1. Information We Collect. We have access to the categories of information regarding you and your visit to the Site that are listed in the sections below. 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. Information which permits us to identify you directly or indirectly is considered personal data in the European Union (EU) according to the provisions of the Data Protection Directive (Directive 95/46/EC), as implemented into the national law of each EU Member State. To the extent we collect and process any personal data, we will do so in accordance with the requirements of the Data Protection Directive. Alkermes plc, registered in Dublin, Ireland, will control and be responsible for the collection and processing of your personal data. This Policy refers to personal data also as personally identifying information.
Information That You Voluntarily Provide:
Site Registration. Alkermes has constructed this Site so that healthcare professionals may visit us and review information about the products we offer without revealing their identity or volunteering any personally identifying information. We do not make any attempts to find out the identities of those visiting this Site without choosing to register to use specific features. We will not associate any data gathered from this Site with any personally identifying information from any source. If you, as a healthcare professional, choose to register to receive information from Alkermes, we will collect “personally identifying information” or “personal data” from you, such as your name, address, telephone number, and email address. Your personal data will be used exclusively for the purposes of contacting you. Your personal data will not be used for any purposes other than that outlined above. Neither will it be shared with any third parties except those who work directly with us and who are responsible for maintaining and/or processing the data as discussed below. By registering to use Alkermes’ features and services you explicitly consent to the collection and processing of your personal data for the above purpose. You also consent to the access and processing of your personal data by the third parties as discussed above. By registering you acknowledge and agree that your personal data may be transferred outside the EU to other countries in which different data protection rules apply. You have the right to consult your personal data collected and processed by Alkermes. You may request its modification, correction, updating or removal according to the provisions of the applicable laws on data protection in your country. Please also see the “Your Privacy Choices” Section below. By registering you also agree that cookies may be placed on your computer in order to collect information regarding your use of the Site and your preferences.
Information That Is Routinely Collected By Our Site Technology:
IP Address. We record and retain 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. We will not attempt to identify you based on your IP address and we will not associate your IP address with information gathered from any other sources which might permit us to identify you either directly or indirectly.
Cookies for non-registered users. The Site may place “cookies” on your personal computer or any other device you may use to access the Site. A cookie is a small file of letters and numbers downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device. The cookies placed on your device are strictly necessary for the functioning of the website. Cookies will not be used to identify you, gather personal data, data on your use of the Site or for any other use that is not related to the functioning of the Site.
Cookies for registered users. Please see section “Site Registration” above.
2. How We May Use Your Information. We may use the information about your use of the services and information on the Site to monitor user traffic patterns and try to analyze what our users prefer so that we can design better services and activities for you.
Personally Identifying Information. You do not have to register to use most of the information and services available to healthcare professionals on the Site. If you choose to register, we will use the personally identifying information or personal data you give us to send you an email confirming your registration with the Site. We may also, from time to time, send you emails with special promotions or newsletters with information that we think may be of interest to you.
Vendors and Suppliers. We may from time to time have relationships with different vendors and suppliers who help us design and maintain our systems and our computer security and respond to email and inquiries from users of the Site. We will not authorize our vendors and suppliers to access or use the information that has been collected concerning registered users of the Site for any purpose not related to our business. Some vendors or suppliers may be established outside the EU where different data protection rules may apply.
Law Enforcement. In certain limited circumstances, we may be called upon by the competent authorities in the EU and the U.S. to release your personally identifying information or personal data 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 personally identifying information or personal data 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 behavior that is illegal or harmful to other users of the Site.
Product Reports. If you, as a healthcare professional, contact us regarding your experience in prescribing or administering one of our products to patients, we may use the information you provide in submitting reports to the U.S. Food and Drug Administration, the competent authorities in the EU, and as otherwise required of us by law.
Other Important Information About Our Relationship With Third Parties:
4. Your Privacy Choices. You, as a healthcare professional, may elect to receive email updates about developments regarding Alkermes. When you subscribe for email alerts through the Site, you will receive an email to confirm your request. If you decide, at any later time, that you no longer wish to receive these emails you may unsubscribe to our email list by following the “unsubscribe” link at the bottom of your email alert.
*Deletion Policy. The information that you provide to us is stored in servers that are operated and maintained by Alkermes and third parties under contract with Alkermes. Site users should be aware that it is not technologically possible to remove from our servers each and every record of the information you have provided to Alkermes. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you and personal data may exist in a non-erasable form that will be difficult or impossible for us to locate. Nevertheless, we promise that upon receiving your request, to the extent allowed by law, Alkermes will delete all personally identifying information and personal data stored in the databases Alkermes actively uses for research and daily business activities, or stored in other readily searchable media. In addition, we will use commercially reasonable efforts not to disclose any personally identifying information and personal data stored in a non-erasable format after receiving your request for removal, except as required by law. Please be aware that we may not comply with an individual’s request to amend or remove information that was provided to Alkermes by a healthcare professional through the Site regarding an adverse drug event or reaction.
5. Our Security Measures. We want your personally identifying information and personal data to remain as secure as reasonably possible.
Data Security. We use encryption practices to help insure the integrity and privacy of some of the personally identifying information and personal data you provide to us. As an added security precaution, all personally identifying information and personal data is kept physically behind firewalls that meet or exceed industry standards to prevent intruders from gaining access. Although we will make reasonable efforts to protect personally identifying information and personal data 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 thieves will find a way to thwart our security systems.