Amneal Privacy Statement
Amneal Pharmaceuticals, Inc. and its subsidiaries (hereafter “Amneal”, “us” or “we”) may collect personal information in order to serve you, communicate with you, operate our business and comply with regulatory requirements. We recognize and respect the privacy rights of individuals with regard to personal information.
This Privacy Statement explains how Amneal collects, uses and discloses your personal information and other information; what data protection rights you may have, including a right to object to certain uses of personal information; and answers questions that you may have regarding privacy and security.
If you have additional questions, please contact us at firstname.lastname@example.org.
1. Types of Personal Information We Collect
This Privacy Statement explains our practices with regard to “Personal Information and other information we collect online or through e-mail.” Personal Information is any information that can be related to you, as an identified or identifiable individual.
The categories of Personal Information that we collect include:
- Contact Information that allows us to communicate with you, such as your name, mailing address, email address, or phone numbers.
- Content of communications you send to us or we send to you.
- Relationship Information that helps us understand your interests, including information about products, treatments, and health conditions that are of interest to you.
- Transaction Information about how you interact with Amneal, including purchases, inquiries, and information about how you use the Amneal websites and applications.
- Financial Account Information, such as your credit card number or Social Security number, as needed to process payments and provide reimbursement services.
- Geo-location Information, as may be transmitted to us by your smart phone or other location-aware devices.
- Your preferences, e.g. in relation to communications you do or do not wish to receive from us.
- Job Applicant Information, to process your job application, such as your contact information, resume, previous work experience, education, transcript, driver’s license information, Social Security number or national identification number and information relating to references.
- Contents of “cookies” and other technical data relating to your device and your use of our website(s) or mobile apps.
2. How Amneal Collects Information
In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our websites, using any interactive features or applications, signing up to receive a newsletter or a rebate, making a direct purchase, or applying for employment. We may collect additional information from third party data suppliers who enhance our files or from social media websites such as Facebook or LinkedIn, if you like our pages or join our communities.
We will aim to mark data fields as optional or mandatory when collecting Personal Information from you via forms. Note, in particular, that to create an account, engage in transactions, and where necessary, prove your identity, the provision of Personal Information is typically mandatory: if relevant data is not provided, then we will not be able to do these things and provide the services you expect.
When you use our mobile applications, we may collect geo-location Information about the location of your mobile device. You may be able to manage your Location Services preferences through the settings of your mobile device.
We may receive Personal Information about you from people related to you or that treat you; for example, if you are a patient that has suffered a suspected adverse reaction to an Amneal product, your physician may tell us about that event, although typically they would do so without naming you or including any other direct identifiers in their correspondence with us.
Amneal has in place a number of internal policies which govern the use of Personal Information and place requirements on vendors and third-parties who process Personal Information collected by Amneal.
3. How Amneal Uses Personal Information
Amneal may use your Personal Information for its business purposes (or otherwise in Amneal’s or a third party’s overriding legitimate interests), such as:
- To respond to your requests for information, products, services, including managing your online accounts with us and providing warranty service for certain products;
- To provide you with general health information (such as information on certain health conditions) as well as information about our products and services;
- To provide you with marketing communications and offers for products and services;
- To administer promotional programs, such as sweepstakes, rewards, and rebate programs;
- To determine if you are eligible for certain products, services, or programs;
- If you have a business or professional relationship with Amneal, to develop our business relationship with you;
- If you apply for a job via our career center, to consider you for employment;
- For our research and development efforts;
- To anonymize data so that it is no longer Personal Information;
- To detect, prevent, or respond to intellectual property infringement, violations of our Terms and Conditions and violations of law, to protect our rights or those of our users or customers, or to detect, prevent or respond to fraud or other misuse of our websites, apps or services;
- In connection with mergers, acquisitions or other corporate transactions; and
- For other everyday business purposes, such as:
- payment processing and financial account management;
- product development, including the improvement of our website and the services we provide, such as by better tailoring our content to our users’ needs, interests, and preferences.
You can contact us to request information about balancing-of-interest tests we conducted, if any, in respect of activities described above.
Amneal may also use your Personal Information:
- to enter into and perform contracts with you;
- where you give us consent, for purposes specified at the time that consent is gathered; and
- in the public interest and/or for legal compliance, such as ensuring product safety (e.g. adverse event reporting, or to communicate product safety information to you).
Where required by law, we will inform you if we use your Personal Information for automated decision-making that significantly affects you.
4. Why Personal Information Is Disclosed by Amneal
We may share your Personal Information between Amneal group companies and staff, so they can help deliver and improve our services, run our business, and comply with our legal obligations and related third party requests. We may also share your Personal Information with third-parties with whom we have contracted for recruitment, clinical trials and other services that require the use of Personal Information. To the extent possible, Personal Information will be encrypted before being shared.
Except as disclosed in this Privacy Statement or other communications with you, Amneal does not sell, share, or otherwise distribute your Personal Information to unaffiliated third-parties for their own marketing purposes. We may share your Personal Information as follows:
- We may share your Personal Information with your consent or as you direct. For example, we may share information with your doctor as part of programs in which you agree to participate.
- We may share your Personal Information with our affiliated companies and product co-promotion partners, which may only use your Personal Information for the purposes listed herein.
- We may share your Personal Information with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions. For example, we may share your Personal Information with vendors who provide data processing or fulfillment services for us.
- We may also disclose Personal Information as appropriate to effect the sale or transfer of business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property, or safety of others, or as needed to support external auditing, compliance, including government reporting obligations, and corporate governance functions.
- We may also disclose Personal Information when requested under legal process, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
- We may also disclose Personal Information when we believe in good faith that disclosure is necessary to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms and Conditions, violations of law, or other misuse of our website or services;
- Please note that we may also disclose information that is not personally identifiable. For example, we may publish reports that contain aggregated and statistical data about our customers. These reports typically aggregate data from multiple individuals and do not contain Personal Information.
5. Disclosure to Subsequent Owner or Operator
If all or part of Amneal or its assets is sold or merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to ensure that information that is transferred will be used or shared in a manner consistent with this Privacy Statement unless we obtain your consent. However, in the event of a sale or merger, your continued use of this website signifies your consent to be bound by the privacy statement and other applicable terms of the subsequent owner or operator (to the extent allowed under applicable law).
6. Processing in the United States and Elsewhere
This website is owned and operated by Amneal in the United States, but the information you provide may be provided or made accessible to our affiliates, vendors, and suppliers in other countries for our legitimate business activities. Furthermore, if you are visiting this website from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries and may not be the same in the United States as your home country. By using this website, to the extent allowed under applicable law, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.
Where Personal Information is transferred out of EEA countries, to countries or international organizations whose privacy and data protection rules have not been deemed “adequate” by the European Commission or other relevant authority, that Personal Information will instead be protected by our use of officially-approved standard contractual clauses or a vendor’s Processor “Binding Corporate Rules”, except in limited, legally-permitted circumstances (for instance, lawful one-off transfers to organizations that do not offer those safeguards). More details are available on request, using the contact details set out below.
7. Cookies and Other Data Collection Technologies
When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons.
For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud.
Amneal uses Flash Cookies (also known as Local Stored Objects), Microsoft Silverlight and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. Flash cookies (and similar applications) use technology to remember settings, preferences, and usage similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please see Adobe’s website at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html or visit www.adobe.com. To manage Silverlight cookies, see Microsoft’s privacy statement at http://www.microsoft.com/en-us/privacystement or visit www.microsoft.com. For management of cookies, see section 11, “Your Choices”, below.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website our online service, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Amneal and the website you visit after you leave our website.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.
In some cases, we do associate the information we collect using cookies and other technology with your Personal Information.
This Privacy Statement governs how we use this information when it is itself Personal Information, or when we associate it with your Personal Information.
Amneal has relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third-party advertising companies may place cookies on your computer when you visit our website or other websites so that they can track your activity over time and across websites and online services to display targeted advertisements to you. These vendors have their own privacy notices. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org.
8. Social Media Plugins
This website may use social media plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our website, app or other online service, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our website or app. If you are logged into the social media service (e.g., Facebook, Twitter) while browsing on our website, app or other online service, the social plugins allow that social media service to share information about your activities on our website, app or other online service with other users of their social media service. For example, Facebook Social Plugins allow Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website or app. Amneal does not control any of the content from the social media plugins. For more information about social plugins from other social media services you should refer to those websites’ privacy and data sharing statements.
9. Do-Not Track Signals and Similar Mechanisms
Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Websites linking to this Privacy Statement do not currently respond to these “do-not-track” signals.
10. Tell-A-Friend Functions
Amneal offers “tell-a-friend” functionality on some of our websites. If you choose to use this function, we will collect Contact Information for your friend. We will automatically send your friend a one-time email with the information you specified or inviting him or her to visit the website. Amneal uses this information for the sole purpose of sending this one-time email and does not retain the information.
11. Your Choices
Wherever we rely on your consent, you can withdraw that consent at any time, although we may have other legal grounds for processing your Personal Information for other purposes (e.g., compliance with the law).
Depending on applicable law, you may also have a right to raise objections to our uses of Personal Information, in particular to direct marketing-related uses of your Personal Information, and to other uses that we identified in Section 3 above as being in our or a third party’s “legitimate interest”.
For direct marketing communications:
- You can limit the promotional communications that Amneal sends to you by following a simple opt-out process. Simply follow the instructions in our emails to opt-out of receiving future marketing communications.
- Please note that even if you opt out of promotional emails, we may still need to contact you with important transactional information about your account. For example, even if you opt out of emails, we will still send you a confirmation when you purchase something from our website as well as product safety communications.
For cookies and related technologies:
- You can manage cookie preferences and opt out of having cookies and other data collection technologies used by adjusting the settings on your web browser. All browsers are different, so visit the help section of your browser to learn about cookie preferences and other privacy settings that may be available.
- You can opt out of being targeted by those third party advertising companies that are NAI members online at www.networkadvertising.org/consumer/opt_out.asp.
Depending on applicable law (in particular, whether the laws of the EEA countries apply), you may also have the right to ask us for access to your Personal Information and further details about its processing; to correct or delete that Personal Information or to restrict its processing; and to obtain a copy of Personal Information about you that you provided to us for a contract (in connection with our agreement with you, or with your consent), in a structured, machine readable format, and to ask us to port this data to (i.e. share that data with) another organization.
If the rights described in this section apply, they may however be limited, for example if fulfilling your request would reveal Personal Information about another person, would infringe the rights of another person or legal entity (including our rights), or if it would delete or change records which we are required by law to keep intact (or where we have other compelling legitimate interests in keeping such records).
You can inquire about your rights and make a request at any time by contacting us (see “How to Contact Us” below). Amendment / deletion of certain Personal Information may be possible by logging into your online account, should you have one.
If you have unresolved concerns, you likely have the right to complain to regulators, depending on applicable law. For example, in the EEA, your complaint can normally be taken to data protection authorities where you live, work or where you believe a breach may have occurred.
12. Data storage periods
We maintain records, including Personal Information, in accordance with the Amneal Record Retention Policy, which is subject to change in accordance with the law. Where we process Personal Information in connection with entering into or performing an agreement with you, or providing services to you, we keep the data for a minimum of 7-10 years from your last interaction with us, depending upon the record type; except in the case of clinical trials or specific products where the information is maintained in accordance with the law.
Where we process Personal Information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of that request indefinitely, so that we can continue to respect your request in future.
Where we process Personal Information for website security purposes, we retain it for 3 years.
Longer retention periods may apply in specific circumstances, such as where ongoing access to records continues to be important to our defense of legal claims or where we are required by law to retain information for specific periods (such as details of suspected adverse reactions or other product safety issues).
13. Information Security
Amneal has implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard your Personal Information from unauthorized use, modification and disclosure. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to our website through means that we do not control, including the Internet and wireless networks, and postal services.
14. Privacy Policies of Third Parties
This Privacy Statement only addresses the use and disclosure of information by Amneal. We may provide links to outside websites or advertisements for third parties that have their own privacy policies and data collection, use, and disclosure practices. Our independent dealers, suppliers, and business partners have their own privacy statements too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion. To the extent permissible under applicable law, by accessing our online services such as our website(s) or mobile apps that link to this policy, you acknowledge and agree that we are not responsible for the collection and use of your information by such third parties that are not under our control.
15. Children’s Privacy
The Amneal website and applications are not intended to attract children, and we do not knowingly collect any Personal Information of anyone under the age of 13 (except in rare cases such as product safety reports). If you believe your child is using our website, please contact us (see “How to Contact Us” below) so we can investigate and delete any such information.
16. Forums, Product Reviews, and Other Public Areas
Our websites may contain forums and other areas where you can publicly post product reviews, communicate with others, and submit media content. All the information you post will be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your email address along with a product review, you may receive unsolicited messages. Please use caution when posting any Personal Information.
17. Changes to this Privacy Statement
We will only use Personal Information in the manner described by the Privacy Statement in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Statement at any time by posting revisions to our website. If we make any material changes to this Privacy Statement, we will either notify you or place a prominent notice on our website.
18. Job Applicants
If you have applied for employment with Amneal, the Personal Information submitted with your job application will be used to process and consider your job application. Amneal will not sell the information on your application to unaffiliated third parties for their marketing purposes. We may share the information on your applications with recruiters, consultants, attorneys, background services, and our affiliates. The information on your application may also be used for certain regulatory, compliance, and legal purposes, consistent with this Privacy Statement.
To the extent the Personal Information you provide contains details of your: racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health condition; sexual life; commission (or alleged commission) of an offence or related proceedings; job evaluations or educational records; you expressly authorize Amneal to handle such details for the purposes of your job application and for the other purposes described herein.
By submitting information to us online, you are sending it to the United States, where it will be subject to the protections afforded under U.S. laws that may be different from the laws in your country and which your country may consider not to provide adequate privacy protections. If you do not agree that your submission of your application information will be governed solely by United States law, Amneal will not accept your application.
19. California Privacy Rights
California Civil Code Section 1798.83 permits California residents who are customers of Amneal to request information once per calendar year regarding our disclosures of certain categories of your personally identifiable information to third parties for their direct marketing purposes. To make such a request, please email us at email@example.com, or write to:
Amneal Pharmaceuticals LLC
Attention: Legal Department
400 Crossing Boulevard, 3rd Floor
Bridgewater, NJ 08807 USA
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.
20. Social Security Number Protection Policy
Amneal collects Social Security numbers and other sensitive Personal Information in the ordinary course of its business. Amneal has implemented reasonable technical, physical, and administrative safeguards to help protect the Social Security numbers and other sensitive Personal Information from unlawful use and unauthorized disclosure. All Amneal workers are required to follow these established procedures, both online and offline. In particular:
- Access to Social Security numbers is limited to those workers and service providers who have a need to access the information to perform tasks for Amneal. Social Security numbers are only disclosed to third parties in accordance with Amneal’s established Privacy Statement.
- We will only disclose Social Security numbers (i) to those service providers, auditors, advisors, and/or successors in interest who are legally or contractually obligated to protect them, or (ii) as required or permitted by law.
21. How to Contact Us
If you have any questions, complaints or requests, you can email us at firstname.lastname@example.org.
You can also reach us via mail at the address below. If you send us a letter, please provide your name, address and email address.
Amneal Pharmaceuticals LLC
Attention: Legal Department
400 Crossing Boulevard, 3rd Floor
Bridgewater, NJ 08807 USA
22. Other Terms
Your use of this website is subject to additional terms set forth in the Legal Notices section of our website.
Effective Date: August 22, 2019