Privacy Policy

Effective Date: December 2022

General

EMD Serono, Inc. (“EMD Serono”) respects the privacy of every individual who visits its websites (the “Websites”). This Privacy Policy outlines the information EMD Serono will collect, how we may use that information and with whom we may share that information.

Your Acceptance of These Terms

By using the Website, you agree to this Privacy Policy (“this Policy”). If you do not agree to this Policy, please do not use the Website. Your continued use of the Website following the posting of changes to these terms will mean you accept those changes. EMD Serono will, however, use Personal Information (defined below) only in accordance with the version of the Privacy Policy under which the information was collected.

How Do We Collect and Use Your Personal Information?

EMD Serono may collect Personal Information such as your name, mailing address, and email address (“Personal Information”) in certain instances. For example, we may collect information directly from you through your interactions with us when you sign up for a service, enter into a contract with us, submit an application to us, participate in a survey, contest, or other service that requires registration or subscription and through various other engagements we may have with you. We may use technologies that automatically collect information when you visit our Website, view our advertisements, or use our products or services. We also may collect information about you from third parties, such as our vendors, suppliers, contractors, and business partners.

Depending on the relationship with EMD Serono, we may collect Personal Information for a number of purposes, including, but not limited to: (1) for business operations (marketing and sales, research and development, patient support, donations and sponsorships, communications); (2) for business administration (finance and accounting, human resources, prevention and investigatory activities); (3) for business management (internal audit, asset management, system and business controls); and (4) as necessary to protect the health, safety, and security of EMD Serono personnel; (5) to comply with legal requirements and obligations; (6) operate the Website, (7) respond to your question or request, (8) communicate with you about our products or services via email; and (9) send information to you.

For Websites that are directed to consumers and/or patients, EMD Serono may collect Personal Information when you: (1) obtain a free information kit about an EMD Serono product; (2) connect with a financial support specialist; (3) connect with a nurse or other healthcare provider; (4) share a story regarding your healthcare; or (5) request marketing communications.

For Websites that are directed to physicians or other healthcare providers, EMD Serono may collect Personal Information when you: (1) connect with a sales representative; (2) request information about an EMD Serono product; (3) report an adverse event; or (4) register to participate in a provider support program. Please click here for the specific HCP Privacy Notice.

Do We Disclose Any Personal Information to Outside Parties?

We may share Personal Information with the following:

We may share Personal Information with other members of the EMD Serono corporate family to improve our products and services and so that we may better provide you with information about our offers, services or products that may be of interest to you. The EMD Serono corporate family includes affiliates that directly or indirectly control, are controlled by, or are under common control with EMD Serono. Any such corporate affiliate may use your Personal Information only according to the terms of this Policy.
We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law. In such circumstances, we will take appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive.

Children

The Websites are not directed at individuals under eighteen years of age, and EMD Serono does not intend to collect any Personal Information from such individuals, unless otherwise stated at the time such information is collected.

Information Collected Automatically

EMD Serono may automatically collect non-Personal Information about your use of the Websites, such as the name of your internet service provider, the EMD Serono web pages you have visited, the date, time and duration of your visit, your IP address and the Internet address of the website from which you linked directly to our Website.

EMD Serono may use this information for statistical purposes to analyze and enhance the Websites, and may aggregate this information and share such aggregated information with business partners, sponsors and other third parties for various purposes including product and service development and improvement activities. For example, we use browsing data to create aggregated statistics (such statistics do not show data about a single user but only about the collected data of a number of users), to learn what is of interest to users in order to improve the Website and its offerings. We also use the browsing data for maintaining or restoring the security of our Websites or to detect and correct technical defects and errors. We also collect data about the location of the devices accessing our Websites for statistical purposes (such as statistics regarding from where visitors access our Website); you can control the authorization for this using your browser settings.

Cookies

We use cookies to enable and facilitate the use of the Websites, for example to optimize the presentation or display of content. “Cookies” are small text files that enable the Websites to store information on your device, including mobile phones or laptops, and retrieve it later (e.g., when you visit our Websites again later). The use of cookies, for example, enables the Websites to “remember” the language in which we are allowed to present our content to you. We include the following three categories of cookies on our Websites:

These cookies are necessary to safeguard the functionalities of our Websites and for the Websites to operate. Cookies are set, in particular, in response to your actions and depend on your specific service requests (e.g., setting your privacy preferences, filling out forms, or logging in). Our Websites cannot function without these cookies and they can only be disabled by changing your browser preferences.
These cookies may be set to learn more about your interests and show you relevant ads on other websites. These cookies work by uniquely identifying your browser and device. By integrating these cookies, we aim to learn more about your interests and to be able to place our advertising in a targeted manner.

You can disable or block cookies in your browser software; however, this may result in restrictions regarding the usability of the Websites. In addition to cookies, we may also use other web technologies such as pixel tags, web beacons or clear GIFs (hereinafter also referred to as “cookies”) for these purposes.

Web Analytics Services

This Website may use a number of third-party web analytics services, including those provided by Google, Inc. (“Google”) and Adobe Systems Software Ireland Limited ("Adobe"). Services such as Google Analytics and Adobe Analytics use cookies to help the Websites analyze how users use the site. This means that information about you and your use of the Websites is transmitted to Google, Adobe or other services that we may use and processed on our behalf for the purpose of compiling reports on website activity, measuring website visits and visitors and providing similar services for us. This includes the transmission of your IP address, but it will not be merged with other Google, Adobe or other third-party data. If we use Google Analytics, Adobe Analytics or other web analytic services, you can opt-out from being tracked by them as follows:

For Google Analytics, you can opt-out by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en.

For Adobe Analytics, you can opt-out by using the following link ("Use of Adobe Marketing Cloud by our business customers" section): http://www.adobe.com/privacy/opt-out.html.

Internet-Based Advertising and the Advertising Option Icon

We hope to deliver to you advertising for products and services you need or want. There are many ways to do this in the online advertising world. For example, we (or our business partners) may partner with websites and applications with whom you have shared your interests, conditions and concerns directly and ask them to serve our ads to you if you have expressed an interest in EMD Serono products or health conditions that our products treat. We may also partner with advertising companies that may place or recognize a unique cookie on your browser (including through the use of pixel tags), or use other technologies, to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”). These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use. You can read more about IBA at a site offered by the advertising industry’s Digital Advertising Alliance (“DAA”), aboutads.info.

We want it to be easy for you to understand how we and our business partners use information to serve ads tailored for you and to opt-out from targeting based on IBA. To this end, our business partner has licensed the DAA Advertising Options icon, see bottom of this page, which appears in our ads served using IBA, and agreed to adhere to the DAA Self-Regulatory Program for IBA. To learn how to opt-out of having the information collected from you used for IBA purposes on the particular device on which you are accessing this Policy, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/. If you have any questions about our use of IBA or participation in the DAA Self-Regulatory Program, please do not hesitate to contact us at dataprivacy@emdgroup.com

Response to “Do Not Track” Signals

Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, EMD Serono does not process or respond to “Do Not Track” signals.

Links to Other Websites

The Website may link to various other web sites. EMD Serono assumes no responsibility for the content and information practices of sites you are able to access through the Websites. These links to other sites do not imply affiliation or endorsement of a linked site.

Security

The importance of security for all Personal Information associated with visitors to the Websites is of utmost concern to us. Unfortunately, no data transmission over the Internet can be guaranteed to be secure. As a result, EMD Serono cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your Personal Information, we will take reasonable efforts to ensure its security on our systems.

Terms and Conditions of Use

Use of the Website is governed by the EMD Serono Legal Statement which can be accessed here.

Changes to this Privacy Policy

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date in the upper left corner of this Policy so that it will be easier for you to know when there has been a change. When we make a change to this Policy regarding use or disclosure of Personal Information, we will provide notice on the Websites. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.

Questions

If you have any questions about this Privacy Policy, please contact us at privacy@emdgroup.com.

Privacy Rights for Residents of California, Colorado, Connecticut, Utah and Virginia

The following terms apply to the Personal Information of residents of California, Colorado, Connecticut, Utah and Virginia (the “States”). These provisions are intended to comply with the privacy laws enacted by the States (the “State Privacy Laws”), including the California Consumer Privacy Act, the California Privacy Rights Act and related regulations (collectively, the “CCPA”). These provisions supplement the other sections of our Policy. Any terms that are defined in the State Privacy Laws have the same meaning here. The term definitions applicable to you are those provided in the State Privacy Law of the state in which you are a resident.

The categories of Personal Information we may have collected from you, the sources of that Personal Information, and how and with whom we may have used or shared such Personal Information during the past year include the following:

Category of Personal Information Collected	Source of Information	Purpose for Collection	Categories of Recipients
Contact information: such as your name, address, email address, telephone numbers, or other contact information	From you, your authorized agent, or family member; from public data sources; from your health care provider or other caregiver; from other parties such as conference organizers or publishers which have received ‌Personal Information from you.	To communicate with you; to enroll you in programs or services; to send you catalogs, information, newsletters, promotional materials and other offerings from us or on behalf of our partners and affiliates; to offer you the chance to participate in contests or other promotional activities; when you contact us; when you request customer service or support; to complete your registration on our websites (“Sites”); to administer your account with us.	Our service providers, and our co-marketing partners, including select partners and affiliates that we believe may have or facilitate offers that may be of interest to you.
Payment information: name, card issuer and card type, credit or debit card number, expiration date, CVV code and billing address.	From you and your payment card issuer.	To check that the right person is using the right card or account, meets the requirements of the card brands or account issuers, and to make sure we are paid for what you buy.	Our service providers who process payments for us and who are contractually required to comply with laws and requirements applicable to payment processing, which may include Payment Card Industry Data Security Standards.
Legal information: fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected crimes, complaints, claims and accidents.	From you, the police, crime and fraud prevention agencies, payment card providers, the public, regulators, your and our professional advisors and representatives.	To protect you, other customers and our business against criminal activities and risks, make sure we understand and can meet our legal obligations to you and others and can defend ourselves.	Our service providers who help us with fraud protection and credit risk reduction, and law enforcement and other governmental authorities in accordance with applicable law.
Preference information: your marketing preferences, your account settings (including any default preferences), any preferences you have indicated, the types of services/offers that interest you, the areas of our Sites or Apps that you have visited or ways that you interact with our Sites or Apps.	From you, from our website technology interaction with your browser/devices and cookies and other similar technologies tracking the pages you visit, the marketing messages you open and the links you follow.	To enhance your online shopping experience, including as a way to recognize you and welcome you to the Sites or applications (“Apps”), to provide you with customized Site or App content, targeted offers from us or others, promotions and advertising on our Sites or Apps, through other third-party sites or apps, via email, text messages, or App push notifications that are offered by us or others that might be of interest to you.	Our third-party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping experiences through our Sites, our Apps or elsewhere.
Communications: communications we have with you. Please note that we may record calls to our customer service team or other sites for quality assurance.	From you	To handle your requests, to contact you when necessary or requested, including responding to your questions and comments and providing customer support, and to obtain customer feedback and improve our customer service and customer shopping experience.	Our service providers who assist us with customer service.
Voluntary information: any voluntary information you provide us with, such as responses to surveys or competitions and social media account details.	From you and your social media account provider.	To know you better, make our communications with you more personal, learn and improve from your survey feedback, organize events and pick competition winners.	Our service providers who administer surveys and promotions, and our co-marketing partners.
Personalization: your journey online and how you use our Sites and Apps, whether and when you open our marketing emails and respond to our advertisements.	From you, from our Sites or Apps technology interaction with your browser or devices and cookies tracking the pages you visit.	To improve our Sites, Apps, products and services, customer service, and customer shopping experience.	Our third-party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping or website experience for our Sites, our Apps or elsewhere.
Device information: IP address, internet provider, operating system and browser used, type of device (such as laptop or smart phone), device cookie settings and other device details (such as MAC address and geolocation), if you use our Sites or Apps and permit them to obtain your precise geolocation.	From you and from our website or app technology’s interaction with your browser or devices.	To make sure our website and app technology works properly with your device and make sure you can see and use our intended website and apps on the device you are using, for analytical and demographic purposes, and to provide offers that may be of interest to you. We also will use this information to protect the security and integrity of the Site and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users.	Our service providers who help us with fraud protection, and third-party vendors and service providers that perform website analytic services for us or enable more relevant offers to you on our Sites, our Apps or elsewhere.
Information automatically collected from your browser: when you use our Sites or Apps, some data is automatically transferred from your browser to our server, including your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, IP address, mobile device identifier or other unique identifier, sites or apps visited before coming to our Sites or Apps, the amount of time you spend viewing or using the Sites or Apps, the number of times you return, or other click-stream or site usage data, emails we send that you open, forward, or click through to our Sites or Apps.	From you and from our website or app technology’s interaction with your browser or devices.	We will use this information in an aggregated non-specific format for analytical and demographic purposes. We also will use this information to protect the security or integrity of our websites and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users.	Our third-party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping or website experience and the relevance of offers to you on our Sites, our Apps or elsewhere.

If you are a resident of one of the States, State Privacy Law provides you with the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected, used or disclosed about you.
- The right to request that we delete any Personal Information we have collected about you.
- The right to request that we delete any inaccurate Personal Information we have collected about you.
We may collect some sensitive personal information, as that term is defined under State Privacy Laws and as described in this Policy, such as your credit card payment information or precise geolocation data. Your sensitive personal information will not be used for any additional purposes that are incompatible with the purposes listed above, unless we provide you with notice of those additional purposes.
If you are a California resident and we receive your Personal Information in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have the privacy rights under State Privacy Laws with respect to your business contact Personal Information described above.

The processing activity may include the following data categories:
- Your contact information (e.g., name, title, form of address or salutation, address, gender, telephone numbers, email address); and
- Details on your profession (e.g., job title, position, personnel number, place of work, branch office, department, qualifications).
This data processing is based on our legitimate business interests. We have a legitimate economic interest in maintaining contacts beyond the initial context and in using them to establish and develop a business relationship and to remain in contact with the parties concerned.

Such business contacts could also be easily processed in our email communications with you and then kept in typical business software, either centrally or on the electronic devices of our employees.
You may submit requests to delete and/or to know Personal Information we have collected about you by accessing our State Privacy Rights request portal at:

https://privacyportal-de.onetrust.com/webform/71528392-912c-4f33-b3b5-9e665d0de552/44a2b69a-52e7-4f71-bd11-3c4b71ad611d

or by contacting our Toll-Free Telephone Number at:

+1 (888) 914-9661 (PIN 659429)

We will respond to your request in compliance with the State Privacy Laws or other applicable law.
When you exercise these rights and submit a request to us, we or our partners will verify your identity by asking you to authenticate your identity via standard authentication procedures. For example, we may ask for your email address, order numbers of previous orders of our products and services, the last four digits of a credit or debit card or bank account number used to make a purchase, or the date of your last purchase from us. We also may use a third-party verification provider to verify your identity.
You may permit an authorized agent to submit a request to know or to delete your Personal Information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Information.
We may retain your Personal Information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements. We strive to retain your Personal Information no longer than is reasonably necessary to carry out the purposes listed in this Policy or as required by law. Under certain circumstances, your data may also be kept longer, e.g., if a Legal or Litigation Hold (i.e., a ban on deleting data for the duration of the procedure) is ordered in connection with official or legal proceedings. We retain your Personal Information following the end of your services or other business relationship in accordance with applicable law and our record retention and destruction policies. Data without any personal identifiable information may be stored permanently.