Privacy Policy
As described in more detail below, this Policy may be supplemented or amended from time to time by additional privacy notices provided at the time when We collect your Personal Information (“Privacy Notices”), and We reserve the right to collect, use, disclose, and transfer your Personal Information as described in this Policy, any Privacy Notices, or in accordance with any consent or authorization you otherwise provide. For example, certain pages of this Website may contain Privacy Notices providing more details about the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.
Some of the information we collect through this Website may be “Personal Data” as defined below. Among other things, this Policy describes:
- What information we collect about you
- How we collect your Personal Data
- How and on what basis we use the information we collect
- How long we keep your Personal Data
- How we share the information we collect
- How we protect your information
- How you can access and control your information
- How you can contact us
If you have a disability, you may request access to this Policy in an alternative format by emailing contact@protegapharma.com.
Your acknowledgment of this Policy
By using this Website, including your choices regarding cookie settings, or using the Website, you are acknowledging and agreeing to the collection, use, disclosure, and transfer of your information as described in this Policy (and any additional Privacy Notices that apply to you). If you do not agree to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Website. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.
Complete agreement for use of the Website
This Policy is part of the Terms of Use that govern your use of this Website. A link to our Terms of Use is provided at the bottom of each page of this Website.
Except as written in any other disclaimers, policies, or other notices on this Website, this Policy and the Terms of Use are the complete agreement between you and Protega with respect to your use of this Website. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials or sections of this Site.
Information We Collect
This Website is intended for informational purposes only.
Although Protega does not use Cookies and/or website analytics software to track and trace users of the Website, our service providers may collect certain information automatically as you navigate around the Website. Third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.
You have choices about the collection of information by third parties on our Sites. You may use the cookie pop-up banner on the Site to decline non-essential cookies. Additionally, you may download an Opt-out Browser Add-on to opt-out of Google Analytics by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.
You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need to take the steps outlined above from each device and browser. If you do not disable Cookies and continue to use our Website, we will infer your consent to their use.
How we collect Personal Information will depend upon the nature of your dealings with us. We collect and use non-Personal Data differently from Personal Data. Whenever it is reasonable and practical to do so, we will collect your Personal Data directly from you. We may also collect Personal Data from third parties, including in the course of providing products to you such as from our distributors, your healthcare practitioners, your caregiver/family member, guardian, publicly available information and databases supplied by third parties.
Generally, Personal Data we collect may include but is not limited to:
- Name and contact details;
- Details of your company, industry, role and accreditations;
- Information from your visits to our websites, including the IP address, type of browser, device (including unique device identifiers) and operating system you use, network information, access times, pages viewed, links clicked on;
- Details of products you have inquired about or that we have supplied to you, including any additional information necessary to deliver those products and to respond to your inquiries;
- Information that you provide to us directly through one of our websites, apps or that you email to us; and
- Information you provide in customer surveys, interviews or case studies.
Product User Data
If you are someone who uses our products including clinical trial participants: we may collect additional specific information about your use of our products and you, such as your gender, date of birth, your medical history and conditions, treatment, device information, family and social history, medical inquiries you or your physician make, and adverse events you report. We may receive some of this information from third parties, such as our distributors or your health care professional. Some of this information may be, but is not always, anonymized, or de-identified. If you are a clinical trial participant, your information will be used in accordance with the informed consent and applicable law.
Suppliers, Customers or Other External Stakeholder Data
If you are a supplier, customer, distributor, or a healthcare professional: we may collect additional specific information including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and your dealings with us.
Employees, Contractors and Applicants
If you are an employee, contractor, or applicant: we may collect additional specific information including your gender, date of birth, contact details, information collected in our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or history. We may receive some of this information from third parties such as recruiters or from reference checks.
Personal Data You Manually Provide through this Site
Protega collects the information you manually provide (e.g., using your keyboard, mouse, or touchscreen) when you use this Site. For example, we collect the information you provide if you choose to complete a pre-screening questionnaire entitled, “Am I a Candidate?” or similar questionnaire, contact us with questions, or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Data including but not limited to:
- Contact data: such as name, title, address, phone number, mailing address, and email.
- Communication data submitted by you: such as questions and feedback.
Information Automatically Collected through this Website
Protega collects information through this Site that is sent to us automatically by your web browser or mobile device. This information may include but is not limited to:
- Product use and application data (including date and time of your visit)
- IP address
- The browser you are using (including name and version)
- Your location and other geographic data
- The website you came from and the website you visit after leaving
- Pages viewed on the Website
- Links clicked on the Website
- Time spent on a particular page of the Website or the Website as a whole
- Website data used to facilitate the use of the Website such as login and technical data
The information we receive may depend on your browser or device settings as well as your cookie settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information that either does, or may, identify you.
What is Personal Information?
Personal Information is any information that relates to an identified or identifiable individual. Generally, Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
How We Use and Disclose Information We Collect
We use and disclose information you provide to us as described to you at the point of collection. Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection. We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, to comply with our pharmacovigilance obligations), or for our legitimate business interests. We may also rely on other legal bases, specifically for:
- Legitimate interest. We can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. We will use your personal data in order to help us provide you with our services and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
- Consent. In some cases, we will only process your information where you have given your consent. For example, if you sign up for email communications, provide your phone number for phone communication, or where you may be providing special categories of personal data (or “sensitive data”). Please note that we may have a different legal basis for processing (e.g., legitimate interest) so that consent is not needed. When our use and sharing is not readily apparent when you provide your information, we will provide additional information at the time we collect the information regarding our purposes and use of the information.
- To fulfill our obligations to you under a contract. If you purchase a product from us, we may process your personal data in order to fulfill our contract with you.
- As required by law. Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud.
We also disclose information collected through the Website:
- to our affiliates for the purposes described in this Privacy Policy. Protega is the party responsible for the management of the jointly used Personal Information;
- to our third-party partners that support and provide services to Us, such as pharmacovigilance operations;
- to our third-party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, IT services, customer service, email and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
- as permitted by applicable law, to a third-party in the event of any re-organization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
In addition, We may use and disclose your information as We believe to be necessary or appropriate: (a) to comply with legal process or applicable law, which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. We may also use and disclose your information in other ways, after obtaining your consent to do so.
We may use and disclose information We collect automatically as described above, under “Automatic Information Collection and Use.”
In addition, where allowed by applicable law, We may use and disclose information that is not in personally identifiable form for any purpose. If We combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), We will treat the combined information as personal information as long as it is combined.
Retention of Your Information
We will always keep Personal Data for the period required to comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements, ethical and safety requirements. We may also maintain your information as required to comply with any contract to which we are a party. Otherwise, we keep your Personal Data for as long as Protega has legitimate business purposes such as to provide you with access to product and longer to assist us in best addressing any safety matters that may arise with respect to our products, or, where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request.
How We Share Your Information
Our headquarters are in the United States. We may have offices, use service providers, and have distributors in other jurisdictions and may disclose your information to other companies in our corporate group, or to databases or servers overseas which may be provided to us by our third-party service providers. As a result, your Personal Data may sometimes be shared with others and transferred and processed outside of your home country. We may share your Personal Data with:
- Companies within our group.
- Third parties who we have a business relationship with, including distributors, agents, suppliers, healthcare professionals and advisors. This would also include companies that provide technology services to us, our professional advisors, and auditors.
- Governments, regulators, courts, and law enforcement authorities.
- Other third parties in connection with any reorganization or sale of all or any part of our business.
We will not sell, share, or otherwise distribute Personal Data about you to any person, except as provided in this Policy and in accordance with applicable law and regulation. The circumstances in which we may disclose that information include where:
- We may share your information with selected third-party service providers in connection with our business operations, for example, email or cloud service providers.
- We expressly tell you at the time you supply the information, or it is expressly permitted under any agreement with you.
- The information is aggregated and/or no longer personally identifiable.
- It is necessary to provide you with the products which you have requested.
- It is requested by third parties for use in the ordinary operation of our business. We will only disclose your Personal Data to reputable third parties and only on a confidential basis.
- Disclosure is in response to demands or requests made by regulators, governments, courts, and law enforcement authorities.
- Permitted or required by law, regulation, or applicable guidance.
Our Commitment to Privacy
Your privacy is very important to us. We strive to adhere to the following principles:
- Before or at the time of collecting personal information, We will identify the purposes for which information is being collected.
- To collect and use personal information to fulfill those purposes specified by us and for other compatible purposes, unless We obtain the consent of the individual concerned or as authorized or required by law.
- To only retain personal information as long as necessary for the fulfillment of those purposes.
- To only collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
- Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
- We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
- We will make readily available information about our policies and practices relating to the management of personal information.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
Security
We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.
Transfer and Storage of Your Personal Information
Protega is headquartered and conducts its business operations in the United States. We primarily process Personal Information in the United States. Accordingly, We may store, collect, transfer and process your Personal Information in a country other than your country of residence. The data protection requirements and other laws of countries to which your Personal Information may be transferred may be different from your country of residence. By using this Website or otherwise providing your Personal Information, you agree to the collection, transfer, storage, or processing of your Personal Information as described in this Policy or applicable Privacy Notice.
Children’s Privacy
This Website is not targeted to children and We will not intentionally collect Personal Information about children in general, particularly under the age of 16 years. If you believe We have collected Personal Information from a child under the age of 16 years, please contact Us.
Your Rights
You may make a request to access, correct, or delete your Personal Information or otherwise object to Our processing of such Personal Information by contacting Us directly. We will respond to reasonable requests in accordance with applicable laws, and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.
There may be times where We cannot grant you access to the Personal Information We hold. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. In these cases, We will provide written explanation for Our refusal to grant access.
California residents, please see the State Specific Notices, below, to further understand your rights.
Changes to this Policy
Protega reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information We collect after We have posted the revised Policy or Privacy Notice on this Site.
Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of the public areas of this Site.
Links to Other Websites
This Site may also contain links to websites that are not operated by or on behalf of Protega or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. Protega does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information
This Privacy Policy does not address, and We are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Website or to which this Website contains a link. The availability of, or inclusion of a link to, any such site or property on the Website does not imply endorsement of it by Us or by Our affiliates.
Contact Us
If you have any questions regarding this Privacy Policy or about our privacy practices, or need to contact us for purposes related to this Policy, please contact us at contact@protegapharma.com
Complete Agreement
This Policy is part of the Terms of Use that govern your use of this Website. A link to Our Terms of Use is provided at the bottom of each page of this Website.
Except as written in any other disclaimers, policies, or other notices on this Website, this Policy and the Terms of Use are the complete agreement between you and Protega with respect to your use of this Site. Any terms We use in this Policy without defining them may have their definitions provided in the Terms of Use. There may be additional terms that apply to Site sections or particular materials on this Site.
State Specific Notices
“Do Not Track” Policy — California Online Privacy Protection Act (CalOPPA)
Our website does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
California’s Shine the Light Law
Our website does not collect your personal information and share it with third parties for direct marketing purposes. If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Privacy Policy.
California Privacy Rights for Minor Users
California Business and Professions Code section 22581 allow California residents under the age of 18 years who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact Us using the contact information provided in this Policy and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.