Privacy Policy

Privacy Policy

LEO PHARMA INC.

Last Updated: May 16, 2016

LEO PHARMA INC. (“LEO,” “we,” “us,” or “our”) provide this Privacy Policy because we know that you care about how your information is collected, used, shared and retained. This Privacy Policy applies to information collected when you visit any LEO website identified as LEO QualityCareTM (the “Websites”), or use the services that we make available via the Websites from time to time (the “Services”). Our Services may include offering you the opportunity to become a registered user of the Websites, receive information on products, disease awareness, research studies, and/or participate in LEO-sponsored programs and initiatives. By visiting the Websites or using the Services, you consent to our collection, use, disclosure and retention of your information as set forth in this Privacy Policy.

The Information We Collect

LEO collects the following types of information via the Websites, both directly from you and indirectly through our third party service providers (our “Providers”).

Personal Information

“Personal Information” means any information or set of information that identifies or could be used by, or on behalf of, LEO, to identify a natural person. When you use the Services, we collect certain Personal Information that you provide such as your name, mailing address and email address. Personal Information does not include information regarding corporate entities or information that is encoded or made anonymous, or publicly available information that has not been combined with non-public Personal Information.

Other Information

Other Information collected when you visit the Websites or use the Services that does not identify you personally may include your IP address, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Websites you visit, number of links you click while on the Websites, search terms, operating system, website traffic and related statistics, keywords, key word searches and/or other data.

How We Use Your Information

We may use your Personal Information in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use such Personal Information in connection with the reason for which it was provided. For instance, we will use Personal Information to administer access to the Website and the Services; to improve the Websites and the Services; to permit our Providers to administer the Services and the Websites; to provide the Services and respond to other inquiries; to provide support; and for LEO, its successors, affiliated companies, and/or agents to communicate with you via email, newsletter, phone, sms, and/or regular mail regarding our products, Services and programs, and/or disease awareness. We may also use your Personal Information to carry out surveys, studies, evaluations, and to supply you with goods or services that you have ordered on the Websites. We may use your Personal Information and Other Information to personalize your experience on the Website, including serving advertisements regarding our products and services, and disease awareness, tailored to your interests.

If we intend on using any of your Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use and you will have the opportunity to opt out. You may choose not to submit your Personal Information at any time, but that decision may prevent you from accessing and/or using certain of the Services. You have the right to correct or modify your Personal Information by providing notice to us. (see “How to Contact Us”).

We may block users located in certain countries from using the Websites. We may retain and use your Personal Information and Other Information for as long as is required to fulfill our business objectives.

Aggregated Personal Information

We may analyze your Personal Information in aggregate form which does not identify you personally. We may share this aggregate data with our parent, affiliates, agents, advertisers, manufacturers and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

Sharing Your Information. There are certain circumstances where we may share your Personal Information and/or Other Information with third parties without notice to you, including:

  • Agents, Consultants and Related Third Parties. We, like many businesses, sometimes hire other companies to perform certain business-related functions. When we employ another company or third party to perform a function of this nature, we only provide them with the information that they need to perform their specific function. We may also share your information with our parent company, affiliates, or other companies under common control with us.
  • Legal Requirements. We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) protect the personal safety of users of the Websites or the public, or (d) protect against legal liability.
  • Business Transfers. As we develop our business, we might share your information with Providers, business partners or third parties. We may also sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets. If we transfer our business or assets to another entity, we will require it to honor the terms of this Privacy Policy, if applicable. We will not otherwise sell your Personal Information to third parties without first providing you with notice and choice to opt out.

Web Beacons and JavaScript Tags. LEO and its Providers use certain technologies, including the following:

  • JavaScript tags trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist). We may use JavaScript tags to help us tailor and optimize our Websites and provide you relevant LEO advertisements outside of our Websites.
  • Web beacons, also known as “clear gif” technology, are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web site users. Unlike cookies, which can be stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We may use web beacons to help us manage information on the Websites by tracking what information is effective.

External Websites

The Websites may contain links to third party websites. LEO has no control over the privacy practices or the content of those websites. As such, we are not responsible for the content or the privacy policies of those third party websites. You should check the applicable third party privacy policy and terms of use when visiting any other websites, and before providing any Personal Information to other websites.

Security

We take commercially reasonable steps to protect your Personal Information and Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Secured socket layer (“SSL”) technology is used for processing payment transactions with Providers. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Therefore, you acknowledge and agree that we assume no liability regarding the theft, loss, alteration or misuse of personal or other information or content, including, without limitation, such information that has been provided to third parties or other users, or with regards to the failure of a third party to abide by the agreement between us and such third party.

Accessing and Modifying Information

Upon request, we will grant you reasonable access to Personal Information that we and our agents have about you for the purpose of reviewing and/or requesting changes. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

Website Communications

If you register on the Websites, we may send you certain notifications, advertisements, promotions, and other information. We may also send you any legally required notifications and certain notifications, including but not limited to, service related notices or notices regarding a change to any of our policies. For example, we may send you a notice regarding server problems or scheduled maintenance to the Websites. In order to opt-out of receiving these notices, you may need to deactivate your account. You can opt-out of receiving certain communications from LEO, its successors, affiliated companies and/or its agents, including emails, mail, sms, and phone calls relating to our products, Services, and programs, and/or disease awareness information. We may provide various ways to opt-out, which may include opt-out boxes on materials sent by regular mail, and unsubscribe functions in emails. We will not change your preferences without your consent. You cannot, however, opt-out of receiving transactional communications from LEO related to your account. 

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Please be aware that, to the extent permitted by applicable law, our use of the Personal Information and Other Information is governed by the Privacy Policy in effect at the time we collect the information. If you visit the Websites or use the Services after a change to this Privacy Policy is posted on the Websites, you will be bound by such change. Please refer back to this Privacy Policy on a regular basis.

Important Notices to Non-U.S. Residents

The Websites and our servers may be operated in the United States and other countries. Please be aware that any information you provide to us may be transferred into and out of the United States. Unless you are a resident of the European Union (see “Transfer of Personal Information of European Union Citizens” below) your use of the Websites and your provision of information to us in any manner will be construed as consent to such transfers. 

Transfer of Personal Information of European Union Citizens

If you are a European Union citizen, we may transfer your Personal Information from the European Union to the United States or another country that the European Commission has determined does not ensure an adequate level of protection for such Personal Information, provided that such transfer is for a purpose that is consistent with this Privacy Policy, or necessary for performance of a contract between us, such as a purchase of Services or for the purpose of implementing pre-contractual measures for the contract, such as registration or creating an account.   

In response to the recent decision by the European Court of Justice that the Safe Harbor Framework is no longer a valid mechanism for transfers, we will use Model Contract Clauses (processor) approved by the European Commission in connection with such transfers when appropriate. We will also continue to abide by the Safe Harbor Framework, and adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement.

Children’s Privacy

As we are committed to protecting the privacy of children, we do not collect Personal Information from anyone who is, to our knowledge, under the age of 13.

Questions. If you have any questions regarding this Privacy Policy, please contact us as described in the “How to Contact Us” section. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question.

How to Contact Us

If you have questions about this Privacy Policy, please contact LEO via e-mail at us.privacy@leo-pharma.com with “PRIVACY POLICY” in the subject line or at the contact information set forth in the Contact page of the Websites.