This privacy notice (“Notice”) is provided by Modavar Pharmaceuticals, LLC. Modavar is referred to in this Notice as “we”, “us” and “our”.
This Notice explains what types of personal data Modavar may collect from you and how we use it. It also explains the policies and practices that we have developed to safeguard personal data and to comply with applicable data protection laws. Please read this Notice carefully to understand what personal data we collect, how we collect it, how we use it, who we may disclose it to, and how you can manage your personal data.
This privacy notice explains our general practices. However, where local laws or regulations require that we process information differently, or refrain from such processing, we will always comply with the applicable local law.
We may collect, use, store and transfer different categories of personal data about you which we have grouped together as follows:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes personal data you provide when you:
Automated interactions. As you interact with our website or intranet, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
Third parties (or publicly available sources). We may receive categories of personal data about you from various third parties and public sources as set out below:
We process the personal information we collect for the following purposes/legal bases:
We process your personal data when it is necessary for the performance of a contract with you, or where you have requested us to take steps prior to us entering into a contract together, in particular:
b. Legal obligation
We process your personal data to meet legal (including tax and accounting), regulatory, pharmacovigilance, quality, medical inquiry, and compliance requirements, including:
We may also process your personal data in connection with dispute resolution, legal claims, compliance, regulatory and such investigative purposes as we deem to be necessary (including disclosure of such information in connection with legal process or litigation). We maintain records of any consents, preferences or other settings to enable us to comply with data protection laws.
c. Legitimate interests
We also process your personal data when it is necessary for the purposes of our legitimate interests as a controller (or those of a third party):
Modavar does not and will not sell your personal data. We may, however, share your personal data with the parties set out below for the purposes set out in the section “How We Use Your Information.”
Internal Third Parties: other companies or departments in Modavar that provide IT and system administration services and undertake leadership reporting may receive any category of data as necessary to perform job functions.
External Third Parties: service providers who provide IT and system administration services and data analytics, vendors who provide clinical trial services, and third parties that provide promotional and marketing support may receive any category of data as necessary to perform their services.
Other Third Parties: third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets may receive any category of data as necessary to perform the transaction. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
Professional advisers: advisors (e.g., lawyers, bankers, auditors and insurers) who provide consultancy, banking, legal, insurance and accounting and payroll services may receive any category of data as necessary to perform their services.
Supervisory Authorities: Revenue and Customs, IRS and FDA, regulators and other authorities who require reporting of processing activities in certain circumstances may receive any category of data as necessary to comply with legal and regulatory requirements.
Modavar may also disclose aggregate or anonymized data that is not personally identifiable to third parties for any purpose.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional material from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Opting in. You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have opted-in to receiving that marketing.
Third-party marketing. We will get your express opt-in consent before we share your personal data with any company outside Modavar for marketing purposes.
Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty, product/service experience or other transactions.
Google Analytics. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach when we are legally required to do so.
The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers (i.e., California residents) with specific rights, subject to some limitations and verification, regarding their personal data:
1. Consumers have the right to know about the personal data Modavar collected, disclosed, or sold about them in the 12 months preceding the date Modavar received the request.
2. Consumers have the right to request deletion of their personal data collected or maintained by Modavar.
3. Consumers have the right to opt-out of the sale of their personal data.
4. Consumers have the right to non-discrimination for the exercise of their privacy rights.
If you would like to exercise any of these rights, please go to the “Contact Us” section of our website. We will provide you with a form to complete that will ask you for your contact information, the right(s) you wish to exercise, and two pieces of identification that between them show your name, date of birth and address. The information collected will only be used to respond to your request and for record-keeping purposes to demonstrate compliance with the CCPA.
If the consumer prefers, he or she may designate an authorized agent to make a request under the CCPA on the consumer’s behalf.
California Civil Code Section 1798.83 permits California residents who are individual customers of Modavar products to request certain information regarding its disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using our contact information listed in Section A (“How to Contact Us”).
Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.
While in some instances we may collect personal data about children with the consent of a parent or guardian, such as clinical activities or for patient support programs, we do not otherwise knowingly solicit data from, or market to, children. If a parent or guardian becomes aware that his or her child has provided us with personal data, he or she should contact us through the “Contact Us” section of our website. We will take reasonable steps to delete such data from our database within a reasonable time.
As a convenience to our website visitors and users, Modavar may offer links to non-Modavar sites that we believe may offer useful information. The inclusion of a link on the Modavar website does not imply our endorsement of the linked site or service. When you click on one of these links, you will be transferred from the website and be connected to the site of the organization or company that you selected. This Notice is no longer applicable when you leave a Modavar site by way of link. Each of these linked sites maintains its own independent privacy policies and procedures, which you should consult before providing any of your personal information. After choosing to move to a third-party’s website, you will receive a notification that you are leaving our website.
Modavar may update this Notice from time to time. Please check this Notice periodically for changes. If we make any changes, the updated Notice will be posted with a revised effective date. We encourage you to periodically review this page for the latest information on our privacy practices.
By law you may be entitled under circumstances to the following:
If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using the contact details in this Privacy Notice.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Please contact us at: email@example.com
Effective Date: April 2022