the targeted or Interest Based Advertising Choices section below. To find out more about declining, deleting or disabling Cookies please refer to the paragraph that outlines our use of Cookies under the Information Automatically Collected section of this Privacy Policy.
Our system may not recognize Do Not Track requests or headers from some or all browsers. We may use cookies or other Technologies to deliver advertising for our products when you visit other Third Party Sites.
4.2. Interest-Based Advertising Choices
To understand your choices for receiving more relevant advertising provided on Third Party Sites and online services, please review the information below:
To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info.
To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit http://optout.networkadvertising.org.
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available https://tools.google.com/dlpage/gaoptout/.
On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
Please note you must separately opt out in each browser and on each device. Even if you opt out, you still may receive advertising from us that is not customized based on your service or usage information, or advertising from other third parties if they are not a DAA or NAI participating company.
4.3. Unsubscribing from our Marketing Communications
We provide our Websites visitors with the opportunity to update their information or opt out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your request. To opt out of marketing communications, you may:
Send us an e-mail at privacy@dompe.com
Contact us by mail at the address below in the “How to Contact Us” section or
Unsubscribe from our email communications at any time by selecting unsubscribe in the email you received.
If you receive marketing communications from one or more Dompé U.S. affiliates, you must opt-out individually from each specific mailing list by following the instructions in the email communication and or by sending an email to privacy@dompe.com.
Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable, in accordance with applicable law.
4.4. Updating Your Information
If you wish to update any of your personal information, you may contact us at the address or e-mail in the “How to Contact Us” section below.
4.5. Your GDPR Rights
When applicable, GDPR gives you certain privacy rights which include: the right to request access to your information at any time, the right to request correction of your information; the right to object to processing of your information, the right to restrict processing of your information and to request erasure; the right to request transferring some of your information to other organizations. To exercise your privacy rights please contact us as set forth in “How to Contact Us” section below.
5. CHILDREN’S PRIVACY
Protecting children’s privacy is important to us. We do not direct the Website to, nor do we knowingly collect any personal information from, children under the age of eighteen (or other age as required by local law). If you learn that your child has provided us with personal information without your consent, you may contact the Dompé U.S. Privacy Officer as set forth above. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information unless we have a legal obligation to maintain it and will terminate the child’s account.
6. DATA RETENTION AND SECURITY
We store the information we receive as described in this Privacy Policy for at least as long as as necessary to fulfill the purpose(s) for which it was collected and or as otherwise required to comply with applicable laws.
We have taken certain physical, administrative, and technical steps to safeguard the information we collect and store. To find out more about our security specifications, please write to us at: privacy@dompe.com.
While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.
By providing personal information, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Websites, applications, platforms, and Services. If we learn of a security system’s breach, we will notify you, as required to comply with applicable law.
7. INTERNATIONAL TRANSFER
The information we collect from you may be stored on servers in the European Union and or the United States depending on the purpose for which it was collected; however, some of our brands, subsidiaries, parent company, and service providers with which we may share you information, as disclosed in this Privacy Policy, may store information on servers hosted in other countries. As such, your personal information may be subject to the laws of other countries, where privacy or data protection and other laws may differ from those of the European Union and or the United States. Your information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.
8. REVISIONS TO THIS PRIVACY POLICY
We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post an updated Privacy Policy on the Websites, applications, platforms or Services. Your continued use of the Websites, applications, platforms or Services following the posting of changes to this Privacy Policy will indicate that you accept these changes. If we change the Privacy Policy in a way that materially affects your rights, we will notify you as required by applicable law.
9. HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at privacy@dompe.com or by mail to:
Dompé U.S. Inc.
Attn: Privacy Officer
181 2nd Ave Ste. 600
San Mateo, CA 94401
And or
Dompé farmaceutici S.p.A.
Attn: Privacy Officer
Via San Martino 12/12a, Milan
20122 Milano, Italy
10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
Nevada Residents: If you are a resident of the state of Nevada in the United States, please note Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@dompe.com with the subject line “Nevada Opt-Out.”
California, Colorado, Connecticut, Utah, and Virginia Residents: For the residents of the States of California, Colorado, Connecticut, Nevada, Utah and Virginia, these Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our Services, please read our Privacy Policy.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or de-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
Collection and Use of Personal Information
We collect personal information from and about individuals for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal information, and the purposes for which we use or share this information please refer to the “Information We Collect”, “Our Information Use”, and the Information We Share With Others sections of our Privacy Policy.
Sensitive Information
Some of the categories of personal information elements we collect may be classified as “sensitive” under U.S. state privacy laws (“sensitive information”), including racial or ethnic origin, citizenship or immigration status, health information, government identification numbers (such as social security number, driver’s license number, state ID card number, or passport number), account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, the contents of a consumer’s mail, email, or text message, information concerning sex life or sexual orientation. We use this information for the purposes set forth in the “Our Information Use” section of our Privacy Policy.
De-identified Information
We may receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
Your Privacy Rights
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations of law):
The Right to Know: The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you in the last 12 months, including:
The categories of personal information collected;
The categories of sources of the personal information;
The purposes for which the personal information was collected;
The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
The Right to Access and Portability: The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Request Deletion: The right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Correction: The right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
The Right to Opt-Out of Sales or Sharing for Targeted Advertising: The right to direct us not to “sell” personal information we have collected about you to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to direct us to limit the use of your sensitive personal information to certain purposes, including for instance only to perform our Services or provide our products or goods or products, in a reasonable manner as may be expected by an average consumer who requests those goods or services.
The Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
To submit a request to exercise one of the privacy rights identified above, please submit a request by either:
Filling out our Individual Rights Request Form and emailing it to us at: privacy@dompe.com and with a copy to: dpo@dompe.com with the subject line: “Consumer Rights Request”
Calling our toll-free number at: 1 (800) 868-2185.
When you make a request, we will make reasonable efforts to respond promptly to your requests in accordance with applicable law. We may ask you to provide information to verify your identity, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means, if needed, to verify your identity. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems and or if, for instance, we are prevented from doing so by applicable law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted or Interest-Based Advertising
Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information with third parties for cross-context behavioral advertising purposes and as further described in the Interest-Based Advertising paragraph of the Our Information Use section or the Our Information We Share With Others section of this Privacy Policy. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.
We may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
To exercise the right to opt-out of personal information sales or sharing for targeted or interest-based advertising see the Your Choices and Opt-Outs section, and or you may do the following:
Cookies-based Opt-Out (Do Not Sell or Share My Personal Information). To exercise your right to opt-out as it relates to the use of Cookies and other tracking technologies for analytics and interest-based advertising or targeted ads, please see the Interest Based Advertising Choices paragraph above and or refer to and use the specific opt out associated to the browser you are using. You must reset your preferences if you clear Cookies or use a different browser or device. The paragraph that addresses Cookies within the Information Automatically Collected section above includes links to opt out of Cookies within the most commonly used browsers.
Opt-Out of “Selling” of Personal Information. In limited circumstances we may share your personal information (such as your name, e-mail address, postal address, and phone number) with third parties who may use such information for their own commercial or business purposes. In certain states, this may be considered a sale. To opt out of such sharing, please fill out our Individual Rights Request Form.
Authorized Agents
In certain circumstances, you are permitted to use an authorized person or corporate entity to act as your agent (as that term is defined by the California Consumer Protection Act (“CCPA”)) to exercise your rights and submit requests on your behalf. Agents acting on your behalf to exercise your rights should follow the instructions in this Privacy Policy and in this section. When we receive an agent request we must verify that the request is valid and intentional (e.g. that it comes from you) so we may seek to verify your identity with you or the agent, and we will also verify the agent’s identity and its authority to act on your behalf. To the extent that we are unable to verify the identity of the agent acting on your behalf, we may request additional information before we process a request.
For requests to know, delete, or correct personal information, we require that you submit an Individual Rights Request Form together with one of the following to help us verify the agent’s identity:
a power of attorney valid under the laws of California authorizing your agent to act on your behalf for the purposes you elect; or
sufficient evidence to show that you have:
provided the authorized agent signed permission to act on your behalf; and
verified your own identity directly with us:
pursuant to the instructions set forth in these U.S. Disclosures; or that
You have directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales” or “sharing”, we require signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the Individual Rights Request Form.
Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
California-Specific Privacy Disclosures
This section of the notice applies solely to residents of the State of California.
Personal Information Collection
We collect the personal information described in the Information We Collect section of this Privacy Policy for the purposes described in Our Information Use section of this Privacy Policy. The personal information we collect may be information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We have collected the categories of personal data from consumers listed in the Information We Collect section of this Privacy Policy within the last twelve (12) months.
Sources of Personal Information
We obtain personal information as described in detail in the Information We Collect section of this Privacy Policy.
Use of Personal Information
We may use the personal information we collect as described in Our Information Use section and may disclose it as described in the Information We Share with Others section.
Disclosure of Personal Information
We disclose your personal data for a business purpose as set forth in the Information we Share with Others section above.
Sales of Personal Information and Sharing for Targeted and or Interest-Based Advertising
In the last 12 months, we have sold the following categories of personal information to third parties, subject to your settings and preferences and your right to opt-out:
Identifiers
IP, Internet / network information
The categories of third parties with whom we may sell or share such personal information include:
Online advertising networks and analytics providers
Social networks
Minors
We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at 1 (800) 868-2185 or at privacy@dompe.com to inform us if you, or your minor child, are under the age of 16.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacy@dompe.com or call us at 1 (800) 868-2185. We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).
“Shine the Light”
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at privacy@dompe.com, or call us at 1 (800) 868-2185.