Lupin California Notice at Collection
Last Updated: October 5, 2023
Lupin Pharmaceuticals, Inc. (“Company,” “Lupin,” “we,” “us,” or “our”) respects your privacy. This California Notice at Collection (“Notice”) provides you with timely notice before or at the time when we collect Personal Information from you. In this Notice, we explain the categories and sources of Personal Information we collect from you and how we use, share, and protect that Personal Information. This Notice applies to Personal Information you provide whether your visit our website (“Website”), interact with us over the phone, or visit our stores.
For more information about our privacy practices, please visit our Privacy Statement.
WE MAY MODIFY THIS NOTICE AT ANY TIME. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING TO THE WEBSITE.
If you are a California resident and would like to submit a request to opt out of the selling or sharing of your Personal Information, please see the Your Privacy Choices webpage.
IF YOU PROVIDE PERSONAL INFORMATION WITH REGARD TO OUR PHARMACOVIGILANCE PROGRAM, PLEASE SEE OUR PHARMACOVIGILANCE PRIVACY STATEMENT WHICH DESCRIBES HOW WE COLLECT, USE AND SHARE THE PERSONAL INFORMATION YOU PROVIDE IN CONNECTION WITH THAT PROGRAM.
1. WHAT IS PERSONAL INFORMATION?
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include publicly available information or aggregated information that does not include personal identifiers.
2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We may collect the following categories of your Personal Information. We have collected the following categories of Personal Information from consumers within the twelve (12) months preceding the effective date of this Privacy Statement:
|Category||Examples||Retention Period||Is the Category Sold or Shared?|
|Identifiers||Name, address, internet protocol address (“IP Address”), social media handle, email address, phone number and government ID numbers, mailing address, physician NPI and ME numbers.||We retain this information for so long as we maintain a business relationship with you; and for so long as required for any other business or legal purpose.||Yes|
|Customer Records||Your signature, government ID numbers, physical characteristics or description, address, telephone number, insurance policy number and other medical information that you provide if you report an adverse event or product complaint.||This Personal Information will generally be kept for as long as is reasonably necessary taking into consideration our business relationship with you and our need to answer queries or resolve problems, and any other purpose outlined below.
If collected as part of our Pharmacovigilance Program, we keep this information for so long as necessary to comply with legal requirements under applicable law(s), in particular by the US Food & Drug Administration regulations related to reporting of adverse events related to our products.
|Protected Classifications||Please see our Pharmacovigilance Privacy Statement.||Please see our Pharmacovigilance Privacy Statement.||No|
|Commercial Information||Records of products purchased or used by you, and content of communications you send to us or post online, including our social media accounts or posts.||We retain this information for so long as we keep a business relationship with you; and for so long as required for any other business or legal purpose.||Yes|
|Internet Activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.||We retain this information for 14 months.||Yes|
|Sensory Data||Recordings of customer service calls, if you participate in our patient testimonial videos for the Website, employee introduction videos.||Recording of customer service calls are retained for 10 years, as required to meet our legal obligations.
Internal training videos and patient testimonial videos are kept for so long as we have a legitimate business need.
|Employment Information||Professional or employment-related information that you provide when you apply for a position with us.||If Lupin does not hire you, we keep your application for 12 to 18 months. If you are hired at Lupin, we keep your application and employment information for the duration of employment plus 6 years after termination of employment.||No|
|Education Information||Education-related information, including information you provide when you apply for a position with us.||If Lupin does not hire you, we keep your application for 12 to 18 months. If you are hired at Lupin, we keep your application and employment information for the duration of employment plus 6 years after termination of employment.||No|
|Inferences Drawn from other Personal Information||Inferences drawn from the categories of Personal Information we collect are used to create a profile about your consumer preferences and purchasing tendencies.||We retain this information for as long as we have a business relationship with you; and for so long as required for any other business or legal purpose.||No|
3. WHAT ARE THE PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION?
We collect Personal Information for the following business or commercial purposes:
|Purpose of Collection and Use||Examples/Explanations||Category|
|To Provide and Improve Our Customer Service||We use Information we collect from the Website to improve our products, choose what products we offer, offer you new products, and to predict trends with regard to our products.||Identifiers, Commercial Information, Internet Activity|
|Business Purposes||We use Personal Information for administrative purposes, such informing our business strategies, to understand the Website demographics and user preferences, for evaluating job applications, paying vendor invoices, and to manage profiles.||Identifiers, Commercial Information, Internet Activity.|
|Website Management||We use Personal Information for website management, such as troubleshooting problems, improving the content and functionality of our Website, statistical and other analyses of the Website, and to customize the Website. We also may use Personal Information to audit our Website for compliance, authorized access and security.||Identifiers, Internet Activity|
If you participate in our patient testimonial videos, we may collect Personal Information about you to facilitate that process.
We may obtain your Social Media handle if you comment on or “like” our Social Media posts or ads.
|Identifiers, Commercial Information, Internet Activity|
|To Protect Our Rights||We may use Personal Information to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Website, or to others. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.||Identifiers, Commercial Information|
|For Drug Safety and To Meet Our Regulatory Obligations||Please see our Pharmacovigilance Privacy Statement for more information.||Please see our Pharmacovigilance Privacy Statement.|
|Job Applications||To enable you to fill out our job application and submit application materials, to enable email communications, and to process and track job applications.
We may collect Personal Information for background checks, drug screenings and others information from job applicants as relevant to the open position.
|Identifiers, Employment Information, Education Information.|