Global Whistleblowing Data Protection Notice

The type of information that we collect will depend on whether you act as a reporter or are an individual referred to in a report. This information generally includes:

• Identifiers/Contact Information: name, surname (including prefix or title), personal or business email, mailing address, telephone number, job title, workplace, relationship with Jazz Pharmaceuticals.
• Report related information:
  • what information you know about the violation and how you learned about it,
  • if there is any documentation that would support the investigation,
  • identity, function, contact details and other relevant personal information of others who may have knowledge of the report,
  • whether your supervisor, local HR or local management has been notified of the report and if so, names and details of the relevant supervisor, local HR or local management,
  • other details concerning the report and collected in the course of the subsequent investigation.

We collect your personal information from a variety of sources.

In most cases we will obtain information directly from you. We may also receive personal information about you from other sources, which could include:

• another reporter,
• individuals referred to in the report or identified during the investigation,
• your supervisor,
• authorized persons involved in the investigation of a report,
• public authorities, or
• other publicly accessible sources.

In certain countries, Jazz Pharmaceuticals has a legal obligation to put in place reinforced control mechanisms and to implement an internal whistleblowing scheme. In such case, Jazz Pharmaceuticals will use your personal information based on such legal obligation to identify and investigate suspected violations of laws, rules, regulations or company policies.

In other countries where there is no legal obligation to implement an internal whistleblowing scheme, Jazz Pharmaceuticals has a legitimate interest to implement such internal scheme to be able to identify and investigate suspected violations of laws, rules, regulations or company policies. In such case, Jazz Pharmaceuticals will use your personal information based on such legitimate interests.

Please note that where required by law we will obtain your consent.

Unless otherwise required by law, the information may only be reviewed and used by those individuals who need to access the data to fulfill their job duties. These individuals may include appropriate Jazz Pharmaceuticals employees in the Legal, Corporate Compliance or Human Resources departments, personnel in the company’s Finance, IT and Audit functions.

We may also need to share your personal information as follows, but only to the extent necessary:

• to third-party service providers who assist us with investigations and/or operate the reporting hotline;
• to other specialized third-party service providers who work with us such as professional advisors such as auditors, accountants and lawyers;
• 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.

Given the global nature of Jazz Pharmaceuticals’ activities your personal information may be transferred to countries located outside your country or region, including to countries that may not provide a similar or adequate level of protection to that provided by your country or region. In such a case, we will implement appropriate measures to protect your personal information in accordance with the applicable data protection laws.

For example, if you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or 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 the personal information, such as by ensuring the recipient is bound by standard contractual clauses adopted by the European Commission, UK and Swiss governmental authorities.

All Jazz Pharmaceuticals’ 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.

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.

Any information you submit that is not needed to answer your question or for the investigation of any incident may be deleted or archived, as permitted by local law. In addition, once we have responded to your question or completed any investigation, all information you submitted will be deleted or archived as required by local law.

You may have certain rights under local applicable data protection laws, which may be subject to limitations and/or restrictions. These rights may include the right to: (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) the right to data portability.

Please be aware that there may be limitations to your rights if they interfere with our legal obligations.

If you wish to exercise one of the above-mentioned rights, please send us your request by using any of the methods listed in the “How to contact us” section below.

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.

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

Address: 3170 Porter Drive, Palo Alto, CA 94303, U.S.                                
Tel.: (650) 496-3777                                
Email: privacy@jazzpharma.com

For UK, Swiss and European purposes, our Data Protection Officer can be reached at dpo@jazzpharma.com.

We may update this Privacy Notice from time to time and will provide notice of such changes by updating the “Last Updated” date listed on this Privacy Notice. If changes are significant, we will provide a more prominent notice to let you know what the changes are.