Healthcare Professionals (“HCPs”) Privacy Notice

Jazz Pharmaceuticals collects your personal information from a variety of sources. In most cases Jazz Pharmaceuticals will obtain information directly from you when you:

• interact with Jazz Pharmaceuticals’ employees or representatives;
• participate in, or request to be considered for Jazz Pharmaceuticals-related activities, such as clinical trials, advisory boards or consultancies;
• register for a Jazz Pharmaceuticals-sponsored event (including online events); and
• contact Jazz Pharmaceuticals for medical information, safety or quality issues.

u Jazz Pharmaceuticals may also collect your personal information from alternative sources including, but not limited to publicly accessible sources (such as websites, social media and other digital platforms, publication databases, journals, societies, editorial board websites, national registries, professional directories and third party healthcare professionals databases), or third party vendors and service providers acting on Jazz Pharmaceuticals’ behalf.

Jazz Pharmaceuticals only keeps information about you that is necessary for managing its relationship with you. Depending on the relationship, Jazz Pharmaceuticals may obtain information about you including:

• General information: name, postal and/or email address, phone number, date of birth, payment-related information, government issued identification where legally required or authorised (e.g. passport, tax identification number), agreements, communications preferences, special conditions (dietary preferences/requirements, accessibility information);
• Professional information: such as a job title, educational information, professional qualifications, prescribing history, work experience, professional licenses, networks and affiliates, programs and activities participated in, publications authored or co-authored, awards, board memberships, professional conference and events, employment status, influence rankings.
• Assessment information: such as details of interactions with Jazz Pharmaceuticals, including without limitation what kind of meetings Jazz Pharmaceuticals has held, topics discussed, your knowledge of and questions you have had on Jazz Pharmaceuticals business and products, what kind of material Jazz Pharmaceuticals has displayed to you and any feedback that you have provided, as well as your opinions and routines on prescribing, routines regarding your patients and diagnosis, and similar information.
• Transparency information: information related to payments and services provided, invoices and tax related information.

Jazz Pharmaceuticals may use your personal information for different purposes depending on the type of interaction Jazz Pharmaceuticals has with you:

• Conducting its business operations: for example, managing its relationship with you (e.g. through the operation of a database keeping records of interactions with health care professionals or managing call planning as well as call reporting); inviting you to its events or to participate in its activities; answering your requests and providing you with efficient support; providing you with appropriate, adequate and updated information about disease as well as Jazz Pharmaceuticals’ products and services; tracking its activities (e.g. measuring interactions or sales, number of appointments/calls);
• Comply with legal, regulatory, industry best practices and ethical obligations: for example; reporting of interactions with HCPs for transparency purposes; complying with applicable laws, regulations and requests from governmental agencies (e.g. complying with pharmacovigilance data capture and reporting obligations); and complying with industry standards and its policies;
• Conduct security and fraud detection and prevention: for example to ensure security and confidentiality of your information, ensuring a safe environment at Jazz Pharmaceuticals’ events, facilities or networks.
• Any other purpose that is relevant in the relationship between Jazz Pharmaceuticals and HCPs.

Jazz Pharmaceuticals will use information for further purposes, where lawful to do so (such as for archiving, scientific or market research purposes) or when legally obliged to do so.

Jazz Pharmaceuticals may use your personal information based on one or more of the following bases

• Your Consent: In some cases, Jazz Pharmaceuticals may ask for your consent to collect and use your Personal Information. Where Jazz Pharmaceuticals uses your personal information based on consent, it will provide more detailed information to you at the time when it obtains your consent.
• Compliance with applicable laws: In specific circumstances, Jazz Pharmaceuticals may use your personal information where it is required or authorized by law or a court/tribunal order.
• Jazz Pharmaceuticals’ reasonable need: Jazz Pharmaceuticals may use your personal information in its customer databases where such information is reasonably necessary for Jazz Pharmaceuticals’ functions and activities such as communicating with you and managing its interactions with you regarding Jazz Pharmaceuticals products and services (including planning potential collaboration, contact, visits and meetings), scientific research, and education opportunities.

Jazz Pharmaceuticals may disclose your personal information:

• to its affiliates, service providers (e.g., payment service providers, database hosting providers) and advisors;
• to fraud prevention agencies and law enforcement agencies;
• to courts, governmental and non-governmental regulators and ombudsmen;
• to any third party that acquires, or is interested in acquiring, all or part of Jazz Pharmaceuticals’ assets or shares, or that succeeds Jazz Pharmaceuticals in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise; or
• as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Jazz Pharmaceuticals believes in good faith that disclosure is legally required or Jazz Pharmaceuticals has a legitimate interest in making a disclosure, such as where necessary to protect Jazz Pharmaceuticals’ rights and property.

Jazz Pharmaceuticals may disclose your personal information to recipients (as described above) located outside of your country in a country which may not have data privacy laws equivalent to those in your country. In such a case, Jazz Pharmaceuticals will take all reasonable steps to ensure the safety of your personal information in accordance with the applicable privacy laws.

Certain international recipients of your personal data may have signed special contracts with Jazz Pharmaceuticals to provide legal protection for your transferred personal data (e.g. “Standard Contractual Clauses”).

You can request further information using the contact details below.

Your personal information will be maintained for no longer than is necessary to fulfil the purposes outlined in this Privacy Notice. Jazz Pharmaceuticals will store and retain your personal information in accordance with its Records Management Policy. Please note that information may be retained for a longer duration where applicable laws or regulations require, or allow Jazz Pharmaceuticals to do so.

You have certain rights under applicable data protection laws, which may be subject to limitations and/or restrictions. These include the right to:

• request access to and rectification of, your personal information;
• object to the use of your personal information for direct marketing purposes; and
• the right to withdraw consent to the use of your personal information where applicable.

You also have the right to lodge a complaint about the handling of your personal information with the Office of the Australian Information Commissioner (“OAIC”) or applicable recognised external dispute resolution scheme (“EDR”).

All your requests, inquiries or complaints regarding this Privacy Notice or relating to the handling of your personal information including all requests as detailed in the Section, ‘Your Rights’ above, should be sent in writing to Jazz Pharmaceuticals’ Privacy Office at the following address: Jazz Pharmaceuticals, 3170 Porter Drive, Palo Alto, CA 94303, United States or by email at: privacy@jazzpharma.com .