Global Clinical Trial Site Personnel Privacy Notice

CANADA

Last updated: October 2026

Jazz Pharmaceuticals — Global Healthcare Professional and Clinical Trial Site Personnel Privacy Notice

This Global Healthcare Professional and Clinical Trial Site Personnel Privacy Notice (“HCP Notice”) explains how Jazz Pharmaceuticals plc and its corporate subsidiaries and affiliates (collectively “Jazz”, “we”, “us”, “our”) processes personal information (i.e. any information that could identify an individual either directly (e.g. name) or indirectly (e.g. a unique ID number)) about physicians, pharmacists, and other health care professionals with whom we interact in a business-related capacity and clinical investigators (principal investigators, sub-investigators or co-investigators) and site personnel (nurses, pharmacists or technicians, etc.) of clinical trials sponsored by Jazz (collectively, “HCPs”). It explains how we collect, disclose, use, and otherwise process personal information of HCPs and how HCPs can exercise their privacy rights.

HCPs located in certain jurisdictions, including the European Economic Area, United Kingdom, and Switzerland and residents of California have certain rights with respect to the collection, processing, and disclosure of their personal information. For more information, please see the “Additional Disclosures for HCPs in the EEA, UK, and Switzerland” section of this HCP Notice or the California Healthcare Professional and Clinical Trial Site Personnel Privacy Notice as applicable.

Please note that this HCP Notice does not apply to information we collect from non-HCP business contacts who interact with Jazz. For further details about our privacy practices pertaining to non-HCP personal information, please visit https://privacy.jazzpharma.com/.

What personal information do we collect about HCPs?   

Depending on locally applicable law, we may collect the following categories of personal information from HCPs:

  • Identifiers, such as name, postal address, email address, phone number, national provider identifier, date of birth, other contact information, photographs and other visual images of you, and computer or facilities access and authentication information (e.g., identification codes, passwords), IP address, online identifiers, and other similar identifiers.
  • Financial Information, including payment-related information, tax identification number, and other financial disclosure information as required by law.
  • Characteristics of Protected Classifications under state or federal law, such as age and gender.
  • Commercial Information, such as programs and activities in which you have participated, information about your prescribing of our products, any agreements you have executed with Jazz, and your communication preferences.
  • Internet or Other Network Information, such as browsing history, search history, information regarding your interactions with our websites or advertisements.
  • Geolocation Data, such as device location that is more granular than a city or town.
  • Audio, Electronic, Visual and Similar Information, such as call and video recordings.
  • Professional or Employment-Related Information, such as work experience, professional credentials, professional qualifications, registrations and memberships in associations and boards, scientific activities and publications of academic or scientific research and articles, patents and other scientific and medical achievements, roles or positions held with government bodies or hospital or payor organizations, organizational and institutional affiliations, and information about your scientific and medical colleagues and leaders in your specialty area.
  • Education Information, such as academic background and credentials.
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Sensitive Personal Information, including personal information that reveals:
    • Social security, driver’s license, state identification card, or passport number; or
    • Racial or ethnic origin.

You can choose not to give us the personal information listed above when we ask you for it. If you decide not to give us your personal information, we may not be able to continue in our business relationship or engagement with you, and you may not be able to work on clinical studies sponsored by Jazz (“Clinical Studies”), as applicable.


We will not process personal information (including any of the information listed above) if local law prohibits us from doing so.

 

How do we collect HCP personal information?  

We collect HCP personal information directly from HCPs. We may also collect HCP personal information from the following sources:

  • Publicly available sources such as websites including clinicaltrials.gov, www.clinicaltrialsregister.eu, the US FDA’s Debarment and Disqualified and Restricted Lists for clinical investigators;
  • The research center where you work or conduct/support research activities;
  • Service providers and third parties when they disclose personal information to us;
  • Providers of demographic data; publications; professional organizations; educational institutions; and social media platforms;
  • Cookies and other tracking technologies when you visit our websites.

How do we use HCP personal information?  

We may use your personal information for the following purposes:

  • To manage and provide our patient assistance and support programs;
  • To facilitate your registration and attendance at events we sponsor;
  • To provide you with promotional and scientific information about our products, services, and events;
  • To inform you, plan and/or conduct other Clinical Studies including to identify suitable investigators for our studies;
  • To coordinate your participation as a speaker at events we sponsor, including any compensation or honorarium;
  • To respond to your inquiries about our products, policies and programs and provide you with information when you request it;
  • To identify and evaluate potential sites for our Clinical Studies;
  • To plan and manage our Clinical Studies in accordance with applicable legislation in the context of clinical research;
  • To comply with legal, regulatory, industry best practices, and ethical obligations including without limitation applicable laws and industry codes imposing disclosure requirements for transfers of value made to healthcare professionals and healthcare organizations; pharmacovigilance data capture and reporting obligations; and adverse experience and product complaint reporting;
  • To inform you, plan and/or conduct other Clinical Studies including to identify suitable investigators for our studies;
  • To enable patient recruitment for our Clinical Studies;
  • To assess the effectiveness of the sites participating in our Clinical Studies;
  • To reimburse you for expenses or pay you under a contract we have entered into with you;Clinical Studies;
  • To analyze or predict your preferences to identify aggregated trends to develop, improve or modify our products, services and business activities;
  • To analyze or predict your preferences to identify aggregated trends to develop, improve or modify our products, services and business activities;
  • To protect someone's health, safety or welfare;
  • For market research purposes;
  • To manage and protect our network and IT systems;
  • For the establishment, exercise or defense of legal claims or proceedings, to protect our rights or property, and to comply with and enforce our policies; and
  • For fraud prevention and detection.

We may also aggregate and/or deidentify HCP personal information and analyze those data for analytical, research, statistical, or any other purposes permitted by law. After it has been deidentified, the information is no longer personal information and is not subject to this HCP Notice.


Please note that, depending on locally applicable law, we may also process personal information via use of automated technologies, including artificial intelligence, for the purposes listed above. We may also use personal information we collect, as appropriate and to the extent permitted by applicable law, to train automated technologies we use for the above purposes. 
 

With whom do we disclose HCP personal information?  

We disclose the categories of personal information listed in this HCP Notice in the following contexts: 

  • Within Jazz and Affiliates. We may disclose HCP personal information to Jazz personnel and to our affiliates (listed at https://jazzpharma.com/contact/) for the purposes set out in the “How do we use HCP personal information” section of this HCP Notice.
  • Service Providers. We may disclose HCP personal information to our service providers that provide us with services and act on our behalf. For example, we use service providers to assist us in running and managing our Clinical Studies, including CROs, laboratories, and imaging vendors; to manage our patient assistance and support programs; help us to develop and improve our websites, digital forums, and apps, such as technologies suppliers; and professional advisors such as auditors, accountants and lawyers. We impose contractual limitations on our service providers’ use of personal information they collect in conjunction with providing services to us. 
  • Regulatory Authorities and Ethics Committees. We may disclose HCP personal information to regulatory authorities (such as the FDA), auditors, ethics committees, and institutional review boards in order to comply with laws, regulations, and pharmaceutical industry codes.
  • Our Partners. We may disclose HCP personal information to our partners or other sponsors (e.g., other pharmaceutical and medical device companies in the context of consortia or industry initiatives to facilitate research opportunities) at your direction, with your consent, or where permitted or required by applicable law.
  • Clinical Investigators and Site Personnel. We may disclose HCP personal information to other clinical investigators and/or site personnel as part of communications related to Clinical Studies.
  • Third Parties for Marketing & Advertising Purposes. We may disclose your personal information, in accordance with applicable law, to Third Parties, including third party marketing and advertising and analytics providers, who may process personal information for their own purposes.
  • As Described in a Privacy Notice or With Your Consent. We may disclose personal information as described in any privacy notice we provide to you, or with your consent if we obtain it from you in a particular context, to the extent permitted by applicable law.
  • In Aggregate or Deidentified Form. We may aggregate or deidentify the personal information we collect, and we may disclose aggregated and/or deidentified information  n to our affiliates, vendors and to third parties for our business operational purposes and for any other purposes permitted by applicable law.

We may also disclose HCP personal information in the following contexts: 

  • For Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose your personal information to fraud prevention agencies and law enforcement agencies; to courts, governmental and non-governmental regulators and ombudsmen; or as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Jazz believes in good faith that disclosure is legally required or Jazz has a legitimate interest in making a disclosure, such as where necessary to protect Jazz’s rights and property.
  • As Part of a Business Transfer. We may also transfer your personal information to another entity in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings). If such a transfer occurs, we will seek assurances that the successor organization will treat the Personal Information we disclose to it in accordance with this HCP Notice.

Given the global nature of Jazz's activities, your personal information may be transferred to countries located outside your home country or region, including to countries that may not have data protection laws equivalent to those in your home country. In such a case, we will implement appropriate measures to protect your personal information where required by and in accordance with the applicable data protection laws.

How do we protect HCP personal information?


The security of your personal information is important to us. We take reasonable steps, including technical, administrative and physical safeguards, designed to protect the personal information submitted to us from loss, misuse and unauthorised access, disclosure, alteration and destruction. However, no method of security or method of transmission over the Internet is entirely secure. We therefore cannot guarantee that your personal information will not be disclosed, misused, or lost by accident or by the unauthorised acts of others. You should always use caution when transmitting personal information over the Internet. 

How long do we keep HCP personal information? 

We may retain your personal information for as long as your account is active or as needed for the specific business purpose for which it was collected. In some cases, we may be required to retain information for longer to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements. Please note that in certain countries we may be required to retain Clinical Study Documentation for a minimum of 25 years.

Additional Disclosures for HCPs in the EEA, UK, and Switzerland 

This section provides additional information applicable to HCPs located in the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland. 
Data controller. Jazz Pharmaceuticals plc, with an office at Waterloo Exchange, Waterloo Road, Dublin 4, D04 E5W7, is the controller of your personal information, either independently or jointly.
Legal basis. We rely on the following legal basis to process HCP personal information under the GDPR and UK GDPR: 

  • With your consent (GDPR Art. 6(1)(a)), including for the following purposes: to facilitate your registration and attendance at events we sponsor; to respond to your inquiries about our products, policies and programs and provide you with information when you request it.
  • When the processing is necessary for the performance of a contract with you (GDPR Art. 6(b)), including for the following purposes: to coordinate your participation as a speaker at events we sponsor, including any compensation or honorarium; to reimburse you for expenses or pay you under a contract we have entered into with you.
  • When the processing is necessary for the compliance of a legal obligation to which Jazz is subject (GDPR Art. 6(1)(c)), including for the following purposes: to comply with legal, regulatory, industry best practices, and ethical obligations including without limitation applicable laws and industry codes imposing disclosure requirements for transfers of value made to healthcare professionals and healthcare organizations; pharmacovigilance data capture and reporting obligations; and adverse experience and product complaint reporting.
  • When the processing is necessary in order to protect the vital interest of a natural person (GDPR Art. 6(1)(d), including for the following purposes: to protect someone's health, safety or welfare.
  • When the processing is necessary for our legitimate interest in managing our business, improving and advertising our products and services, providing the requested information, to further and manage our Clinical Studies, and in facilitating research opportunities (GDPR Art. 6(1)(f)), including for the following purposes: to manage and provide our patient assistance and support programs; to provide you with promotional and scientific information about our products, services, and events; to identify and evaluate potential sites for our Clinical Studies; to plan and manage our Clinical Studies in accordance with applicable legislation in the context of clinical research; to inform you, plan and/or conduct other Clinical Studies including to identify suitable investigators for our studies; to enable patient recruitment for our Clinical Studies; to assess the effectiveness of the sites participating in our Clinical Studies; to analyze or predict your preferences to identify aggregated trends to develop, improve or modify our products, services and business activities; to conduct advertising, including interest-based advertising on our websites and applications and to improve our advertising efforts; for market research purposes; to manage and protect our network and IT systems; for the establishment, exercise or defense of legal claims or proceedings, to protect our rights or property, and to comply with and enforce our policies; and for fraud prevention and detection.


We only collect and process sensitive personal information if such processing is allowed or required under applicable law. In addition, we only process such sensitive personal information where (in addition to having a legal basis as set out above) it is necessary for the establishment, exercise, or defense of legal claims, where it is necessary for reasons of public interest in the area of public health, where we have obtained your explicit consent to process such data, or where we are required or allowed to do so under EU member state, UK, or Swiss data protection law, as applicable.


Automated decision-making. We do not rely solely on automated processing, including profiling, to make decisions that produce legal or similarly significant effects concerning you as an Applicant. If this changes, we will update this notice and provide all information required by applicable law.


Transfers of personal information outside the EEA, UK, and Switzerland. We may transfer your personal information to the United States or other countries outside of the EEA, UK or Switzerland. For the transfer of personal information from the EEA, UK or Switzerland to any countries not recognized by the European Commission, UK or Swiss governmental authorities as providing an adequate level of data protection according to EEA, UK or Swiss standards, we have implemented adequate measures to protect your personal information, such as by ensuring the recipient is bound by standard contractual clauses adopted by the European Commission, UK and Swiss governmental authorities. You can obtain information concerning such safeguards, including obtaining a copy of the standard contractual clauses, by contacting our data protection officer at dpo@jazzpharma.com.


All Jazz entities have entered into an Interaffiliate Data Processing and Transfer Agreement including Standard Contractual Clauses to govern the transfer of personal information within Jazz Pharmaceuticals from the EEA, the UK and Switzerland to other countries including the United States. 


Data subject rights. HCPs located in the EEA, UK, and Switzerland have the following rights to their personal information, subject to certain exceptions. 

  • Right of Access: you have the right to confirm what personal information is being processed, obtain information about the processing activities and to receive a copy of your personal information.
  • Right to Rectification: you have the right to request rectification / correction of your personal information where it is inaccurate or incomplete.
  • Right to Erasure: you have the right to request deletion of your personal information.
  • Right to Restriction: you have the right to ask that we restrict or suspend the processing of your personal information in certain contexts.
  • Right to Data Portability: you have the right to request to receive your personal information in a structured, commonly used, and machine-readable format and have the right to transmit that information to another data controller.
  • Right to Object: you have the right to object to the processing of your personal information in certain contexts, including for any direct marketing purposes.
  • Right to Withdraw Consent: to the extent our processing of your personal information is based on your consent, you have the right to withdraw your consent, at any time, without hindrance or cost, to prevent further processing. Please note that withdrawing your consent does not affect the lawfulness of our processing of your personal information based on such consent before the withdrawal.
  • Right to Lodge a Complaint: you have the right to file a complaint concerning our processing of your personal information with the competent data protection supervisory authority in the relevant jurisdiction. 
     

For HCPs who work on our Clinical Studies, please note that due to the nature of the processing for scientific research purposes, not all of the above rights may be available to you. For example, personal information cannot be erased at the end of your involvement with the Clinical Study. If you withdraw from working on the clinical study, personal information collected up to your departure will be retained and processed to comply with legal obligations under applicable clinical study legislation, but no further personal information will be collected. We will consider any request and advise you if it is possible without affecting the Clinical Study data integrity.


You can make such a request by contacting us using any of the methods listed in the “How to contact us” section below. Please include your full name, email address, and relationship to Jazz, and type of request. We will respond to your request consistent with applicable law.


When you submit a request regarding your personal information, we reserve the right to verify your identity to help ensure that we provide the information we maintain to the individual to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. Additionally, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized person permission to make a request on your behalf.


If you feel your rights have been infringed as a result of the processing of your personal information in non-compliance with applicable data protection laws, you also have the right to lodge a complaint with your local data protection authority. 


Data Protection Officer. If you have any questions about this HCP Notice or our privacy practices, please contact our Data Protection Officer at dpo@jazzpharma.com.

How to contact us 


If you have any questions, comments or suggestions about this HCP Notice or our privacy practices, please contact the Jazz Pharmaceuticals Privacy Office at:


Address 3000 El Camino Real 2 Palo Alto Square, Suite 600 Palo Alto, CA 94306, U.S.              
Tel.: (650) 496-3777              
Email: privacy@jazzpharma.com

How do we update this HCP Notice? 

We may update this HCP Notice from time to time and will provide notice of such changes by updating the “Last Updated” date listed on this HCP Notice. If required by applicable law, we will provide you with additional notice if we make a material change to the HCP Notice, for example, by sending you an email or posting a banner on our websites. 


Last Updated: October 02, 2026 


 

Jazz Pharmaceuticals — California Healthcare Professional and Clinical Trial Site Personnel Notice

 


The California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”), gives California residents certain rights and requires businesses to make certain disclosures regarding their collection, use, and disclosure of personal information. This California Healthcare Professional and Clinical Trial Site Personnel Privacy Notice (“California HCP Notice”) supplements the Jazz Pharmaceuticals Global Healthcare Professional and Clinical Trial Site Personnel Privacy Notice and provides additional information about Jazz’s processing of personal information about HCPs who are residents of California. 


Please note that this California HCP Notice does not apply to information we collect from non-HCP business contacts or to HCPs that are not California residents. For further details about our privacy  practices pertaining to non-HCP personal information, please visit https://privacy.jazzpharma.com/. 

Definitions  

 

  • “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular HCP or household. 
  • “Service Provider” means a service provider, vendor, contractor, or processor which collects, stores, or otherwise handles personal information for us and is bound by certain contractual obligations consistent with applicable laws.
  • “Third Party” means a person or organization which is not a consumer, Service Provider, or an entity owned or controlled by us.
     

Other terms used herein that are defined terms under the CCPA shall have the meanings afforded to them by the CCPA, whether or not capitalized, unless the context indicates otherwise. 

Categories of HCP Personal Information We Collect 


We collect, and in the past 12 months have collected, the following categories of personal information from HCPs, in accordance with local law and per applicable consents:

  • Identifiers, such as name, postal address, email address, phone number, national provider identifier, date of birth, other contact information, photographs and other visual images of you, and computer or facilities access and authentication information (e.g., identification codes, passwords), IP address, online identifiers, and other similar identifiers.
  • Financial Information, including payment-related information, tax identification number, and other financial disclosure information as required by law. 
  • Characteristics of Protected Classifications under state or federal law, such as age and gender.
  • Commercial Information, such as programs and activities in which you have participated, information about your prescribing of our products, any agreements you have executed with Jazz, and your communication preferences.
  • Internet or Other Network Information, such as browsing history, search history, information regarding your interactions with our websites or advertisements.
  • Geolocation Data, such as device location that is more granular than a city or town.
  • Audio, Electronic, Visual and Similar Information, such as call and video recordings.
  • Professional or Employment-Related Information, such as work experience, professional credentials, professional qualifications, registrations and memberships in associations and boards, scientific activities and publications of academic or scientific research and articles, patents and other scientific and medical achievements, roles or positions held with government bodies or hospital or payor organizations, organizational and institutional affiliations, and information about your scientific and medical colleagues and leaders in your specialty area. 
  • Education Information, such as academic background and credentials. 
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 
  • Sensitive Personal Information, including personal information that reveals:
    •  Social security, driver’s license, state identification card, or passport number; or
    • Racial or ethnic origin.

 

Purpose for Collecting, Processing, and Disclosing HCP Personal Information 


We collect, process, and disclose, and in the past 12 months have collected, processed, and disclosed, the categories of personal information listed in Section II of this California HCP Notice for the following purposes:

  • To manage and provide our patient assistance and support programs; 
  • To facilitate your registration and attendance at events we sponsor; 
  • To provide you with promotional and scientific information about our products, services, and events; 
  • To coordinate your participation as a speaker at events we sponsor, including any compensation or honorarium;
  • To respond to your inquiries about our products, policies and programs and provide you with information when you request it;
  • To identify and evaluate potential sites for our Clinical Studies; 
    •    To plan and manage our Clinical Studies in accordance with applicable legislation in the context of clinical research;
  • To comply with legal, regulatory, industry best practices, and ethical obligations including without limitation applicable laws and industry codes imposing disclosure requirements for transfers of value made to healthcare professionals and healthcare organizations; pharmacovigilance data capture and reporting obligations; and adverse experience and product complaint reporting; 
  • To inform you, plan and/or conduct other Clinical Studies including to identify suitable investigators for our studies;
  • To enable patient recruitment for our Clinical Studies; 
  • To assess the effectiveness of the sites participating in our Clinical Studies;
  • To reimburse you for expenses or pay you under a contract we have entered into with you;
  • To analyze or predict your preferences to identify aggregated trends to develop, improve or modify our products, services and business activities;
  • To conduct advertising, including interest-based advertising on our websites and applications and to improve our advertising efforts; 
  • For market research purposes; 
  • To manage and protect our network and IT systems;
  • To protect someone's health, safety or welfare;
  • For the establishment, exercise or defense of legal claims or proceedings, to protect our rights or property, and to comply with and enforce our policies; and
  • For fraud prevention and detection.


Further, we collect, process, and disclose the categories of sensitive personal information described in this California HCP Notice only for purposes that are permitted by the CCPA regulations, including to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services and to perform services on behalf of the business.


We may also aggregate and/or deidentify HCP personal information and analyze those data for analytical, research, statistical, or any other purposes permitted by law. When we do so, we take reasonable measures to ensure that the information cannot be associated with an HCP or household, and we maintain and use the information in deidentified form. We will not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements. After it has been deidentified, the information is no longer personal information and is not subject to this California HCP Notice.


Please note that we may also process HCP personal information via use of automated technologies, including artificial intelligence, for the purposes listed above. To the extent permitted by applicable law, we may also use personal information we collect to train automated technologies we use for the above purposes.  However, we do not process HCP personal information using automated decision making technologies to make significant decisions concerning HCPs.  

HCP Personal Information Retention  


We may retain your personal information for as long as your account is active or as needed for the specific business purpose for which it was collected. In some cases, we may be required to retain information for longer to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements. Please note that in certain countries we may be required to retain Clinical Study Documentation for a minimum of 25 years.

Sale & Sharing of HCP Personal Information  


Under the CCPA “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s personal information to a Third Party for money or other valuable consideration, and “Share,” “Shared,” or “Sharing” means transferring an individual’s personal information to a Third Party for cross-context behavioral advertising, whether or not for money or other valuable consideration. Accordingly, we Sell and Share and in the past 12 months have Sold and Shared, identifiers, such as IP addresses and other device identifiers, internet or other electronic network activity information, and inferences to third party marketing and analytics providers. We Sell and Share these categories of personal information for marketing and analytics purposes, including to analyze or predict consumer preferences to identify aggregated trends to develop, improve or modify our products, services and business activities and to deliver advertising, including interest-based advertising on our websites and applications and improving our advertising efforts. We do not otherwise “Sell” or “Share” other types of personal information we may collect about HCPs outside the cookie and online tracking technology context. 


California HCPs have the right to opt-out of the Sale and Sharing of their personal information. To do so, click the “Your Privacy Choices” link in the footer of our websites and click “Reject All.”


We do not Sell or Share personal information of consumers we know, or reasonably should know, are under 18 years of age.

Disclosure of HCP Personal Information 


We disclose, and in the past 12 months have disclosed, the categories of HCP personal information listed in Section II of this California HCP Notice in the following contexts: 

  • Within Jazz and Affiliates. We may disclose HCP personal information to Jazz personnel and to our affiliates (listed at https://jazzpharma.com/contact/) for the purposes set out in Section III of this California HCP Notice.
  • Service Providers. We may disclose HCP personal information to our Service Providers that provide us with services and act on our behalf. For example, we use Service Providers to assist us in running and managing our Clinical Studies, including CROs, laboratories, and imaging vendors; to manage our patient assistance and support programs; help us to develop and improve our websites, digital forums, and apps, such as technologies suppliers; and professional advisors such as auditors, accountants and lawyers. We impose contractual limitations on our Service Providers’ use of personal information they collect in conjunction with providing services to us. 
  • Regulatory Authorities and Ethics Committees. We may disclose HCP personal information to regulatory authorities (such as the FDA), auditors, ethics committees, and institutional review boards in order to comply with laws, regulations, and pharmaceutical industry codes.
  • Our Partners. We may disclose HCP personal information to our partners or other sponsors (e.g., other pharmaceutical and medical device companies in the context of consortia or industry initiatives to facilitate research opportunities) at your direction, with your consent, or where permitted or required by applicable law.
  • Clinical Investigators and Site Personnel. We may disclose HCP personal information to other clinical investigators and/or site personnel as part of communications related to Clinical Studies.
  • Third Parties for Marketing & Advertising Purposes. We may disclose certain categories of personal information in accordance with applicable law  to Third Parties, including third party marketing and advertising and analytics providers, who may process personal information for their own purposes. Please note this may constitute a Sale or Share of your personal information. For more information, please see Section V of this California HCP Notice. 
  • As Described in a Privacy Notice or With Your Consent. We may disclose personal information as described in any privacy notice we provide to you, or with your consent if we obtain it from you in a particular context, to the extent permitted by applicable law.
  • In Aggregate or Deidentified Form. We may aggregate or deidentify the personal information we collect, and we may disclose aggregated and/or deidentified information to our Service Providers and Third Parties for our business operational purposes and for any other purposes permitted by applicable law.


We may also disclose HCP personal information in the following contexts: 

  • For Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose your personal information to fraud prevention agencies and law enforcement agencies; to courts, governmental and non-governmental regulators and ombudsmen; or as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Jazz believes in good faith that disclosure is legally required or Jazz has a legitimate interest in making a disclosure, such as where necessary to protect Jazz’s rights and property.
  • As Part of a Business Transfer. We may also transfer your personal information to another entity in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings). If such a transfer occurs, we will seek assurances that the successor organization will treat the Personal Information we disclose to it in accordance with this California HCP Notice.

Sources of HCP Personal Information  


We collect HCP personal information directly from HCPs. We may also collect HCP personal information from the following sources: 

  • Publicly available sources such as websites including clinicaltrials.gov, www.clinicaltrialsregister.eu, the US FDA’s Debarment and Disqualified and Restricted Lists for clinical investigators;
  • The research center where you work or conduct/support research activities;
  • Service Providers and Third Parties when they disclose personal information to us;
  • Providers of demographic data; publications; professional organizations; educational institutions; and social media platforms;
  • Cookies and other tracking technologies when you visit our websites. 

Your Rights 


As a California HCP, you have the following rights regarding our collection and use of your personal information, subject to certain exceptions.


Rights that Require Verification 

  • Right to Know: You may request that we provide you with the following information about how we have handled your personal information:
    • The categories of personal information we collected about you; 
    • The categories of sources from which we collect such personal information;
    • The business or commercial purpose for collecting, Selling, or Sharing the personal information we collected about you;
    • The categories of personal information about you that we Shared, Sold, or disclosed; and
    • The categories of Third Parties with whom we Sold, Shared, or disclosed the personal information collected about you.
  • Right to Deletion: You may request that we delete any personal information about you that we collected from you. 
  • Right to Correction: You may request that we correct any inaccurate personal information we maintain about you. 
  • Right to Access Specific Pieces of Personal Information: You may ask to obtain the specific pieces of personal information we have collected about you. You may not exercise this right more than two times in a calendar year. 


Exercising the Rights to Know, Deletion, Correction, and Access Specific Pieces of PI: You can make such a request by calling (888) 249-7888, or by clicking here and filling out the Privacy Request Form. To verify your identity, we will match the information provided in the request to the information we have in our records. If necessary, we may ask the requestor to provide additional information to verify your identity and confirm that the request is valid. You may be able to authorize an agent to submit a request on your behalf. Authorized agents may submit a request in the same manner as an HCP, as listed above. When you use an authorized agent, we may ask the authorized agent to provide a copy of the HCP’s signed permission authorizing the agent to act on the HCP’s behalf, and in certain circumstances, we may ask you to verify your own identity directly with us. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.


Rights that Do Not Require Verification 

  • Right to Opt-Out of Sale and Sharing: You have the right to opt out of the Sale and Sharing of your personal information. To do so, click the “Your Privacy Choices” link in the footer of each page of our website and click “Reject All”.
  • Limit the Use of Your Sensitive Personal Information: We do not use sensitive personal information that we collect about HCPs for purposes other than those that are permitted by the CCPA regulations. But if we did, you would have the right to limit the use of your sensitive personal information to the purposes permitted by the CCPA.
  • Right to Opt-Out of ADMT: We do not process HCP personal information using automated decision making technologies to make significant decisions concerning HCPs. But if we did, you would have the right to opt out of our use of automated decision making technologies to make significant decisions about you, subject to certain exceptions. 

Opt-Out Preference Signals: We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by the CCPA, we treat such opt-out preference signals as a valid request to opt-out of Sale and Sharing for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of Sale and Sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. However, our sites do not respond to the “Do Not Track” signal, which is different from the opt-out preference signals described above. 


Non-Retaliation: You have the right not to receive discriminatory treatment for the exercise of these rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

Other Disclosures 

 

  • Financial Incentives: We do not provide financial incentives to California HCPs. We will describe such programs to you if and when we offer them to you.

 

Changes to this California HCP Notice& 


We may update this California HCP Notice from time to time and will provide notice of such changes by updating the “Last Updated” date listed on this California HCP Notice. If required by applicable law, we will provide you with additional notice if we make a material change to the California HCP Notice, for example, by sending you an email or posting a banner on our websites. 

Contact Us 


If you have any questions about this California HCP Notice or our privacy practices, please contact the Jazz Pharmaceuticals Privacy Office at:


Address: 3000 El Camino Real 2 Palo Alto Square, Suite 600 3170 Porter Drive, Palo Alto, CA 94306, U.S.   
Tel.: (650) 496-3777; Toll Free: (888) 249-7888                            
Email: privacy@jazzpharma.com