Privacy Policy

Last Updated: December 2nd, 2025

Dompé U.S. Inc. (“Dompé U.S.”) is the United States subsidiary of Dompé farmaceutici S.p.A. an Italian biopharmaceutical research and manufacturing company. This privacy policy describes how Dompé U.S. (as well as any additional subsidiary, affiliate or branch Dompé U.S. may subsequently form in the U.S.) collects, uses, processes, combines and discloses, if applicable, different types of information in the regular course of its business (the “Privacy Policy”). This Privacy Policy governs the use of all Dompé U.S. owned and or operated applications, platforms, websites or mobile websites which reference or link to this specific Dompé U.S. Privacy Policy (the Dompé owned or operated websites and mobile websites are collectively, the “Websites”). This Privacy Policy also governs Dompé U.S.’ offline offerings and or any services we provide, including but not limited to clinical trials, and or interactions with the scientific community, consumers, patients, and health care professionals (collectively, the “Services”). This Privacy Policy also explains your ability to control certain uses or disclosures of your information, your rights, and/or choices. If you provide us with the information of anyone other than yourself (such as a patient or family member), you are responsible for obtaining valid consent and complying with all applicable data and privacy laws before you do so. 

Please see our Consumer Health Data Privacy Policy for additional information about our collection of consumer health data.

1. INFORMATION WE COLLECT
1.1. Directly
1.2. Automatically 
1.3. From Other Sources 
1.4. Notice Regarding Third-Party Websites, Social Media Platforms and Software Development Kits. 
1.5. Combination of Information 

2. OUR INFORMATION USE 
2.1. Use By or For Dompé
2.2. Interest-Based Advertising 

3. INFORMATION WE SHARE WITH OTHERS 

4. YOUR CHOICES AND OPT-OUTS
4.1. Cookies, Tracking Options, and California Do Not Track Disclosures 
4.2. Interest-Based Advertising Choices 
4.3. Partner-Specific Preferences
4.4. Unsubscribing from Our Marketing Communications
4.5. Updating Your Information
4.6. Your GDPR Rights 

5. CHILDREN'S PRIVACY 

6. DATA RETENTION AND SECURITY 

7. INTERNATIONAL TRANSFER 

8. REVISIONS TO THIS PRIVACY POLICY

9. HOW TO CONTACT US

10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES

1. INFORMATION WE COLLECT

The categories of information we collect depend on whether you visit or engage with our Websites receive or use our Services, and the requirements of applicable law. 

There are several ways we collect information about or from you, including: (1.1) directly; (1.2) automatically; and (1.3) from third parties. The information we collect includes data, information that is de-identified, and information that identifies you like your name, or which can be linked to you (i.e., information about your online use).

1.1 Directly

When you elect to share information with us (or a third party engaged by us to perform a service for us) Dompé collects all information you provide directly. For instance:

• When you contact us via email, letter or phone, we will collect at a minimum your name, and email address, and any additional information we request or you send us during the verbal or written exchange. Please note that some phone calls may be recorded and that we may keep a copy of the recording for quality assurance or other reasons; however, we will abide by legal requirements as applicable to inform you that a call is being recorded.
  
  
• When you interact with or provide any information on our Website forms, such as signing up for our email lists, applying for a grant, requesting professional support, or otherwise chat or communicate with or contact us online, we collect any information you actually provide on any field, application or form, and depending on the reason for communicating with us this could include your first and last name, reason for contacting us, chat or post information, professional or employer information, as well as contact information, as applicable, which would include your email address, address, zip code, and or a telephone number.
  
  
• When HCPs or members of the scientific community provide us their information during industry events, trade shows, or conferences, we collect any information supplied.
  
  
• In connection with pharmacovigilance or government reporting requirements, and our clinical trials (after you provide written consent) we will collect any information you provide us as well as all elements required by law, which, as applicable, could include official forms of identification like driver’s license, passport number, tax identification number, as well as health information related to your medications, medical history, medical insurance details, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history.
  
  
• We or third parties on our behalf may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal data, and all such information will be collected.
  
  
• We or third parties on our behalf may offer forums, blogs, or social media pages. Any content you provide on these types of channels will be considered “public” and is not subject to privacy protections nor this privacy policy.
  
  
• When you sign our Dompé U.S.’ patient support program Dompé CONNECT to Care (“DC2C”) enrollment form we collect your personal, demographic, contact, health, treatment and contact information, and you consent ((and authorize your health plans, health care providers, healthcare clearinghouses, and their business associates such as Dompé U.S.’ specialty pharmacy and or pharmacy hub (“Covered Entities,” as such term is defined under the Health Insurance Portability and Accountability Act, better know as HIPPA)) to share said information with Dompé U.S. and or certain third parties working with or for Dompé U.S. to provide you patient support program Services related to your prescription for a Dompé U.S. product. Dompé U.S. only receives such information if you have chosen to enroll in the DC2C program by signing the enrollment form, and we do not share your consent to be contacted for marketing purposes with anyone.
  
  
• Whenever you partake in our recruitment efforts and or apply to Dompé U.S. for employment and or internships, we will collect any information you provide to us, including but not limited to, for instance, contact information, CV, and all other information you supply to us in the process.

1.2 Automatically

Whenever you visit or interact with the Websites we own or offer, we, as well as any of our third-party service providers, such as Google® Analytics, or other third parties which provide content, advertising or other functionality on the Websites may use a variety of technologies and tracking tools such as cookies* (i.e.: flash cookies, html5 cookies, Google Analytics cookies), web beacons, pixel tags, log files, local shared objects (flash cookies), HTML5 Cookies, or other technologies to automatically or passively collect, store, and combine certain information about you and or your online activity. 

Information collected automatically by the Websites and such third parties includes but is not limited to the following:

• Device Information, like your Internet Protocol (“IP”) address, MAC Address, mobile carrier, or other unique identifier or information from your computer, mobile device, tablet or other device that you use to access the Websites, as well as your browser type, device type, operating system, software version, phone model, and the domain name from which you accessed the Websites.
  
  
• Website usage information, such as the date, time you visit, areas or pages of the Websites you browse, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, other click-stream or site usage data, emails that you open, forward or click-through to our Websites, and or websites, platforms or applications owned Dompé U.S. affiliates.
  
  
• Location Information. We also collect general information about where traffic on our Websites is coming from around the world. This is used at an aggregate level that does not identify individual users to create reports to better understand our engagement with visitors to the Websites. Location information at an individual level may be used for narrowly tailored efforts for our products or research activities.

In sum, information we collect automatically helps us maintain the accuracy of the information we collect about you, improve the Websites and the Services, enables us to render our Services to you, target our communications so that we can inform you of products, services or other offers that you have identified or we determine may be of interest to you, and or for internal business analysis or other business purposes. We may also use the information collected to assess the effectiveness of such technologies, vs. newer third party technologies, which newer technologies we may also adopt from time to time.

*Cookies. Generally, cookies are small text files that are stored on users' computers or devices by websites they visit. Cookies may be used to make websites and devices work and operate more efficiently and to provide information to the website owners. The Websites use technical or functional cookies, Google Analytics Cookies and other third-Party Cookies. If you’d like to learn more about cookies generally and how they work, Google® provides a concise explanation on its privacy and terms page.
 

• Technical or Functional Cookies. These are installed by us, and can be divided into browser or session cookies, enabling a more seamless and personalized browsing experience and use of the Websites (for instance, they help define a browsing session or select the Website language or font size).
  
  
• GoogleAnalytics® Cookies. This is what Google® says about Google Analytics cookies as of the Effective Date of this Privacy Policy and it applies to the Websites: “Google Analytics uses a set of cookies to collect information on behalf of businesses which use the Google Analytics service and report site usage statistics to them without personally identifying individual visitors. ‘_ga’, the main cookie used by Google Analytics, enables the service to distinguish one visitor from another and lasts for 2 years. Any site that implements Google Analytics, including Google services, uses the ‘_ga’ cookie. Each ‘_ga’ cookie is unique to the specific property, so it cannot be used to track a given user or browser across unrelated websites. Google services also use ‘NID’ and ‘_Secure-ENID’ cookies on Google Search, and ‘VISITOR_INFO1_LIVE’ and ‘__Secure-YEC’ cookies on YouTube, for analytics. Google mobile apps may also use unique identifiers, such as the ‘Google Usage ID’, for analytics.”
  
  
• Third-Party-Cookies. Other parties may also have cookies installed throughout the Websites. With regard to these cookies, the Websites owner and editor may be unable to define the procedures and purposes of the operation of said cookies. For information on the third-party cookies in use, visit the websites of the third-party website suppliers.
  
  
• You accept or reject cookies by changing your browser security settings. Here are a few useful working links as of the Effective Date of this Privacy Policy:
• Chrome Browser Settings
• Firefox / Mozilla Browser Settings
• Microsoft Explorer Browser Settings
• Safari Apple Browser Settings
• Opera Browser Settings

1.3.  Information Collected from Other Sources

We also receive information about or from you via third-party log-in services or social networking sites you use to access our Websites, and or any of our Services. This information includes any information you have made public via your privacy settings, such as your name, location, gender, birth date, email, or contacts, and or other information you have agreed to disclose pursuant to such social media platforms. Information we receive from social media platforms allows us to verify information you have provided to us and to enhance our ability to provide you with information about our business, product(s), and Services, and or your experience on the Websites.

1.4. Notice Regarding Third-Party Websites, Social Media Platforms, Application Programming Interfaces and Software Development Kits.  

 The Websites, applications, or platforms may contain links to or from third party services, websites, applications, application programming interfaces (“APIs”), social media platforms, software development kits (“SDKs”) (“Third Party Sites”). We encourage our users to read the privacy policies of each Third-Party Site with which they interact carefully. Dompé U.S does not endorse, screen or approve, is not responsible for and specifically disclaims liability for the privacy practices or content of such Third-Party Sites. Visiting these other Third-Party Sites is at your own risk.

Our Websites, applications, platforms or Services may include publicly accessible Third Party Site blogs, forums, social media pages, and private messaging features.

By using such Third Party Site features you assume the risk that the personal information provided by you may be viewed and used by such Third Party Sites for any number of purposes over which Dompé U.S. exercises no control. In addition, social media buttons from Third Party Sites like Facebook®, Twitter®, and LinkedIn® (that might include widgets such as the “share this” button or other interactive mini-programs) may be integrated into our Websites, platforms or applications. These Third Party Site features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. These social media features may either be hosted by a Third Party Site or be hosted directly on our Websites, platforms, or applications. Your interactions with these features apart from your visit to our Websites, platforms, or applications are governed by the privacy policy of the Third Party Sites that offer such platforms, blogs, forums, social media pages, and or private messaging features, so we recommend that you read the privacy policies applicable to such Third Party Sites.

Our Services, Websites, platforms or applications may use APIs and SDKs which may allow third parties including analytics and advertising partners to collect certain information from you for various purposes over which Dompé U.S. exercises no control including but not limited to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us at: privacy@dompe.com.

1.5. Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Websites, platforms or applications, as well as information collected offline, from Third Party Sites and from third party sources.

2. OUR INFORMATION USE

2.1. Use by or for Dompé U.S.  

Dompé may use the information we collect from and about you for any of the following purposes:

• To render Services to you, verify your information, respond to your inquiries, contact and or communicate with you directly or indirectly through third parties when necessary or when you request that we do so;
  
  
• To review the usage and operations of our Websites and conduct analyses or research to develop, enhance, demonstrate, maintain the quality and safety of and or improve our or our parent company’s content, products, and Services;
  
  
• To advertise on the Websites, platforms or applications and or to tailor any promotional content or advertisement and send such advertisement directly to you via mail or email, or across Third Party Sites;
  
  
• To contact you, including directly or indirectly through third parties, by any means you have consented to or that are otherwise permissible, with information, newsletters from or about Dompé U.S. or the products it distributes on behalf of Dompé U.S.’ affiliates, and or to request information from you relating to your use of our products and Services;
  
  
• To use your data in an aggregated non-specific format for analytical and demographic purposes;
  
  
• To address problems with and to protect the security or integrity of the Website, our platforms, applications, and our business, including by debugging to identify and repair errors that impair existing intended functionality, and to defend and prosecute those responsible for any malicious, deceptive, fraudulent, or illegal activity;
  
  
• In connection with the DC2C patient program, after you sign our enrollment form, we use the health and contact information provided to contact you via email, landline, mobile or text for the purposes listed in the form. By providing your mobile number in the DC2C enrollment you consent to having us contact you via phone call or text messages with updates about your eligibility or prescription, subject to your text confirmation and our Dompé SMS Terms of Service. Once you have opted in or consented via a text message to have us contact you, we do not transfer your consent to receive text messages to anyone for marketing purposes.
  
  
• As of the Effective Date of this Privacy Policy, we use enrollment form information to contact you via email, landline, or mobile for the following purposes (which may change from time to time - please refer to your signed enrollment form):
  
  - To establish eligibility for DC2C and enroll you in our patient or product support programs
  
  - To communicate with HIPAA Covered Entities and you about your medical care and coverage.
  
  - To facilitate, assess, support or improve the provision of Dompé products, supplies, or services, including the Services provided by Dompé or by Dompe through a third party, including, but not limited to our access hub(s) or specialty pharmacy(ies).
  
  - To use and share your information to send you (or cause third parties to send you) communications and or information regarding your experience with access to and use of our products, Services, and or services such as instruction booklets, brochures, surveys and other market or clinical research invitations], as well as marketing communications, if applicable.
  
  - As otherwise required or permitted by law.
  
  
• For business related activities such as contact options, planning, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  
  
• We or our parent company may use personal information to create non-identifiable information to be used alone or in the aggregate together with information obtained from other sources to help us deliver existing products or Services or develop new ones or for public health, research, analytics.
  
  
• For any other purposes disclosed at the time you provide your information.
  
  
• For any purposes for which you have consented or directed us to use it.
  
  
• As otherwise required by law, for instance to comply with regulatory, pharmacovigilance or other legal requirements, including to investigate, track, and/or report on adverse events or effects resulting from your use of our product(s) or Services, and
  
  
• As otherwise permitted by law.

2.2. Interest-Based Advertising

We may use third parties to measure and target advertisements for us about our products and Services that are tailored to your online interests, this is commonly referred to as targeted or interest-based advertising. We allow these third-party companies to use Cookies, web beacons, pixel tags and similar technologies to track and collect certain data and other information about your online activity. This information is used to display advertisements for Dompé U.S. on the Websites, platforms or applications, and or across Third Party Sites that you visit. For information on your choices with respect to targeted or interest-based ads, see the “Interest Based Advertising Choices” paragraph of the Your Choices and Opt-Outs section below.

3. INFORMATION WE SHARE WITH OTHERS

Except as provided below, we will not disclose, sell, or rent any of your information to any third parties. We may share the information we collect from and about you with the following parties:

• Affiliates: We may share your information with Dompé U.S. affiliates and subsidiaries for business, operational, promotional and marketing purposes, Dompé farmaceuticiS.p.A., our parent company, in Italy may process the information for administrative, marketing, and organizational purposes as Data Controller (as defined under art. 4 of the EU General Data Protection Regulation n. 2016/679, as may be updated from time to time ("GDPR")), in order to coordinate and supervise the activity carried out by its subsidiaries, including Dompé U.S. and other Dompé farmaceutici S.p.A. subsidiaries. Dompé farmaceutici S.p.A. will act in compliance with the obligations set forth under the GDPR, and or any other laws applicable to it.
  
  
• Business Partners: Dompé U.S. may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. When we partner with another business, Dompé U.S. requires our business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which Dompé U.S. provided them.
  
  
• Service Providers: We may share your information with third party service providers that provide business, professional or IT and or other technical support functions to us, help us operate our business and the Websites, platforms or applications, and or provide analytics, customer service, support or administer activities on our behalf whether on our ours or their operating systems.
  
  
• Legal, Regulatory and Pharmacovigilance Requirements; Safety: We may access and disclose your information with government entities or agencies to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, regulatory and pharmacovigilance requirements, as permitted or otherwise required by law. We may need to give access to or disclose your information to protect the security of our Websites, applications, platform servers, network systems, and databases. We also may disclose your information as necessary, if we believe it is necessary to protect our legal rights, or the rights of any third party.
  
  
• Sale or Transfer of Business or Assets and or Joint Venture: If we are involved in a joint venture, merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Websites in a manner that is consistent with this Privacy Policy.
  
  
• Aggregate or De-Identified Non-Personal Information: We may also share aggregate, or de-identified non-personal information with third parties for their marketing or analytics uses.
  
  
• Advertising Partners, Internet Service, Data Analytics and Social Network Providers: Through our Services Websites, platforms, or applications, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from Third Party Sites) for purposes of delivering targeted advertisements to you when you visit Third Party Sites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected through our Websites, platforms, or applications to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions in the Your Choices and Opt-Outs section. In certain U.S. states, the sharing of the information in this section, including but not limited to identifiers, and or IP or network information with third parties like online advertising networks analytics provider and social networks, may be considered a sale, and you may have additional rights to set preferences and exercise a right to opt-out. See the “Additional U.S. State Privacy Disclosures” section to find out more.
  
  
• Other: We may also share your information as disclosed to you at the time of collection or disclosure, and or share it with third parties to whom you or your agents have authorized us or directed us to disclose it.

4. YOUR CHOICES AND OPT-OUTS

4.1. Cookies, Tracking Options and California Do Not Track Disclosures

Certain parts of our Websites require Cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline Cookies, but by doing so, you may not be able to use certain features of the Websites or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on controlling your tracking preferences and or see the targeted or Interest Based Advertising Choices section below. To find out more about declining, deleting or disabling Cookies please refer to the paragraph that outlines our use of Cookies under the Information Automatically Collected section of this Privacy Policy.

Our system may not recognize Do Not Track requests or headers from some or all browsers. We may use cookies or other Technologies to deliver advertising for our products when you visit other Third Party Sites.

4.2. Interest-Based Advertising Choices

To understand your choices for receiving more relevant advertising provided on Third Party Sites and online services, please review the information below:

• To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info. 
  
  
• To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit http://optout.networkadvertising.org.
• If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available https://tools.google.com/dlpage/gaoptout/.

On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising Please note you must separately opt out in each browser and on each device. Even if you opt out, you still may receive advertising from us that is not customized based on your service or usage information, or advertising from other third parties if they are not a DAA or NAI participating company.

4.3. Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide: 

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as you mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

• Google Analytics: Google Analytics allows us to better understand how our customers interact with our services.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager.

4.4. Unsubscribing from our Marketing Communications

We provide our Websites visitors with the opportunity to update their information or opt out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your request. To opt out of marketing communications, you may:

• Send us an e-mail to: privacy@dompe.com 
  
  
• Contact us by mail at the address below in the “How to Contact Us” section or
  
  
• Unsubscribe from our email communications at any time by selecting unsubscribe in the email you received.

If you receive marketing communications from one or more Dompé U.S. affiliates, you must opt-out individually from each specific mailing list by following the instructions in the email communication and or by sending an email to privacy@dompe.com.

When applicable, GDPR gives certain individuals privacy rights which include: the right to request access to your information at any time, the right to request correction of your information; the right to object to processing of your information, the right to restrict processing of your information and to request erasure; the right to request transferring some of your information to other organizations. If GDPR applies to our collection of your information you may be able to exercise your privacy rights; to do so, please contact us as set forth in “How to Contact Us” section below.

5. CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not direct the Website to, nor do we knowingly collect any personal information from, children under the age of eighteen (or other age as required by local law). If you learn that your child has provided us with personal information without your consent, you may contact the Dompé U.S. Privacy Officer as set forth above. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information unless we have a legal obligation to maintain it and will terminate the child’s account.

6. DATA RETENTION AND SECURITY

We store the information we receive as described in this Privacy Policy for at least as long as as necessary to fulfill the purpose(s) for which it was collected and or as otherwise required to comply with applicable laws.

We have taken certain physical, administrative, and technical steps to safeguard the information we collect and store. To find out more about our security specifications, please write to us at: privacy@dompe.com.

While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

[Area di testo]By providing personal information, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Websites, applications, platforms, and Services. If we learn of a security system’s breach, we will notify you, as required to comply with applicable law.

7. INTERNATIONAL TRANSFER

The information we collect from you may be stored on servers in the European Union and or the United States depending on the purpose for which it was collected; however, some of our brands, subsidiaries, parent company, and service providers with which we may share you information, as disclosed in this Privacy Policy, may store information on servers hosted in other countries. As such, your personal information may be subject to the laws of other countries, where privacy or data protection and other laws may differ from those of the European Union and or the United States. Your information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

8. REVISIONS TO THIS PRIVACY POLICY

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post an updated Privacy Policy on the Websites, applications, platforms or Services. Your continued use of the Websites, applications, platforms or Services following the posting of changes to this Privacy Policy will indicate that you accept these changes. If we change the Privacy Policy in a way that materially affects your rights, we will notify you as required by applicable law.

9. HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described, you may contact us at privacy@dompe.com or by mail to:

Dompé U.S. Inc.
Attn: Privacy Officer  
400 S. El Camino Real, Ste. 400   
San Mateo, CA 94402

And or

Dompé farmaceutici S.p.A.
Attn: Privacy Officer
Via San Martino 12/12a, Milan
20122 Milano, Italy

10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES

Nevada Residents: If you are a resident of the state of Nevada in the United States, please note Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@dompe.com with the subject line “Nevada Opt-Out.”

California, Connecticut, and Texas Residents: For the residents of the States of California, Connecticut, and Texas, these Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our Services, please read our Privacy Policy.

For the purposes of these U.S. Disclosures, personal information does not include publicly available information or de-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

We collect personal information from and about individuals for a variety of purposes. To learn more about the types of personal data we collect, the sources from which we collect or receive personal information, and the purposes for which we use or share this information please refer to the “Information We Collect”, “Our Information Use”, and the Information We Share With Others sections of our Privacy Policy.

Sensitive Information

Some of the categories of personal information elements we collect may be classified as “sensitive” under applicable U.S. state privacy laws (“sensitive information”), including racial or ethnic origin, citizenship or immigration status, health information, government identification numbers (such as social security number, driver’s license number, state ID card number, or passport number), account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, the contents of a consumer’s mail, email, or text message, information concerning sex life or sexual orientation. 

We use this information for the purposes set forth in the “Our Information Use” section of our Privacy Policy. We do not sell sensitive personal information, and we do not process or otherwise share sensitive personal information for the purpose of targeted advertising. However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive personal data (as described in the “Your Privacy Rights” section below).

De-identified Information

We may receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Your Privacy Rights

Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations of law):

• The Right to Know: The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including:
  
  
• The categories of personal information collected;
  
  
• The categories of sources of the personal information;
  
  
• The purposes for which the personal information was collected;
  
  
• The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
  
  
• The categories of personal information shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
  
  
• The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
  
  
• The Right to Access and Portability: The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  
  
• The Right to Request Deletion: The right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
  
  
• The Right to Correction: The right to request that any inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
  
  
• The Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal information for certain targeted advertising purposes.
  
  
• The Right to Control Over Sensitive Personal Information: You have the right to exercise control over our collection and processing of certain sensitive personal information.
  
  
• The Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes.
  
  
• Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties, including the right to opt-out of the disclosure of personal data to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.
  
  
• Right to Deletion: The right to have us delete personal data we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party).

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by either:

• Filling out our Individual Rights Request Form and emailing it to us at:
  
  privacy@dompe.com and with a copy to: dpo@dompe.com with the subject line: “Consumer Rights Request”
  
  
• Calling our toll-free number at: 1 (800) 868-2185.

When you make a request, we will make reasonable efforts to respond promptly to your requests in accordance with applicable law. We may ask you to provide information to verify your identity, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means, if needed, to verify your identity. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems and or if, for instance, we are prevented from doing so by applicable law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Exercise Your Right to Opt-Out of Sales or Targeted Advertising

Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information with third parties for cross-context behavioral advertising purposes and as further described in the Interest-Based Advertising paragraph of the Our Information Use section or the Our Information We Share With Others section of this Privacy Policy. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.

We may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

To exercise the right to opt-out of sales or targeted advertising see the Your Choices and Opt-Outs section, and or you may do the following:

• Cookies-based Opt-Out (Do Not Sell or Share My Personal Information). To exercise your right to opt-out as it relates to the use of Cookies and other tracking technologies for analytics and interest-based advertising or targeted ads, please see the Interest Based Advertising Choices paragraph above and or refer to and use the specific opt out associated to the browser you are using. You must reset your preferences if you clear Cookies or use a different browser or device. The paragraph that addresses Cookies within the Information Automatically Collected section above includes links to opt out of Cookies within the most commonly used browsers.
  
  
• Opt-Out of “Selling” of Personal Information. In limited circumstances we may share your personal information (such as your name, e-mail address, postal address, and phone number) with third parties who may use such information for their own commercial or business purposes. In certain states, this may be considered a sale. To opt out of such sharing, please fill out our Individual Rights Request Form.

Authorized Agents

In certain circumstances, you are permitted to use an authorized person or corporate entity to act as your agent (as that term is defined by the applicable state privacy law) to exercise your rights and submit requests on your behalf. Agents acting on your behalf to exercise your rights should follow the instructions in this Privacy Policy and in this section. When we receive an agent request we must verify that the request is valid and intentional (e.g. that it comes from you) so we may seek to verify your identity with you or the agent, and we will also verify the agent’s identity and its authority to act on your behalf. To the extent that we are unable to verify the identity of the agent acting on your behalf, we may request additional information before we process a request.

For requests to know, delete, or correct personal information, we require that you submit an Individual Rights Request Form together with one of the following to help us verify the agent’s identity:

• a power of attorney valid under the applicable state law authorizing your agent to act on your behalf for the purposes you elect; or
  
  
• sufficient evidence to show that you have:
  
  
• provided the authorized agent signed permission to act on your behalf; and
  
  
• verified your own identity directly with us:
  
  
• pursuant to the instructions set forth in these U.S. Disclosures; or that
  
  
• You have directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales” or “sharing”, we require signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the Individual Rights Request Form.

California-Specific Privacy Disclosures

This section of the notice applies solely to residents of the State of California.

California Categories of Personal Data

California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in the Information We Collect section of our Privacy Policy below:

• Identifiers, such as, include first and last name, zip code, email, telephone number, home or business address, home or business phone and fax number.
  
  
• Protected classification characteristics, such as, age, gender, race, disability and pregnancy information.
  
  
• Commercial information, such as banking information and records of previous services.
  
  
• Internet / network information, such as, computer or device information and usage information (as defined in “Information Automatically Collected” in our Privacy Policy.
  
  
• Geolocation data, such as, general information about where traffic on our Websites is coming from around the world.
  
  
• Professional / employment information, such as, medical specialization, email address, professional qualifications sometimes in the form of curriculum vitaes (“CVs”), license numbers and scientific society membership numbers, institution or employer name, practice name, professional qualifications, license number.
  
  
• Sensitive personal data, such as, driver’s license, passport number, tax identification number, and health information related to your medications, medical history medical insurance details, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history. Please see our Consumer Health Data Privacy Policy for additional information.
  
  
• Other personal data, such as, certain personal information to comply with regulatory and pharmacovigilance requirements, including information relating to any adverse effects you may have experienced when using our products.

Personal Information Collection

We collect the personal information described in the Information We Collect section of this Privacy Policy for the purposes described in Our Information Use section of this Privacy Policy. The personal information we collect may be information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Sources of Personal Information

We obtain personal information as described in detail in the Information We Collect section of this Privacy Policy.

Use of Personal Information

We may use the personal information we collect as described in Our Information Use section and may disclose it as described in the Information We Share with Others section.

Disclosure of Personal Information

We disclose your personal data for a business purpose, as set forth in the Information We Share with Others section above.

Sales of Personal Information and Sharing for Targeted Advertising

We have sold the following categories of personal information to third parties, subject to your settings and preferences and your right to opt-out:

• Identifiers
  
  
• IP, Internet / network information

The categories of third parties with whom we may sell or share such personal information include:

• Online advertising networks and analytics providers
  
  
• Social networks

Minors

We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at 1 (800) 868-2185 or at privacy@dompe.com to inform us if you, or your minor child, are under the age of 16.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacy@dompe.com or call us at 1 (800) 868-2185. We may not be able to modify or delete your information in all circumstances. 

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).