Synergy Pharmaceuticals online privacy policy

Effective Date of this Privacy Policy: January 19, 2017

Synergy Pharmaceuticals (“Synergy”) understands that you may have concerns about sharing your personal information with us. Synergy is committed to respecting your privacy. This Online Privacy Policy (“Privacy Policy”) will address your concerns about sharing your information with us by explaining how we handle the personal information provided to us on websites, including mobile applications and our social media pages, controlled by Synergy in the United States of America that link to this Privacy Policy (“Synergy Websites”).

This Privacy Policy does not apply to personal information collected from you offline, to Synergy Websites that do not link to this Privacy Policy, or to third-party Websites to which Synergy Websites may link. Your use of Synergy Websites that link to this Privacy Policy is subject to this Privacy Policy and the Terms of Use. http://www.synergypharma.com/terms-of-use

Please read this Privacy Policy before using Synergy Websites or submitting information to us. This Privacy Policy is designed to help you better understand how Synergy uses and shares your information and protects your privacy when you use Synergy Websites.

Synergy is committed to protecting your privacy and we want to ensure that you understand what we collect from or about you, how we use it and the safeguards we have in place designed to protect it. Synergy may update this Privacy Policy from time to time. Please check this Privacy Policy periodically for changes. If we make any changes, the updated policy will be posted on Synergy Websites with a revised effective date. We encourage you to periodically review this page for the latest information on our privacy practices.

TYPES OF INFORMATION WE COLLECT ONLINE

In the regular course of business, Synergy acquires personal information by interaction and communication with patients, healthcare professionals, employees, and others. The types of personal information that we may collect while you use the Synergy Websites are described in this section. Only some of these categories of information identify you directly, but each category offers some information about your interests and activities that could be used to make inferences about you. We may supplement the information we receive from you with information about you that we receive from other sources, such as public databases, joint marketing partners, social media platforms and other third parties.

Information You Voluntarily Provide

Some of the information that we may obtain will only be collected if you voluntarily provide it to us, such as information provided during registration for a product or service, in response to questionnaires, or during other interactions with us.

Personal Identifying Information You Submit During Registration or in Response to Questionnaires

Synergy collects Personal Identifying Information that you voluntarily provide on Synergy Websites, for example, in order to register for Synergy programs and services, register to receive marketing products and information, contact Synergy customer service, or respond to Synergy questionnaires or surveys. “Personal Identifying Information” means information that identifies you or that could reasonably be used to identify you. Examples of Personal Identifying Information include name, address, telephone number, and email address. When this information is combined with any information on health or medical status, we refer to the resulting information as “health-related information.”

If you choose to register for a program or service or to participate in our interactive services such as questionnaires and surveys, you may disclose health-related information as well as personal facts that could be used to identify you. To protect your privacy, you should not provide Synergy with any information that is not specifically requested.

Personal Identifying Information You Submit During Other Interactions with Synergy

You may contact Synergy to ask questions, discuss your concerns, or report problems regarding our products. If you communicate with or request information from Synergy personnel, they will have your email address as well as whatever health-related and/or personal facts that you choose to include in your communication.

If you are reporting a product experience, we may ask you for specific facts, including patient initials, age, gender, and prescribing physician. US regulations require us to collect this information in order to file reports with the US Food and Drug Administration regarding the safety of our products.

Information That May Be Collected by Synergy Site Technology

Other types of personal information will be automatically collected by us through our Website technology including tracking technologies and cookies as further discussed below.

IP Address

We may record the Internet Protocol (“IP”) address of your computer when you visit our site. An IP address identifies your computer, which allows us to maintain communication with your computer as you move about Synergy Websites.

Cookies and Other Tracking Technologies

We also collect nonidentifying information about your use of Synergy Websites through technology such as cookies and Web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” is a transparent graphic image placed on a Website that enables the monitoring of things such as user activity and site traffic. These technologies help remember your preferences on a site and allow us to bring you the content and features that are likely to be of greatest interest to you, on the basis of your previous activities on our Websites. They also allow us to collect “clickstream” data, which is not Personal Identifying Information, but which reflects activities on Synergy Websites, including your interest in certain healthcare conditions or Synergy services or products. To learn more about cookies and other tracking technologies, please visit http://www.allaboutcookies.org/.

HOW WE USE YOUR INFORMATION

We may combine information about you from a visit to one Synergy Website with information about you from visits to other Synergy Websites. We may also combine information about you that is collected online with information that we have collected offline, as well as with information provided to us by third parties. We may use this information for the following purposes.

Marketing, Programs, and Services

You do not have to register for a service or a program to use most of the information available on Synergy Websites. If you choose to register, we may use the Personal Identifying Information that you provide through Synergy Websites to respond to your questions and to provide you with efficient customer service. We may also use your Personal Identifying Information for other business purposes, such as to offer you the opportunity to receive notices regarding Synergy’s products or services, to invite you to participate in surveys about our products, or to notify you about special promotions.

Customized User Experiences

The Personal Identifying Information that you provide may be used to create customized offers, information, or services tailored to your interests and preferences. Also, we may use your IP address and the nonidentifying data that we obtain through the use of cookies to make our sites easier to use and navigate as well as to personalize the content provided on Synergy Websites by anticipating the information and services that may be of interest to you.

Product Improvement

If you choose to participate in our interactive services such as questionnaires or surveys or to register for a Synergy program or service, we will collect the information that you disclose and analyze the data to discover new facts that could help us better understand our products. We may use this information for our internal business purposes, such as research to improve our products and analyses that may help us better market our products.

Service and Website Improvement

We may use the information about your use of the services and activities on Synergy Websites to monitor user traffic patterns and to try to analyze what our users prefer, so that we can design better services. We may analyze the information that is collected with cookie and other tracking technology to help us improve the function of Synergy Websites and to modify the services and information that we provide.

HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES

We may use third parties to provide services and information on our sites and to assist with online marketing and advertising, and we may provide some cobranded services in partnership with others. We also may use third parties to analyze data collected on Synergy Websites. If we allow a third party to have access to your Personal Identifying Information, we will not authorize them to use it for any purpose that is not consistent with this Privacy Policy. Additionally, Synergy may share your Personal Identifying Information with a third party in connection with the sale or transfer of one of its product lines or divisions, so that the buyer can continue to provide you with information and services. Except as otherwise explained in this Privacy Policy, we will not sell or disclose any Personal Identifying Information that you provide on Synergy Websites to an unrelated third party without your express permission.

Third-Party Website Advertising and Online Behavioral Advertising; Ad Choices Opt-Out

You may be provided with online advertisements on third-party Websites that are tailored to you, for example, on the basis of information that is provided by you but that does not identify you (nonidentifying information),or of your Web browsing activity, purchases, or interests. These types of tailored online advertisements may come through several sources, such as the following:

  • We may share with our advertising companies your nonidentifying information, including nonidentifying personal information and other data that we have obtained from cookies and other tracking technologies.
  • We may use online behavioral advertising practices (this is also sometimes called retarget advertising or interest-based advertising). Our advertising network partners may place and use cookies on Synergy Websites and on other third-party Websites to collect information about your activities in order to provide you with online advertisements that are based on your interests.

When a Synergy online behavioral advertisement is delivered to you, you will see an “Ad Choices” icon. Clicking on the icon will take you to a Website where you can manage or opt out of the use of data about your browsing history that is used for the delivery of online behavioral advertisements. If you opt out, you may still see advertisements online, including advertisements from Synergy that are based on other information (e.g., based on the content of the page being viewed). In some cases, data may still be collected about your browsing activity by these third-party advertisers, but they will not use this data to deliver advertisements that are based on your past online browsing behavior. 

Vendors and Suppliers

We have relationships with various vendors and suppliers who help us operate our business. We will not authorize our vendors and suppliers to use your information for any purpose that is not related to Synergy’s business operation.

Co-branded Sites

We 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 Synergy logo and the logo of the co-branding partner displayed on your screen. To access the services available on a co-branded site, you may have to complete a new online registration form, and this registration information may be shared with Synergy’s co-branding partners. You should read the individual privacy policies of our co-branding partners, as they 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.

Social Media Plug-ins

Synergy websites may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our Website, the operator of the social plug-in can place a cookie on your computer that enables that operator to recognize individuals who have previously visited our site. If you are logged into the social media Website (e.g., Facebook, Twitter) while browsing on our Website, the social media plug-in allows that social media Website to receive information that you have visited our Website. The social media plug-in also allows the social media Website to share information about your activities on our Website with other users of their social media Website.

Product Reports

If you contact Synergy regarding your experience in using one of our products, we may use the information that you provide in submitting reports to the US Food and Drug Administration 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 the use of our product.

Law Enforcement

In certain limited circumstances, Synergy may be called upon to release your Personal Identifying Information in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests while taking appropriate measures to ensure that the requester understands the sensitive nature of the 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 who engage in behavior that is illegal or harmful to others or to others’ property.

We may also disclose your information in the following circumstances:

  • As required by law, including laws, writs and ordinances outside your country of residence, to comply with a subpoena, required registration or legal process.
  • To respond to requests from public and government authorities, including authorities outside your country of residence.
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request.
  • To allow us to pursue available remedies and limit the damage we may sustain.
  • In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings.

PRIVACY OF CHILDREN

Synergy does not knowingly collect or use any personal information from children (we define “children” as minors younger than 18) on Synergy Websites. We do not knowingly allow children to order our products, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

YOUR PRIVACY CHOICES

The section below will provide you with background information and options on how you can control the use of Personal Identifying Information on our Websites.

Requesting a Change to How We May Use (or Not Use) Your Personal Identifying Information

If you have questions about the use, amendment, or deletion of Personal Identifying Information that you have provided to us, or if you would like to opt out of future communications from a Synergy business or from a particular Synergy program, please contact us by clicking on the “Contact Us” link on the Website that you are visiting.

In all communications to Synergy, please include the email address used for registration (if applicable), the Website address or the specific Synergy program to which you provided personal information (e.g., Synergy.com), and a detailed explanation of your request. If you would like to delete, amend, or correct your personal information and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email. We will respond to all reasonable requests in a timely manner.

Voluntary Disclosures

When you access any interactive tool, program, or service on an Synergy Website, you will be asked to affirmatively choose to provide the requested information. You may always choose to not provide the requested information.

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 our site may not work properly. Cookies and similar technologies are how we ensure that we can promptly retrieve and deliver information to you when you use our site.

Do-Not-Track Signals and Similar Mechanisms

Some Web browsers may transmit “do-not-track” signals to Websites with which the browser communicates. As of the Effective Date of this Privacy Policy, an industry standard has not yet been established on how to respond to these signals. Therefore, Synergy does not currently respond to these signals.

Communications with Synergy by Email

Consumers and providers may communicate with our staff to learn more about our products and services on Synergy Websites. We also offer interactive tools that provide consumers and healthcare professionals with the ability to submit customized email requests for information about diseases and therapies. Please be aware that email transmissions may be vulnerable to unauthorized interception. In addition, we remind you that email sent or received through an employer’s computer or computer system is not confidential and may be the legal property of the employer.

DATA SECURITY

Synergy’s practice is to secure each Web page that collects your information. Although we will make reasonable efforts to protect Personal Identifiable Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Synergy cannot guarantee that unauthorized third parties will not gain access to your personal information; therefore, when submitting personal information to Synergy Websites, you must weigh both the benefits and the risks.

CONSENT TO PROCESSING IN THE UNITED STATES AND ELSEWHERE

This site is owned and operated by Synergy in the United States, but the information you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting this site from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries; however, we will take the security measures described in this Privacy Policy in an effort to keep your information secure. By using this site, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

RETENTION PERIOD

We will retain your PII for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

SENSITIVE INFORMATION

We ask that you do not send us or disclose any sensitive Personally Identifiable Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through Synergy Websites or otherwise to us, unless necessary to receive the services provided.

CHANGES TO OUR PRIVACY POLICY

We will only use personal information in the manner described in the Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time. Any such changes to this Privacy Policy will be promptly reflected on this page. Synergy encourages you to review this Privacy Policy regularly for any changes. Your continued use of Synergy Websites will be subject to the then-current Privacy Policy.