Privacy Notice

Notice Effective Date: February 2022

Ferring Pharmaceuticals Inc. (“Ferring”) values your privacy. In this Privacy Notice (“Notice”), we describe how we collect, use, and disclose information that we obtain about our visitors to our website www.ferringusa.com (the “Site”) and other Ferring services and activities that display or reference this Notice (the “Services”), and how we may use and disclose that information.

This Notice applies to individuals we interact with in the United States through the Site and Services, including website visitors, patients, healthcare professionals, and job applicants (collectively, “Individuals,” “you,” or “your”). This Notice does not apply to patients and healthcare providers who participate our clinical trials or provide us with drug safety information. By visiting the Site, or using any of our Services, you agree that your personal information will be as described in this Notice. Your use of our Site or Services, and any dispute over privacy, is subject to this Notice and our terms of service, including applicable limitations on damages and the resolution of disputes. The Ferring terms of service are incorporated by reference into this Notice.

For individuals outside of the United States or with Pharmacovigilance privacy concerns, policies are available at our Global Privacy Policy click here.

What Personal Information We Collect

Contact Information: For example, we may collect your name, personal or professional mailing address, phone number, and e-mail address.

Demographic Information: When you provide it to us, we may collect your age, gender, marital status, disability, and date of birth.

Government Identifiers: We may collect your Social Security number, driver’s license number, or State ID card number if you are a patient or healthcare professional.

Professional Information: For example, if you are a healthcare professional, we may collect details about your workplace, position, the medical field in which you are active, your professional qualifications, and scientific activities (such as previous clinical trials and participation in previous or ongoing studies at Ferring and others), publication of academic or scientific research and articles and membership of associations and boards.

Health Information: For example, we may collect patient health information in limited circumstances, including information about your health condition, diagnosis, insurance, and treatment information when you have provided consent or your healthcare provider has obtained your consent to disclose that information.

Financial Information: For example, we may collect your account number, credit or debit card number, or other financial details including direct identifiers that would permit access to an individual’s financial account.

Internet and Network Activity Information: We collect information about your use of the Site, such as information about the date and time you access our Site, frequency of use, engagement with particular features, and which sections of the Site are visited most. We may also collect information about the browser you are using, your IP address, and device identifiers.

Online Identifiers. For example, we collect IP address, unique device ID, cookie IDs and other information about your device.

Employment-Related Information. When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa to work in the United States, and/or salary expectations.

Other Information from Your Interactions with Us. We collect details of the interactions you have with us such as topics discussed, your questions about our business, products and services and your feedback. For healthcare professionals, we also collect information your views and routines about prescribing, routines related to your patients and diagnosis, and similar data.

Where/How We Collect Personal Information

We collect personal information about you from:

You. We collect personal information directly from you when you provide your information on our Site, enroll in a program that Ferring offers, apply for a job, or communicate with us.

Service Providers. We work with service providers who collect information on our behalf in order to provide services to us. We only allow our service providers to use your personal information in connection with the services they provide us, and for purposes permitted under law (such as security and fraud protection).

Third-Party Advertising Partners. We may use third parties such as ad networks and other partners to serve our ads on third-party websites or other media (e.g., social networking platforms). This enables us to target advertisements for our products and services to you. Our third-party advertising partners, including third-party ad network providers, advertisers, sponsors and/or traffic measurement services, may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you.

Third-Party Business Partners and Public Sources. We may collect personal information from other third parties, including companies that have organized activities sponsored or supported by Ferring; public sources, recruitment agencies, interim offices, and third parties, such as IQVIA, etc.

Cookies and Similar Technologies. Our web sites collect information by depositing certain bits of information called “cookies” in a visitor’s computer. The cookies can tell us how and when pages in a web site were visited and by how many people. This information will enable us to improve our web sites to serve and inform you better. It also may allow you to shortcut access to points of interest on our web site when you re-enter our system. We use the following types of cookies:

• Strictly necessary cookies. These cookies are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our web site. This category of cookies cannot be disabled.
• Analytical cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. Information collected by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States. To see an overview of privacy at Google, visit https://www.google.com/intl/en/policies/privacy/. You may opt out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
• Advertising or targeting cookies. These cookies make advertising more relevant to you and your interests. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners (e.g. ad networks and advertisers) may use the cookies to build a profile of your interests and deliver relevant advertising on other websites.

How We Use Personal Information

We may use the personal information we collect about you:

• to provide information and the Services you requested;
• to contact you, via e-mail or regular mail, to provide you with information we believe may be of interest;
• to perform analyses designed to help us understand and serve our customers’ needs;
• to perform analyses designed to help us understand the utility of the services we provide online;
• to process and respond to questions regarding data privacy and your privacy rights;
• to process and assess reported cases for potential misconduct and/or violation of the Ferring Philosophy as well as other applicable Policies and SOPs;
• to process reports from patients regarding side effects, adverse drug reactions, adverse events or other safety information relation to a Ferring drug/product;
• to manage our business relationship with healthcare professionals;
• to comply with applicable laws and regulations;
• to process applications for current vacancies and/or accept unsolicited job applications;
• for any other legitimate business purposes such as data analysis, audit, public relations and marketing, improving your customer experience and our services, and expanding our business activities.

We may also use your personal information for other purposes disclosed to you at the time you provide personal information or with your consent.

With Whom Do We Share Personal Information

With Service Providers.  We share your personal information with service providers acting on our behalf to help us with the purposes described in the previous section.

We will also disclose your personal information to our third partners in the following circumstances:

• a legitimate business need or purpose exists, including performing services such as customer service, website management, order fulfillment, protecting the security of the Site or Services and the integrity of the personal data, and other similar services ;
• where applicable, as a result of a request by you;
• where we are required to do so under applicable laws or local statutes, or with government or regulatory agencies consistent with our legal obligations;
• where third party is an advertising partner that helps us deliver, measure, and analyze the effectiveness of our ads; or
• where Ferring decides to sell, buy, merge or otherwise reorganize its business structure.

We may also share personal information for other reasons we may describe to you from time to time as permitted by law.

Your Privacy Choices

Opt Out of Marketing Emails. You can opt out of receiving our marketing emails. To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us. You can also make a request at Data Subject Contact Form or call toll-free at 1-888-FERRING (1-888-337-7464). Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions or emails related to actions you take on our Site.

Opt-Out of Cookies and Other Technologies. You may disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to disable all cookies (including strictly necessary cookies) you may not be able to access all or parts of the Site.

Users in the United States may also opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites.

Disabling a cookie or category of cookie does not delete the cookie from your browser. You will need to do this separately within your browser. If you have disabled one or more analytical cookies, we may still use information collected from cookies prior to your disabled preference being set. Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info and the NAI’s website at www.networkadvertising.org.

You can also exercise your choices by contacting 1-888-FERRING (1-888-337-7464), Monday through Friday, 8 AM to 7 PM ET to speak to a representative or leave a voicemail. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads).

California Privacy Rights

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. We do not currently engage in this activity.

If you reside in California, you also have the right to make the following requests with respect to your personal information:

• You have the right to request that we disclose the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or disclosed, the business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we share the personal information, and the specific pieces of personal information collected about you over the past 12 months.
• Deletion. You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
• Correction. You can request that we correct personal information about you that you believe to be inaccurate.  We may ask you to provide documentation to confirm the accuracy of your information.
• Opt-out. Under California law, our use of cookies for online advertising may be considered a “sale” or “sharing” of your personal information.  You have the right to opt out of this activity.
• Right to be free from discrimination. You have the right not to be discriminated against for exercising these rights.

We do not use or disclose sensitive personal information outside of the purposes for which it was collected.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Employment-related information will not be included in fulfillment of your requests. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity. You may exercise the above rights by calling our toll-free number at 1-888-FERRING (1-888-337-7464) or contacting us at Data Subject Contact Form.

Do Not Track

We do not currently respond to browser do-not-track signals. Instead, we adhere to the standards set out in this Privacy Policy and offer the opt-out choices described above.

Some browsers offer you the ability to opt out of cookie-based and other online tracking, which may be considered a “sale” or “sharing” of your personal information. We will respond to those signals in the same manner in which we respond to opt-out requests made through this policy or on our Site.

Notice at Collection

The information below is the information we are required to provide to California residents when their information is collected. Additional information on our privacy practices can be found throughout this Privacy Policy.

• We may collect the following categories of personal information as set forth in applicable California law:
  • Contact Information
  • Demographic Information
  • Government Identifiers
  • Professional Information
  • Health Information
  • Financial Information
  • Internet and Network Activity Information
  • Online Identifiers
  • Employment-Related Information
  • Other Information from Your Interactions with Us.
• We collect and use these categories of personal information for the business and commercial purposes described here
• We collect these categories of personal information from the sources described here

Under California law, our use of cookies for online advertising may be considered a “sale” or “sharing” of your personal information.  We may sell or share the following information:

• Internet and Network Activity Information
• Online Identifiers

You can opt-out by clicking here –Data Subject Contact Form.

We retain your personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, and in accordance with our legal obligations

Security

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Further, we take steps to limit access to personal information to certain Ferring personnel only – and per a need to know basis. We also take steps to educate our personnel about their obligations to protect your privacy rights as they relate to your personal information that may be collected.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Links to Other Sites

As a resource to our visitors, Ferring may provide links to other web sites. We try to choose web sites that we believe are useful and meet our high standards for the accuracy and utility of information. However, because web site design and content can change so quickly, we cannot guarantee the standards of every web site to which we link. Likewise, we are not responsible for the content of any non-Ferring site. We also cannot guarantee the privacy policies of these other sites and suggest you check the privacy policies of those sites directly.

Location of Personal Information

Information we collect from you may be transferred to, processed in, or stored in the United States or another destination outside of the European Economic Area (or “EEA”). Personnel operating in these locations who work for us or one of our business partners may process information. The European Commission does not consider the standard of data protection in the United States and in certain other countries where we may process your information to adequate when compared to the data protection standards of the European Union and EEA. By using our Services, or by submitting your personal information on our Site, you consent to such transfer, storing and processing. We protect the transfer of personal information from the EEA and European Union using standard contractual clauses or other approved transfer mechanisms.

Children

Ferring does not intentionally collect or retain personally identifiable information from children who are younger than 18 years of age. If your child may have submitted information to us without indicating his or her actual age, and you would like it removed, please contact us at Data Subject Contact Form, and we will delete it immediately.

Particularly, our Services are not for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Changes

Any changes to this privacy Notice will be communicated promptly at this location. Please check the privacy page periodically to review any changes, which we reserve the right to implement at our own discretion and pursuant to internal Ferring directives.

Contact Information

If you have any questions, concerns or requests regarding this Privacy Notice, please contact us at Data Subject Contact Form or call toll-free at 1-888-FERRING (1-888-337-7464).