Jazz Pharmaceuticals — General Privacy Statement

UNITED STATES

Last updated: January 21, 2025

Jazz Pharmaceuticals — General Privacy Statement

Introduction

Jazz Pharmaceuticals plc and its corporate subsidiaries and affiliates including GW Pharmaceuticals companies (“we”, “us” and “our”) recognise the importance of and are committed to respecting and protecting your privacy.

This Privacy Statement applies to our collection and use of your personal information through our websites, mobile pages, applications, devices and platforms (together, the “Site”), when we communicate with you and through our offline business-related interactions with you when other notices in our Privacy Center do not apply.

Personal information means any information or piece of information which could identify you either directly (e.g. your name) or indirectly (e.g. a unique ID number).

For the purposes of UK, Swiss and European data protection laws, we are acting as the data controller of your personal information either independently or jointly.

Please read this Privacy Statement carefully in order to understand how we collect, use, share and store your personal information. By continuing using the Site or by providing your personal information to us, you agree to this Privacy Statement. If you do not agree with our use of your personal information as described in this Privacy Statement, please do not use the Site or otherwise provide personal information to us.

If you are a California resident, please read the Supplemental Notice for California Consumers by clicking here.

What personal information do we collect about you?   

We may collect the following personal information about you:

  • Basic information – your name, surname (including prefix or title), alias, gender, age or date of birth, as well as your preferred language.
  • Contact information – information that enables us to contact you, e.g. your personal or business email, mailing address, telephone numbers and profile on a social media platform;
  • Product use – data related to your use of our products (including feedback), your purchase history and preferences, your interactions with us, your preferred method of communications with us, and services you may use;
  • Health information – your health status, health conditions you are experiencing and health information inferred from information that you have provided to us; If you are a patient/consumer in the United States please read our US Consumer Health Data Privacy Policy here;
  • Technical and network activity information – information about your device and your usage of our websites, apps and systems, including your IP address, device ID, hardware model and version, mobile network information, operating system and other online identifiers, type of browser, browsing history, search history, access time, pages viewed, URLs clicked on, forms submitted, and physical location;
  • Audio visual – photos, videos and voice recordings of you including videos recordings captured through closed-circuit television (CCTV) in compliance with applicable laws;
  • Office visits information - Time of entry to and exit from a Jazz Pharmaceuticals office location;
  • Market research information - Responses to market research questions including your views and opinions;
  • Publicly available information - including that on social media (such as comments describing support for or experience with Jazz Pharmaceuticals products); and
  • Any information that you choose to provide to us through a webform, email message, mobile app, phone call, or other method of communication.

How do we collect your personal information?  

We collect your personal information from a variety of sources. In most cases we will obtain information directly from you in the following situations:

  • when you complete forms on the Site, including if you register, upload or submit any material via the Site, or enter into any competition or promotion we may sponsor;
  • when creating a user account;
  • when you report a problem or submit queries, concerns or comments regarding the Site or its content;
  • when subscribing to newsletters or signing-up to receive promotional communications from us;
  • when attending an online event;
  • when ordering products and services via the Site (such as information materials, brochures, etc.)
  • in connection with a patient assistance or support program. If you choose to participate in one of our patient assistance or support programs, please refer to the enrolment form specific to that program for more information on how your personal information will be collected and processed.
  • when you participate in discussion boards or other social media functions connected with the Site;
  • when you choose to respond to or participate in surveys that we may, from time to time, run on the Site for research purposes;
  • when you voluntary participate in our market researches;
  • when you visit our offices; and
  • in connection with offline business-related interactions with you, such as if you provide information to us at an industry event or contact us by telephone.

Our collection of your personal information is necessary for us to provide you with the requested service, including services available through the Site. If you choose not to provide personal information, we may not be able to provide you with the requested services.

We may also receive personal information about you from other sources, which could include:

  • third-party service providers, data brokers, market research agencies and business partners;
  • healthcare professionals and their staff;
  • industry and patient groups and associations (including conference and event organizers);
  • publicly available sources, including information provided on websites, social media platforms, public forums or platforms, and other third-party sources; and
  • government agencies, civil servants and public records..

In addition, we automatically collect basic technical information from all visitors to the Site. We collect technical information during your visit to the Site through our automatic data collection tools, which may include cookies and other commonly used technologies. These tools collect certain standard information that your browser sends to the Site such as your browser type and language, access times, and the address of the site from which you came to the Site. They may also collect information about your Internet Protocol (IP) address, or click stream data within the Site (i.e. the actions taken in connection with the Site). Please see “Cookies and other similar technologies” below for additional detail about the information we collect through cookies and other commonly used technologies.

How do we use your personal information?   

Subject to applicable data protection laws, we may use your personal information for legitimate business purposes for example to enable us to run our business successfully. These include the following:

  • Providing you with the services and information offered through the Site;
  • Contacting you and responding to your requests and inquiries;
  • for business administration, including statistical analysis;
  • Personalising your visit to the Site and assisting you while you use the Site; Improving the Site by helping us understand who uses the Site;
  • Analysing or predicting your preferences to identify aggregated trends to develop, improve or modify our products, services and business activities;
  • Managing our IT and communications systems and networks; and
  • For fraud prevention and detection.

Where required by law, we will gather your consent to process your personal information.

We may also use your personal information to fulfill our contractual obligations, for the establishment, exercise or defence of legal claims or proceedings and to comply with applicable laws, regulations or codes of practice. The servers used in the operation of the Site automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement to protect our rights or property.

We may contact you periodically by e-mail to provide information regarding programs, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing communications from us. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

You may unsubscribe from receiving marketing or other commercial emails from Jazz Pharmaceuticals by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing or transactional communications (such as important product safety information, appointments, or changes in website or mobile application terms).

We may also process personal information that you made publicly available on public social media platforms (including blogs, forums etc.), related to Jazz Pharmaceuticals, our products, and more in general about drugs and diseases. This activity, called “social media listening”, is based on our legitimate business interests, for example to (i) have a better understanding of how certain key audiences like healthcare professionals or patients experience certain diseases or react to the use of Jazz Pharmaceuticals products, (ii) have a better understanding of Jazz Pharmaceuticals’ reputation as well as other market trends, (iii) identify key-stakeholders and to initiate contact with them. This may include your personal information in form of comments, messages, blogs, photos and videos.

We may also use your personal information as part of our market research efforts. We engage market research agencies to conduct the market research who only share aggregate or anonymised information with us. This means that the market research agency will not disclose any information that could identify you to us. We analyze and evaluate your responses to our market research questions to understand needs, preferences, opinions or experiences regarding a product, service, disease, treatment, payer landscape, or healthcare area, or to better understand future opportunities in a market, to improve our understanding of our industry or disease space, or to monitor market performance. Where required by law we will rely on your consent or our legitimate interest to gather data about our company and the industry that we work in, better understanding the reimbursement or disease area, and improving our understanding of the way we work. Where we collect health or medical information, we will do so based on your explicit consent. You can withdraw your consent at any time by telling the person who contacted you in relation to the market research, or by contacting them at a later time using the communication mode (e.g. email/phone) they provided to you at the time of the market research and referencing the market research in which you are participating.

When you visit one of our offices, we process your personal information to (a) register you as a visitor (including the issuance of a visitor badge in some locations), (b) facilitate your visit, (c) administer access to the Visitor WiFi and (d) maintain the general security and integrity of our physical premises, Visitor WiFi and IT systems (such as by implementing closed-circuit television recording with adequate notice as required by law and by monitoring and restricting use of our Visitor WiFi to restrict access to certain websites which may contain inappropriate or untrustworthy content).Such processing is based on our legitimate interests to protect against criminal offenses, safeguard domestic law, maintain a safe workplace for staff, administer access to visitor WiFi, protect the security and integrity of our premises and IT systems (including WiFi) and defend against claims asserted for damages under civil law.

With whom do we share your personal information?  

We may use selected vendors to provide us with services, including companies that provide us with technical support and assistance in respect of the Site, who may have access to your personal information on a need-to-know basis while performing services on our behalf.

Our affiliates (https://jazzpharma.com/contact/) may also have access to your personal information including through or in connection with this Site for the purposes set out in this Privacy Statement.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement, judicial and regulatory authorities.

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.)

When do we transfer your personal information outside your home country?   

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.

How do we protect your 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. You should always use caution when transmitting personal information over the Internet.

How long do we keep your 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 to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements.

In some jurisdictions, laws and regulations tell us how long we must keep your personal information. How long depends on the laws of the jurisdiction you are in when you share the information with us.

What are your rights regarding your personal information?   

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 their personal information; (ii) obtain restriction of processing or to object to processing of their personal information; and (iii) the right to data portability.

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.

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.

Cookies and other similar technologies   

Jazz Pharmaceuticals may use cookies or other similar technologies to make our websites work the way you expect them to; to assess how our websites are used; to personalize your experience and to deliver online content tailored to your interests.

Cookies are small text files that are stored on your computer or other web accessing devices by websites that you visit. These cookies allow us to distinguish you from other users of a website, and to enhance our websites and your experience when you browse our websites. For more information on cookies and other similar technologies, please refer to our Cookie Policy.

You can also find information about the cookies that we use and change your settings for cookies and similar technologies by clicking on the Cookie Settings (or Cookie Preferences) link in the footer of each page of our websites. In addition, you can refuse or accept cookies by activating the settings on your browser. The “help” menu on most internet browsers contains information on how to disable cookies, or you can visit www.allaboutcookies.org. Please note that if cookies are disabled in your browser, some features or functionality of our websites may not function correctly.

External links  

The Site may, from time to time, contain links to external sites operated by other entities. We are not responsible for these external sites or the content of such external sites. Once you have left the Site, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement for the website you visit.

Email a friend  

We may from time to time, where permitted by applicable laws operate a “Send” or “Share” service to enable you to easily share content from the Site with someone else. If you use this facility please ensure that you have obtained that person’s consent before you provide us with their personal information. We will use this personal information to send the individual a single email message on your behalf.

Children under 13  

This Site is not directed towards children under 13 years of age nor do we knowingly collect information from children under 13. If you are under 13, please do not use the Site or submit any personal information to us. If you believe that we have unintentionally collected personal information about your child, you can contact us as described below.

How to contact us   

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 erreichen.

If you are a resident of California, Washington or Nevada please use our online Privacy Request Form.

How do we update this Privacy Statement?   

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