Privacy Policy

Sobi, Inc. (collectively with any subsidiaries or affiliates “We”, “Us, or the “Company”) is strongly committed to protecting the privacy of your personal information. This privacy policy explains the Company's data collection and use practices with respect to its websites at: sobi.com/US/en, sobi.com/canada/en, ctibiopharma.com, ctiaccess.com, ctiaccesscopay.com, doptelet.com, doptelethcp.com, gamifant.com, gamifantcares.com, kineretrx.com, kineretrx.com/hcp, kineret.ca, empaveli.ca, doptelet.ca, orfadin.com, suspectphlh.com, synagis.com, synagishcp.com, tegsedi.com, tegsedihcp.com, tegsedirems.com, vonjo.com/hcp, vonjo.com/patient, insidemymf.com, morethanonemf.com, pacifica-trial.com (individually and collectively, the “Site” or “this website”). Except as specifically provided below, this Privacy Policy references other information collected by Sobi by or through any other means, such as information collected offline. By using the pages in the Sites, you agree to the information collection and use practices described in this Privacy Policy. If you do not agree to the terms set forth herein, do not use the Sites.

Collection of personal information

We may ask you on the Sites for information that personally identifies you or provides information about yourself (“personal information”) or allows us to contact you to provide a service or a product or carry out a transaction that you have requested (such as requesting information about our company). The personal information we collect may include your name, your address, your telephone number, your email address and other contact information, and other information about services requested through the Sites. You are not required to provide the personal information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our services or respond to questions you may have.

The Sites may also collect information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the Site; the pages that you access while at the Site and the Internet address of the website from which you linked directly to the Site. This information is used, among other reasons, to help improve the Site, analyze use trends, and administer the Site.

In addition to the website, Sobi collects information about healthcare professionals when they interact with us or our representatives.Sobi also collects personal data from a number of third- party data sources, in particular from publicly available sources such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers.Sobi collects and processes such publicly available data only to the extent where the purposes for such collection and processing are compatible with and correspond to the initial purposes for which the respective data are made publicly available. Sobi also makes use of third-party data providers to enhance its own knowledge of the healthcare sector. This data will include information about health care providers' role(s), qualifications, specialty, employer, experience, publications and other information related to their professions.

Use of personal information

Except as otherwise required by law, the personal information collected on the Sites will be used solely to:

Operate the Sites and to provide the service(s) and/or product(s) or carry out the transaction(s) you have requested or authorized,
To provide you with more effective customer service,
Send promotional or advertising materials to you (see opt-out provisions below),
To improve the Sites and any related Company products or services, and
To make the Sites easier to use by eliminating the need for your repeated entry of the same information. In order to offer you a more consistent experience in your interactions with the Company, information collected by the Sites may be combined with information collected in connection with other Company products and services.
From our website, you may use third party social media widgets/tools/buttons. If you use that functionality, your use is subject to the third party's privacy policy and terms. As with all links to non-Sobi websites/content/services, we recommend that you read the privacy policies and terms associated with third party properties carefully.

We may use your personal information in the following ways:

Operate our business;
Deliver our products and services;
We may use information we collect directly from you and from outside sources to validate your licensure and eligibility to view such information;
For data analysis, to better understand how our products and services impact you and those you care for;
To track and respond to concerns;
For fraud prevention and to further develop and improve our products and services;
To comply with our regulatory monitoring and reporting obligations including those related to adverse events, product complaints and patient safety;
To process, complete and fulfill your requested transactions;
To provide customer service and respond to requests or inquiries;
To communicate with you;
To tailor our marketing programs and campaigns;
To provide you with newsletters, articles, alerts, announcements, invitations; and other information about products, brands, health topics and disease states.

On what basis do we use your personal data

For EEA Residents: To respond to your requests or inquiries, it is our legitimate interest to retain your information.

We will keep you informed about our trials or other activities that we believe may be of interest to you. Processing is based on your consent, and we will rely on your consent. You have the right to withdraw it anytime in the manner indicated when we requested the consent or by emailing privacy-northamerica@sobi.com.

To operate our websites and to create anonymous, aggregated or de-identified data: These processing activities constitute our legitimate interests.

To comply with regulatory monitoring and reporting obligations and to comply with law: Processing is necessary to comply with our legal obligations.

How we share information

The Company may occasionally hire other companies to provide limited services on our behalf, such as website hosting, website design or technical support, mailing/shipping, answering customer questions about products and services, and sending information about our products, special offers, and other services. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using that information for any other purpose. For example, the Company may share data:

To enable third parties to provide services to us. Categories of recipients of data would include health care providers, specialty pharmacies, financial investment service providers, insurance providers, pension administrators and other benefits providers, payroll support services, relocation, tax and travel management services, health and safety experts, and child care providers;
To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counter-parties to contracts, judicial and governmental bodies;
In response to lawful requests by public authorities (such as national security or law enforcement);
To seek legal advice from external lawyers and advice from other professional advisers such as accountants, management consultants, etc.;
As necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation);
Where necessary to protect Sobi, your vital interests, such as safety and security, or those of another person; or
In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers).
We may aggregate and/or de-identify data about visitors to our Site or other collection activities and use it for any purpose, including product and service development and improvement activities.

Control of personal information

Except as otherwise described in this Privacy Policy, your personal information will not be shared outside of the Company without your permission.

For persons over the age of 13, providing information about yourself through the Site is free and completely voluntary. No information should be submitted to or posted to the Site by any person under the age of 13 years. The Company does not knowingly collect information from children under 13. If you are under 13 years old, you may not attempt to provide your information through the Site. If the Company determines that contact information has been submitted by a person under age 13, such information will be removed. If you are between the ages of 13 and 17, you may use the Site only with your parent or guardian's consent; the Company reserves the right to request verification of such parent or guardian's consent. Personal information of persons between ages 13 and 17 will be collected as described in this Privacy Policy. By submitting your contact information through the Site, you represent that you are age 13 or over.

Retention

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Security of personal information

The Company is strongly committed to protecting the security of your personal information. When you submit personal information on the Site, the Company will take all reasonable efforts in order to protect your personal information. The Company uses certain security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure once it is received.

Cookies

Upon your acceptance of cookies from our websites, we may collect information about your visits to the Sites without you actively re-submitting acceptance of cookies. A cookie is a small text file that is placed on your hard disk by a web page server and that helps the Site to recall your specific information on subsequent visits. The use of cookies simplifies the process of delivering relevant content, eases Site navigation, and provides other similar benefits to users of the Sites. When you return to the Sites, the information you previously provided can be retrieved, so you can easily use the Sites' features.

You have the ability to accept or decline the use of cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Site.

Your rights

If you reside in the United Kingdom, EEA or Switzerland, you may request that we take the following actions in relation to your personal data according to the GDPR:

Access. Provide you with information about our processing of your personal data and give you access to your personal data.
Correct. Update or correct inaccuracies in your personal data.
Delete. Delete your personal data.
Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice.
Restrict. Restrict the processing of your personal data.
Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your personal data
Object. Object to our legitimate interests as the basis of our processing of your personal data.
Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification.
You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.

If you reside in California, you may see our California Privacy Notice, below here.

Marketing communications

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us at privacy-northamerica@sobi.com. You may continue to receive service-related and other non-marketing emails for which you have not opted out.

Sobi, Inc.
77^4th Avenue
Third Floor
Waltham, MA 02451
USA

Email: privacy-northamerica@sobi.com

We will request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you reside in the United Kingdom, EEA or Switzerland and would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at privacy-northamerica@sobi.com or submit a complaint to the data protection regulatory authority in your country.

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Choice/opt-out

The Sites provide you with the opportunity to choose to receive updates about the Company and any information we may want you to know about. You may be added to the Company's mailing lists and signed up for certain notifications from the Company when you submit your contact information through the Sites. If you would like to be removed from this list and/or opt out of these notifications, please unsubscribe using the instructions in the email or call or write us at the physical address, email address or telephone number listed below. Please allow five (5) business days for processing of your opt-out request.

If you need to correct or update your contact information, or you no longer desire our services, you can do so by contacting us using the contact information set forth below.

Links to other sites

The Sites may contain links to other sites that are not affiliated with the Company. Any such link is not, and is not intended to be, an endorsement of such other website or its content and you should review the terms of use and privacy policy of such other website. These websites operate independently of the Company and the Company is not responsible for the privacy practices or the content of such websites.

Changes to this privacy policy

We reserve the right to update this Privacy Policy from time to time and without notice to you. All such updates shall be effective immediately unless otherwise stated. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the personal information we collect. Your continued use of the Site constitutes your agreement to this Privacy Policy, as amended from time to time.

Coordination with Terms and Conditions

This Privacy Policy is intended solely to clarify the Company's practices with respect to personal information and shall not in any way modify or limit the legal effect of the Terms and Conditions to the use of the Site. In the event of any conflict between this Privacy Policy and the Terms and Conditions, the Terms and Conditions shall control. In particular, the Company will not be liable for any damages or injury (including, without limitation, incidental and consequential damages, personal injury/wrongful death, lost profits, or damages resulting from lost data or business interruption) that result from your use of the Site or your submission of personal information through the Site, even if there is negligence on the part of the Company or its employees. In addition, you agree to defend, indemnify, and hold the Company, its officers, directors, employees, agents, licensors, and suppliers, harmless from and against any claims, actions or demands, liabilities and settlements including without limitation, reasonable attorneys' fees, resulting from, or alleged to result from, your submission of personal information to the Site or your unlawful collection of personal information of others through use of the Site.

Governing law and venue

This Privacy Policy is governed by the internal substantive laws of the Commonwealth of Massachusetts, without respect to its conflict of laws principles. Jurisdiction of any claims arising under this Privacy Policy will lie exclusively with the state or federal courts in Massachusetts.

Limitations of privacy policy

This Privacy Policy explains data collection and use practices related to the Company's website and activities specifically covered herein; it may reference other products or services of the Company. Please be aware that this Privacy Policy and any choices you make on the Site will not necessarily apply to personal information you may have provided to the Company in the context of other, separately provided, products or services.

Contact information

The Company welcomes your comments regarding this Privacy Policy. If you believe that the Company has not adhered to this Privacy Policy, please contact us electronically or via postal mail at the following address, and we will use commercially reasonable efforts to promptly determine and remedy the problem, or if you need to contact us for any other reason, you may do so using the following information:

Sobi, Inc.
77^4th Avenue
Third Floor
Waltham, MA 02451
USA

Email: privacy-northamerica@sobi.com