WHO WE ARE
Clinigen respects your privacy and is committed to protecting your personal information in the event we receive it.
HOW THIS WEBSITE WORKS
Clinigen does not collect any personal information through visiting this website. This website is designed not to access, collect, or process any personal information, including technical information, such as cookies or your IP address.
You may choose to interact with this website in 2 ways:
- Search the location of a Treatment Center. There is a Treatment Center finder on both the patient and the healthcare professional portions of the website. The full list of Treatment Centers is part of the website. When you enter a city, state, or zip code, the list is narrowed to provide you with Treatment Centers in the area. We do not collect the information you enter when you search
- Request a mentor. On the patient portion of the website, you have the option to contact us if you would like to speak to a mentor to discuss their experience with Proleukin. If you choose to contact us, the information you provide will be processed according to the policy below
THE INFORMATION WE MAY COLLECT ABOUT YOU
Personal information means any information about an individual from which that person can be identified. It includes personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household. It does not include data where the identifiers have been removed (deidentified or anonymized data).
We may collect, use, store, and transfer different kinds of personal information about you, which we have grouped together as follows:
- Identity information including first name, last name, maiden name, username or similar identifier, Social Security number, driver’s license number, passport number, marital status, title, date of birth, gender, and employment information; and
- Contact information including billing address, delivery address, email address, and telephone numbers
We do not collect any other information about you in connection with this website. Unless we have told you elsewhere in this policy, or otherwise in writing, we do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through this website. Nor do we collect any information about criminal convictions and offenses through this website.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
We may collect information from and about you through:
- Direct interactions. You may give us your identity and contact information by corresponding with us by phone or email; and
- Third parties or publicly available sources. We may receive identity and contact information from publicly available sources in order to verify your identity, if necessary
HOW WE USE YOUR PERSONAL INFORMATION
We will only use (process) your personal information when the law allows us to. We have described below how we plan to use your personal information, and which of the legal bases we rely on to do so.
Type of Information
Lawful Basis for Processing
To connect you with a mentor
To manage our relationship with you, which will include:
Necessary to comply with a legal obligation
To administer our business and this website
Necessary for our legitimate interests (for running our business, including provision of administration and IT services and network security)
Where we talk about legitimate interest, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below for the purposes set out in the table above:
- Other companies in the Clinigen Group that may carry out centralized administrative and reporting activities as processors and joint controllers; and
- External third parties, such as service providers acting as processors, who provide outsourced services such as IT and system administration services
Otherwise, we do not share your personal information that we receive through this website with any third parties. If you choose to be put in touch with a mentor, we will send you the mentor’s contact information (with their consent). It will be up to you to reach out to your mentor and communicate as you see fit. Clinigen will not have access to your communications.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes, and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We do not sell your personal information.
HOW SECURE IS MY INFORMATION?
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household:
- Identity data (as described above); and
- Contact data (as described above)
HOW SECURE IS MY INFORMATION?
We have put into place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those individuals within Clinigen who have a business need-to-know. They will only process your personal information upon our instructions, and they are subject to a duty of confidentiality.
We have put into place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL INFORMATION?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes; in which case, we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have rights under certain privacy and data protection laws, including the California Consumer Privacy Act of 2018 (“CCPA”), as applicable, in relation to your personal information:
- Request disclosure. You have the right to know the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, our purpose for collecting personal information, and the specific pieces of personal information we have collected about you
Please note that we are not required to retain any personal information about you that was collected for a single, one-time transaction, or to reidentify information that is not maintained in a manner that would be considered personal information in the ordinary course of business.
- Request deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will delete your personal information from our records
Please note that we may not delete your personal information in certain circumstances, including if it is necessary to complete the transaction for which the personal information was collected, or provide a service requested by you; comply with an existing legal obligation; or otherwise use your personal information internally, in a lawful manner that is compatible with the context in which you provided the information.
- Protection against discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things, deny services to you if you request disclosure or deletion of your personal information
- Request correction. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
HOW TO EXERCISE YOUR RIGHTS
- Call us toll-free at 833-833-3537
- Contact us:
Attention: Legal and Compliance
790 Township Line Road, Suite 120
Yardley, PA 19067
- Email us at LegalandContracts@clinigengroup.com
You will not have to pay a fee to access your personal information or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under these circumstances. Please note that you may only make a CCPA-related request twice within a 12-month period.
WHAT WE MAY NEED FROM YOU
If you choose to contact us directly, you will need to provide the following:
- Enough information to identify you (eg, your full name and address)
- Proof of your identity and address (eg, a copy of your driver’s license or passport and a recent utility or credit card bill)
- A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within 1 month. Occasionally, it may take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
WHERE TO SEEK FURTHER ADVICE
Effective date: August 4, 2021