Privacy Policy
Last Updated: January 13th, 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. Click here to download a copy of this Privacy Policy 1. INFORMATION WE COLLECT1.1. Information You Provide to Us Directly1.2. Information Collected Automatically1.3. Information Collected from Other Sources1.4. Notice Regarding Third-Party Websites, Social Media Platforms and SoftwareDevelopment Kits.1.5. Combination of Information2. OUR INFORMATION USE2.1. Use By or For Dompé2.2. Interest-Based Advertising3. INFORMATION WE SHARE WITH OTHERS4. YOUR CHOICES AND OPT-OUTS4.1. Cookies, Tracking Options, and California Do Not Track Disclosures4.2. Interest-Based Advertising Choices4.3. Partner-Specific Preferences4.4. Unsubscribing from Our Marketing Communications4.5. Updating Your Information4.6. Your GDPR Rights 5. CHILDREN'S PRIVACY6. DATA RETENTION AND SECURITY7. INTERNATIONAL TRANSFER8. REVISIONS TO THIS PRIVACY POLICY9. HOW TO CONTACT US10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES1. INFORMATION WE COLLECTThe 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 DirectlyWhen 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. For instance:
400 S. El Camino Real, Ste. 400
San Mateo, CA 94402And or Dompé farmaceutici S.p.A.Attn: Privacy OfficerVia San Martino 12/12a, Milan20122 Milano, Italy10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURESNevada 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.Collection and Use of Personal InformationWe 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 InformationSome 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 InformationWe 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 RightsDepending 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):
- 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 and 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 elect to be enrolled in Dompé U.S.’ patient support program Dompé CONNECT to Care (“DC2C”) you consent to provide 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 your personal, demographic, contact, health and treatment information with Dompé U.S. and or certain third parties working with or for Dompé U.S. to provide you the 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.
- 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.
- 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.
- 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:
- 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, provided that you have signed our enrollment form we will receive the information contained in the enrollment form that you or your physician will fill out, and will use it only for the purposes listed in the form which are as follows as of the Effective Date of this Privacy Policy, but which may change from time to time (please refer to your signed enrollment form for the most up to date listing of purposes):
- 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.
- Affiliates: We may share your information with Dompé U.S. affiliates and subsidiaries for business, operational, promotional and marketing purposes, Dompé farmaceutici S.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.
- 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.
- 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, currently available at https://www.adssettings.google.com/anonymous?ref=ps-tech&hl=en.
400 S. El Camino Real, Ste. 400
San Mateo, CA 94402And or Dompé farmaceutici S.p.A.Attn: Privacy OfficerVia San Martino 12/12a, Milan20122 Milano, Italy10. ADDITIONAL U.S. STATE PRIVACY DISCLOSURESNevada 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.Collection and Use of Personal InformationWe 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 InformationSome 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 InformationWe 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 RightsDepending 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 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).
- Filling out our Individual Rights Request Form and emailing it to us at:
- Calling our toll-free number at: 1 (800) 868-2185.
- 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.
- 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:
- 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.
- 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.
- Identifiers
- IP, Internet / network information
- Online advertising networks and analytics providers
- Social networks