Bioverativ is committed to respecting your privacy and we understand how important it is to protect an individual's personal information and apply the highest ethical and regulatory standards. An individual's health, health interests and healthcare are private and sensitive and we know that you may have concerns about sharing information with us.
INFORMATION WE COLLECT
As part of our day-to-day business operations, and from our interactions with you, Bioverativ may collect personal information about you. The personal information we collect is limited to information related to and needed for the conduct of our legitimate business purposes and/or fulfil commitments to you and fulfil our legal obligations. Bioverativ may be able to provide individuals with the option of not identifying themselves, or using a pseudonym when entering transactions when it is lawful and practicable to do so. However, we will not always be able to do this and in such cases, if you do not provide personal information, Bioverativ may not be able to provide services or information to you, or enter commercial engagements with you. We may have access to the following categories of personal information about you and only some of this information is personally identifiable information that could identify you directly, but each category may offer some information about your interests and activities that could be used to make inferences about you.
INFORMATION THAT YOU VOLUNTARILY PROVIDE OR IS LEGALLY REQUIRED:
- Biographic or commercial profile. As part of our interaction with you, we may be required to collect personal information about you in order to provide you with services or information you request, or in order to facilitate commercial engagements with you. This personal information may be collected directly from you through your interactions with our company, through services and content, including online, that we make available to you, or as result of services or other input you provide to Bioverativ. Such information may include name, age, contact details, employment history, education history including qualifications, occupation or business details including areas of specialisation.
- Sensitive personal information. Bioverativ avoids collecting sensitive personal information. However, in rare instances such as facilitating access to patient support offerings, Bioverativ may need to collect sensitive personal information including medical health, lifestyle and medical treatment requirements including current medications. In the event it is necessary to collect any sensitive personal information about you, we will gather your consent to do so. Where you have consented to your sensitive information being collected, that information may be collected directly from an individual or from third parties (e.g.Clifford Hallam Health Care, The National Blood Authority) in accordance with the terms of that consent.
INFORMATION THAT IS COLLECTED BY VISITING OUR SITE:
When you visit this Site, we have access to the following types of information about you:
- Site registration. Bioverativ has constructed this Site so that you may visit us and review information about the services and products we offer without revealing your identity or volunteering any personally identifying information. If you choose to register to use Bioverativ features and services, either as a consumer or a healthcare professional, we will collect "personally identifying information" from you, such as that indicated above, and this information may be combined, to provide you with services or information you request or to ensure that we maintain complete, current and accurate personal information.
- IP address. We record the Internet protocol (IP) address of your computer when you visit the Site. The IP address does not identify you personally, but it allows us to maintain communications with you as you move about the Site.
- Cookies. Cookies are small text files that are placed on your computer or other Web-accessing devices by our websites. These cookies allow us to distinguish you from other users of our website, and to enhance our website and your experience when you browse our website. We also collect information about your use of the Site through cookies and similar technology. Cookies allow us to recognise you and maintain your preferences when you return to our Site. Cookie technology collects "clickstream" data, which does not include personally identifying information, but which reflects your activities on the Site and helps us to customise our Site experience and anticipate what may be of interest to our users, by monitoring traffic in popular areas and modifying the services and information to meet customer demand.
We use the following types of cookies:
- First-party cookies - cookies set by the Site displayed in the browser window - identified by the domain name in the address bar of the browser window.
- Session cookies - cookies that expire at the end of a browser session, starting with the time when a user opens the browser window, and finishing when the user exits the browser.
- Persistent cookies - cookies that 'persist' in the device after the end of a browser session and therefore can allow the preferences or actions of the user to be remembered when they return to the Site.
- Direct users to the relevant sections on the Site.
- Make sure the Site delivers a consistent look across different browsers and devices.
- Enable complex areas of the Site to function.
- Track aggregated statistics about visits to the Site to help us improve Site performance.
We do not allow other sites or third parties to use our cookies for their own purposes.
Most Web browsers allow control of cookies through the browser settings. You can set your browser to notify you when you receive a cookie, which will enable you to decide if you want to accept it or not. However, if you do not accept a particular cookie, certain elements of the Site may not function correctly or completely.
To find out more about cookies, including how to see what cookies have been set and how to the delete them, visit www.allaboutcookies.org.
- Internet tags. Occasionally, we may use Internet tags (also known as Web beacons, action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies (collectively, "Data Collection Technologies") on this Site. We may deploy these tags and cookies through a Web analytical service partner, which may be located and store the respective information, including your IP address, in a foreign country that may provide different protection of personal information privacy, than the country where such information is collected. These tags and cookies are placed on different pages of this Site and we use this technology to measure the registered user's responses to our Sites, including how many times a page is opened and which information is consulted, as well as to evaluate use of this site.
- Online Advertising. Bioverativ also uses the Data Collection Technologies referenced above to help manage our online advertising programme. These Data Collection Technologies are provided by our ad management partners and other third parties. Bioverativ and our ad management partners may use these Data Collection Technologies to track the actions of users of the Site, to measure statistics of our marketing efforts, and to deliver advertisements on third party sites.
You can read more about online advertising at a site offered by the Office of the Australian Information Commissioner at www.oaic.gov.au/individuals/privacy-fact-sheets/general/privacy-fact-sheet-4-online-behavioural-advertising-know-your-options.
HOW WE USE YOUR INFORMATION
INFORMATION LIMITATION, PURPOSE AND DISCLOSURES:
- Limitation. Bioverativ will only collect personal information about you that is necessary for one or more of our legitimate business purposes, or is required by law. In addition, Bioverativ will only collect personal information by lawful and fair means and not in an unreasonably intrusive manner.
- Purpose. When Bioverativ collects your personal information, we will take reasonable steps to advise you of what personal information we are collecting, the purposes for which we are collecting the information and will use such information only for stated primary or related secondary purposes. Such purposes may include, from time to time, sending you promotional material or newsletters that we think may be of interest to you, administering support programmes, monitoring our regulatory compliance, compiling profiles and personal information about you in order to identify suitable education/awareness programmes or suitable opportunities to collaborate with you or obtain services from you.
- Disclosure. Bioverativ will advise you of the organisations (or types of organisations) to which we may normally disclose that personal information, and we will provide you with contact information in the event you would like access to your personal information we hold about you or need to update your personal information or preferences.
- Law enforcement. In certain circumstances, we may be called upon to release your personal information or sensitive/health-related personal information in response to a court order, subpoena, search warrant, law or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal information and/or health-related personal information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behaviour that is illegal or harmful to individuals or the personal information we are responsible for.
- Product reports. If you contact us regarding your experience in using one of our products, we may use the information you provide as necessary in submitting complaint or adverse event reports to local and international health or pharmaceutical regulators, and as otherwise required of us by law. We also may use the information to contact the prescribing physician to follow up regarding an unexpected event involving use of our product.
DISCLOSURE TO THIRD PARTIES
Bioverativ will not sell or disclose your personal information without your consent, except where such disclosure is reasonably necessary for normal business operations and such disclosure is in accordance with all applicable data protection and privacy laws.
We may use third parties to provide services and information and we may provide some co-branded services in partnership with others. We also may use third parties to analyse data collected in the course of our normal business operations, including on this Site. We will not disclose your personally identifying information to anyone other than our employees and those third parties with whom we have a business relationship.
- We have the individual's permission to make the disclosure
- The disclosure is required by law, legal process or mandatory professional standards
- The disclosure is reasonably related to the sale or other disposition of all or part of our business; but we will take reasonable steps to make you aware of such an event so that you might update your preferences in respect to how we process your personal information
- The information in question is publicly available
- The disclosure is reasonably necessary for the establishment of legal claims
- The disclosure is to another Bioverativ entity or to persons or entities providing services on our or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
- is subject to law providing an adequate level of privacy protection; or
- has contractually agreed to provide an adequate level of privacy protection
OTHER IMPORTANT INFORMATION ABOUT OUR RELATIONSHIP WITH THIRD PARTIES:
- Co-branded products or services. Bioverativ may partner with other companies to provide you with content or services on a joint or "co-branded" basis. At a co-branded site, you will see both the Bioverativ logo and the logo of the co-branded partner displayed on your screen. To access the services available on a co-branded site you may have to complete an online registration form, and this registration information may be shared with our co-branded partners. You should read the individual privacy policies of the co-branded sites, as these may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site. Remember, you may always opt-out of sharing your information with a partner site by choosing not to use the service or content provided by the co-branded site.
- Advertisers. We do not permit advertisers to display their advertisements at the Site.
PERSONAL INFORMATION TRANSFERS
Permitted transfers of personal data to third parties or within Bioverativ may include the transfer of data from one jurisdiction to another and may include transfers to a jurisdiction where the laws provide different protection than the jurisdiction in which the data originated, such as France and the United States of America. In such cases, we will take appropriate measures to protect personal data in accordance with this privacy statement and all applicable data-protection law.
OUR CHILDREN'S POLICY
The Site content and services are intended for users over the age of 18. The Site is not designed to attract child users. If we learn that an under 18 user has volunteered personally identifying and/or health-related personal information on the Site, or that a provider has volunteered information about a patient who is identified as younger than 18, we will delete such information from our active databases in accordance with our deletion policy, which is described in the section on privacy choices.
YOUR PRIVACY CHOICES
- Opt-in. When you access any interactive tool or service on the Site, you will be asked to affirmatively choose ("opt-in") to provide the requested information. You may always choose not to provide the requested information.
- Receive email. You may elect to receive email updates about developments regarding Bioverativ. If you decide, at any later time, that you no longer wish to receive these emails, you may unsubscribe to any such contact list by using the "Unsubscribe" links within the electronic communication channel, or by sending an email entitled "Unsubscribe" to email@example.com.
- Accept cookies. Your browser software can be set to reject all cookies, but if you reject our cookies certain of the functions and conveniences of the Site may not work properly.
- Do-not-track signals. Some Web browsers may transmit "do-not-track" signals to websites like ours. At this time, there is no industry or regulatory standard established on how to respond to such signals. Therefore, while Bioverativ is committed to respecting your privacy and we understand how important it is to use and protect any individual's personal information according to the highest ethical and regulatory standards. A person's health, health interests and healthcare are particularly private and sensitive and we know that you may have concerns about sharing information with us.
- Access/review/update personal information. If an individual becomes aware that personal information we maintain about them is inaccurate, incomplete, misleading, irrelevant or out of date, or if an individual would like to access, update or review his or her information, the individual may contact us using the contact information below. Bioverativ will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible, to advise you of the outcome of your request.
- Remove Personal information. You may request the removal of previously provided personal information at any time using the contact information below. Please be aware that we may not comply with a consumer's request to amend or remove information that was provided to Bioverativ by a healthcare professional or a consumer regarding an adverse drug event.
OUR SECURITY MEASURES
We want your personal information to remain as secure as reasonably possible.
- Data security. We employ various physical, electronic and procedural measures, including education and training of our personnel, designed to provide personal information with the highest reasonable protection possible from loss, misuse or unauthorised access, disclosure, alteration or destruction. The security measures we use to protect all personal information are designed to meet or exceed industry standards to prevent intruders from gaining access. Although we will make adequate and reasonable efforts to protect personally identifying information from loss, misuse or alteration by third parties, you should be aware that there is always some risk that an unauthorised third party could intercept an Internet transmission, or that thieves will find a way to thwart our security systems.
- Data encryption. We use encryption practices to help ensure the integrity and privacy of some of the personal information you provide to us. Personal information that is collected or displayed through any Bioverativ-controlled website is protected in transit by encryption processes that meet or exceed applicable regulatory standards.
If you have any concerns about the manner in which your personal information has been collected or handled by Bioverativ, or any queries in regard to this privacy statement or would like to advise us in respect to your choices as outlined above, please email us at firstname.lastname@example.org or click here to reach our Compliance Helpline.
You can also write to the following address:
Suite 10, 79-83 High Street
Kew, Victoria 3101
Bioverativ will review and respond to your concerns within a reasonable time. If you are not satisfied with our handling of your concern, you may have rights to complain to a regulator (e.g. for Australia, the Office of the Australian Information Commissioner. See http://www.oaic.gov.au for more information).