Padagis US LLC and its affiliates (“Padagis”, “we”, “us”, or “our”) recognizes that the personal information it receives is held in a position of trust. Padagis seeks to fulfil that trust by following the principles regarding the protection of personal information set forth in this Privacy Notice (“Notice”). This Notice explains how and why Padagis collects, stores, uses, and shares personal information when you purchase our products, complete an online job application, or visit our websites and applications. This Notice is meant to help you understand your privacy rights and choices.
This Notice applies to our collection, use and sharing of your personal information (a) when you visit our website at https://www.padagis.com or our related websites and applications (collectively, the “Site”), (b) purchase or use our products, (c) visit our facilities, and (d) fill out an online job application or otherwise interact with us. It also applies to your personal information that we may obtain from third parties such as resellers, database vendors, content publishers, distributors, and suppliers. This Notice does not apply to any other information, websites or services not owned or operated by us.
WHAT TYPES OF PERSONAL INFORMATION WE COLLECT
We may collect the following categories and types of personal information, depending on what product you use and the personal information you otherwise make available to us:
- Contact information: name, email address, mailing address, phone number;
- Other identifying information: IP address, passwords and other security information for authentication and access, username, social media handle or digital or electronic signature, and your photograph if you provide it to us (for example product testimonials);
- Biographical and demographic information: if you apply for a job with us or report an adverse event, we may collect your date of birth, age, gender, nationality, marital status;
- Payment-related information: if you purchase our products, we may collect your credit card number or financial account information to complete a transaction with you;
- Commercial information: records of products purchased, obtained or considered, or other purchasing or consuming histories;
- Professional or employment-related information of job applicants: if you apply for a job with us, we may collect your current or past job history or performance evaluations, education records, and salary range;
- Internet or other electronic activity: when you visit our Site, we collect browsing and click history, including information about how you navigate our Site as described in the “Cookie Statement” section below;
- Audio and visual information: if you visit our facilities, we may record audio and visual information via security cameras;
- Health and medical information: if you apply a job or report an adverse event, we may collect information about medical, physical and mental health conditions and diagnoses; treatments for medical conditions; family medical history and medications (including the dosage, timing, and frequency); and medical insurance details related to adverse events;
- Publicly available information: information about you from public databases and social media platforms regarding your interactions with us; and
- Sensitive personal information: we may request and collect sensitive personal information such as racial or ethnic origin or genetic data if you apply for a job with us or as part of adverse event reporting. In collecting this sensitive personal information, Padagis respects individual privacy, protects against unauthorized access to or use of information, and complies fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of sensitive information within Padagis are limited to uses which are necessary to: (a) meet our legal and regulatory requirements; or (b) facilitate access to services, transactions, facilities, and information.
HOW WE COLLECT PERSONAL INFORMATION
Padagis collects personal information in a variety of ways depending on how you interact with us:
- We collect personal information directly from you. This includes personal information that you communicate to us through direct interactions with Padagis (through the Site or otherwise), through your purchase of our products or use of our Site, when you interact with us on social media, through registrations, applications, surveys, etc. For example, we collect data you provide to send us a request for information, take advantage of special offers and discounts, register for events sponsored by Padagis, submit an online job application, or interact with us on our social media pages.
- We collect personal information automatically. We collect certain information about your interactions with our Site through certain technologies, such as cookies. For more information about this type of data collection and your choices, please see the “Cookie Statement” section below.
- We collect personal information in accordance with applicable law from available public sources. This includes data that is published in public profiles, for example LinkedIn and Facebook.
- We collect personal information from third parties. We collect certain personal information from service providers and business partners. We receive this personal information from third parties that are authorized to do so as specified by their own privacy and data protection policies or in accordance with the law. For example, this data may be collected for soliciting consumer reviews of products.
WHY WE COLLECT PERSONAL INFORMATION
Padagis collects your personal information for the following purposes:
- To allow us to communicate with you: to respond to your requests or inquiries, provide support for products and the Site, provide you with important updates, administrative information, required notices, and to organize and manage professional events, including your participation in such events;
- To market our products to you: to sell our products to you, to send you news, information and promotional materials about our products, brands, and operations, and to post testimonials or product reviews from you with your consent;
- To provide you access: to our Site and to manage your accounts;
- To allow us to identify or authenticate you: to allow you to create and access accounts with us, or to identify or authenticate you by government-issued ID or healthcare professional number, when necessary;
- To process payments from you and facilitate future payments;
- To improve and develop our Site and products: to identify usage trends, understand how you and your device interacts with our Site, determine the effectiveness of our promotional campaigns, conduct surveys, offer special programs, activities, trials, events or promotions via our services, carry out market or consumer studies;
- To personalize your experience when using our Site: ensure that our Site is presented in the way that best suits you and present you products and offers tailored to you;
- To comply with legal or regulatory obligations that apply to Padagis, including to monitor the safety of our products, manage adverse events, and carry out prevention and investigatory activities. We may also use your personal information to carry out administrative formalities, to comply with government registration requirements or declarations, or to conduct audits;
- To respond to legal requests from administrative or judicial authorities, in accordance with applicable laws, comply with a subpoena, or legal process;
- For security and to protect our rights and interests: for fraud monitoring and prevention, to maintain the security of our services and operations, protect the rights, privacy, safety or property of Padagis or third parties, and to allow us to pursue available remedies or limit the damages that we may incur, as necessary.
SHARING AND DISCLOSING PERSONAL INFORMATION
We may use third parties to help us design and operate the Site, provide services to support the Site, process your information, provide our products, and provide promotional and marketing activities on our behalf. For example, we may hire a company to run certain Site applications, help us analyze our data, or send information on our behalf about products and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Notice. We may share personal information with:
- Our subsidiaries and affiliates: where allowed and consistent with legal requirements;
- Service providers: who we rely on to provide services such as data storage, website hosting, email services, advertising, marketing, and consulting. Examples of service providers include email, IT services and SMS providers, web hosting providers, analysis firms, advertisers, payment processing companies, customer service and support providers and development companies and fulfillment companies. These service providers will be given limited access to your personal information only to the extent reasonably necessary to deliver the services they are engaged to provide. They are required to process any personal information collected from you, including on our behalf, in a manner that is consistent with applicable privacy laws or this Notice. Service providers that process your personal information on our behalf also commit to implement reasonable security measures;
- A buyer or other successor: in the event of a merger, acquisition, reorganization, or other sale or transfer of some or all of Padagis’ assets;
- A governmental agency or representative: for mandatory reporting including reporting adverse events, tax reporting, or other regulatory reporting requirements;
- Regulators, courts or third parties in order to comply with any court order, law or legal process, including to respond to a legitimate government request, or to protect your safety or the safety of others;
- Data security providers, law firms, law enforcement agencies, data protection authorities: in the case of a suspected data breach, to communicate with outside parties, such as experts in data breach detection or relevant government authorities, as necessary.
STORING PERSONAL INFORMATION
We will securely store your personal information only for as long as necessary for the purposes described above, as required by law, and for the exercise or defense of any legal claims.
SAFEGUARDING PERSONAL INFORMATION
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of personal information transmitted to us. While we make efforts to protect our information systems, no website, mobile application, computer system, or transmission of information over the internet or any other public network can be guaranteed to be 100% secure. We encourage you to use caution when using the internet and providing us your personal information.
- Opt-In; Opt-Out. You have the right to opt-in to receive newsletters, announcements, or other communications and services from us. If you change your mind, you have the right to opt-out from continuing to receive these items. Please note that even if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages (e.g. in case of a product recall, etc.), from which you cannot opt-out.
- Consequences of Not Providing personal information. You are not required to provide all personal information identified in this Notice to use our Site or to otherwise interact with, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, consider you for a job opening, or provide you with marketing that we believe you would find valuable.
When you visit a Padagis website, including related sites and those belonging to our affiliates (collectively, the “Site”), we may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the Site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. However, blocking certain types of cookies may impact your experience of the Site.
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We also use third party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.
- Assisting you in navigation
- Assisting you in service or website registration, login, and your ability to provide feedback
- Analyzing your use of our websites, products, services or applications
- Assisting you with our promotional and marketing efforts (including behavioral advertising)
Below is a description of the types of cookies we use on our Site. Our Site is scanned with a cookie scanning tool to maintain accurate cookie lists. You can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button within the Site.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Strictly Necessary Cookies. These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will then not work. These cookies do not store any personally identifiable information.
- Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Ste. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Site and will not be able to monitor its performance.
- Functional Cookies. These cookies enable the Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
- Social Media Cookies. These cookies are set by a range of social media services that we have added to the Site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other websites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
Cookies on this Site
Specifically, the cookies we use on the Site are:
OUR LEGAL BASES FOR COLLECTING PERSONAL INFORMATION
Padagis will generally process your personal information on one of the following legal bases:
- Your consent: where you have expressed your approval of Padagis’ processing of your personal information. Where we rely on your consent, you have the right to withdraw it anytime in the manner indicated in this Notice and/or on the Site.
- Contractual relationship between you and Padagis: in this instance, the processing of your personal information is necessary to provide the Site, communicate with you, or to provide you the products or services you have requested; this means that if you do not wish for Padagis to process your personal information in that context, Padagis may not be able to provide the products or services you requested.
- Legal obligations: we may process your personal information, including health data and other sensitive information, to comply with our legal obligations, including reporting to a regulatory authority. For instance, to comply with health and safety regulations Padagis must monitor any adverse effects of its products, which generally involves the collection and retention of personal information.
- Legitimate interest: where the processing is necessary for our legitimate interests or the legitimate interests of a third party. This includes sending you marketing communications, for compliance, fraud prevention, and safety purposes, or for sharing your personal information as described in this Notice. We consider and balance the potential impact on 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).
NOTICE TO CERTAIN EUROPEAN RESIDENTS
If you are within the European Economic Area (EEA) or the United Kingdom (UK) this section provides additional information applicable to you. Padagis is the controller with respect to your personal information for the purposes of European data protection legislation. In addition to the rights described generally in this Notice, you have the following rights under the GDPR:
- The right to be provided with a copy of your personal information (right of access).
- The right to request that we correct your personal information if it is inaccurate, incomplete or out of date.
- The right to have your personal information deleted in certain circumstances.
- The right to require us to restrict processing of your personal information in certain circumstances (e.g. if you contest the accuracy of the data).
- In certain circumstances, you have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (right of data portability).
- You have the right to object to our processing of your personal information at any time if your personal information is being processed for direct marketing (including profiling); and in certain other situations you may object to our continued processing of your personal information (e.g. processing carried out for the purpose of our legitimate interests).
To exercise any of these rights, please send the request in writing to the following address. You can contact us by email at [email protected] or by mail at the following address:
Padagis US LLC
Attention: Chief Compliance Officer
1251 Lincoln Road
Allegan, MI 49010
We may 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 would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfers. Any personal information you provide to us may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Notice regardless of where your personal information is kept. Regarding transfers from the EEA or the UK to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA or the UK, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed above.
NOTICE TO CALIFORNIA RESIDENTS
The following section applies to California residents:
- Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed at the end of this Notice and specify you are making a Shine the Light request.
- California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal information we collect. We collect identifiers (such as name, address, email, phone number, job title, and transactional information), personal characteristics (such as age, gender), commercial information (such as a record of the products and services purchased or sample products requested), and internet or other electronic network activity information (such as usage information, IP address, cookie information, and customer feedback).
Why we collect personal information. We use identifiers and personal characteristics to provide the services requested, such as to fulfill a request, provide access to an application, or provide you with information about our services and products. We use identifiers, internet or other electronic network activity, and commercial information for general Site administration, which includes record keeping, troubleshooting, data analysis, testing, and survey purposes. We use identifiers, personal characteristics, commercial information, and Internet or other electronic network activity for trend monitoring, marketing, and advertising, as well as to ensure Site security.
How we collect personal information. We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
- We collect identifiers, personal characteristics of protected classifications, education information, occupation, professional, or employment-related information, and commercial information directly from you. We collect this information in order to provide you with our products and services and to communicate with you. Additionally, If you choose to disclose this information, we collect it as part of the job application process and in the event you report an adverse event related to Padagis-branded or affiliated pharmaceutical products.
- We collect Internet or other electronic network activity information from your usage of the Site. We collect this information to provide you more relevant content, track original Site visits, and optimize your Site. Our Cookie Statement provides additional details about this collection.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
With whom we share personal information. We do not sell your personal information but may disclose it to third parties for a business purpose. As detailed earlier in this Notice, Padagis shares personal information with third parties and service providers as necessary for certain business purposes (as defined by the CCPA). This includes sharing identifiers, commercial information, personal characteristics of protected classifications, education information, occupation, professional, or employment-related information, and internet or other electronic network activity for the purposes of payment processing, customer relationship management, consulting, email communications, job application processing, adverse event reporting, product feedback, and helpdesk services.
Your rights under CCPA. In addition to the rights described generally in this Notice, you have the following rights under the CCPA:
- Right to know: You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months. This includes the specific pieces of information we collected about you, the categories of personal information we collected, our purposes for collecting it, the categories of sources of information, and categories of third parties with whom Padagis shared information for a business purpose or sold information. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to request deletion: You have the right to request that Padagis delete any personal information about you that Padagis has collected from you. Please note that there are exceptions where Padagis does not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.
- The right to non-discrimination: Padagis will not discriminate against you (e.g. through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
How to exercise these rights. To exercise these rights, please email us at [email protected]. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and email address.
Verification. Before we can respond to your request, we will first need to verify your identity using personal information you recently provided to us. If we are not able to verify your request, we will contact you for more information. If we are unable to verify your identify after a good
faith attempt, we may deny the request and, if so, will explain the basis for the denial. Additionally, after the verification process, we will notify you if your request has been granted or declined, or if an exception applies to your request.
You can designate an agent to make a request on your behalf by providing your authorized agent signed permission to do so and verifying your identity directly with us and confirming to us that you provided the authorized agent permission to submit the request on your behalf.
Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal and recordkeeping obligations, enforce agreements, and resolve disputes.
Notices to Nevada Residents
Nevada law gives Nevada residents the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, if you are a Nevada consumer and wish to exercise this right, please do so by contacting us as detailed at the end of this Notice.
We are especially committed to protecting the privacy of children who may visit our Site or use our services. While in some instances we may collect personal information about children with the consent of their parent or guardian for the provision of our services such as clinical activities or for patient support programs, we do not otherwise knowingly solicit personal information from, or market to, children. If a parent or guardian becomes aware that their child has provided us with personal information, they may exercise their privacy rights by contacting us at [email protected].
LINKS TO THIRD PARTY WEBSITES
Our Site may have links to third party websites and content. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control those websites or content and are not responsible for the third party’s privacy practices. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to understand how they use your information.
INTERNATIONAL DATA TRANSFERS
Padagis is headquartered in the United States but we have affiliates and service providers that may be located in in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
CHANGES TO THIS NOTICE
Any change to this Notice will be effective immediately. We will notify you by updating the date at the bottom of this Notice. We encourage you to stay informed about our privacy and cookie practices by reviewing the Notice whenever you interact with us. In certain cases, we may provide you with additional notice of changes to this Notice. We will not treat your personal information collected under a previous version of the Notice in a materially different manner without first receiving your consent. Any change to this Notice will be effective immediately.
If you have any questions about this Notice or our privacy practices, please contact us directly at [email protected].
This Privacy Notice was last updated January 17, 2022.