Privacy Policy
Effective Date: October 8, 2024
Acadia Pharmaceuticals Inc., along with our affiliates, entities, and subsidiaries, including Acadia Pharmaceuticals (Canada) Inc., (collectively: “Acadia”, “we”, or “us”) is committed to protecting and respecting your privacy, and we value your trust that we will protect your information. This Privacy Policy describes how we use, disclose, share, protect or otherwise process your Personal Information (as defined below). This Privacy Policy describes how we use, disclose, protect or otherwise process your Personal Information (as defined below). This Privacy Policy is incorporated into and made a part of our Terms of Use.
This Privacy Policy applies to the Personal Information we obtain through your use of our websites, mobile applications and any other website that links to this Privacy Policy (collectively, the “Site”); your interaction with us offline (e.g. at a convention or event); or other interactions you have with us.
This Privacy Policy contains information about your privacy rights and how you can exercise them. We encourage you to review this Privacy Policy and click on the available links below if you want additional information on a particular topic. Please read this Privacy Policy carefully to understand how we may process your Personal Information. If you do not agree with the terms of this Privacy Policy, please do not use the Site or otherwise provide any Personal Information to us.
- What type of Personal Information do we collect?
- How do we obtain your Personal Information?
- What are the legal bases for collecting and processing your Personal Information?
- How do we use your Personal Information?
- How will we share your Personal Information?
- How can you request access, amendment, or deletion of your Personal Information?
- Your Marketing Choices
- Additional Technical Information
- Security
- Retention of Personal Information
- Children’s Privacy
- International Transfer of Personal Information
- Third Party Website and Services
- Additional Information for Individuals in the European Economic Area, Switzerland, the United Kingdom, and Serbia
- Additional Information for Canadian Residents
- Additional Information for California Residents
- Changes to Privacy Policy
- Contact Us
- Consumer Health Data Privacy Policy
- Supplement to Consumer Health Data Privacy Policy for Nevada Consumers
1. What type of Personal Information do we collect?
“Personal Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location, or factors specific to physical, physiological, genetic, economic, cultural or social identity. We may collect and process the following Personal Information about you:
- Contact information, such as your name, email address, phone number, address, company affiliation, or job title;
- Access information, such as your log-in username and password details;
- Online and technical identifiers, such as your IP (Internet Protocol) address and cookies; for more information, please see our Cookie Policy
- Professional credentials, such as curriculum vitae/resume, work history, qualifications or any other type of information that may be included on a resume or curriculum vitae;
- Demographic information, such as age, date of birth, and gender;
- Medical information;
- Communication and correspondence information, such as the content of communications you send us to report a problem or to submit a query, or your response to a survey for market research purposes;
- Information related to transactions you engage in with us;
- Financial and government identifying numbers, such as social security numbers;
- Voice and image recordings; and
- Any other information that you provide to us that can be used to identify you.
2. How do we obtain your Personal Information?
We collect Personal Information from a number of sources, including:
- Directly from you, such as when you enquire about our products and services, contact us via the Site, apply for employment, ask to be a research study participant or a principal investigator in one of our trials, or in any way engage with us or our personnel;
- Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links in our emails;
- Through the use of social media platforms, such that if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
- Third party vendors, which may include those vendors, suppliers, contractors or business partners that provide services for us (e.g. market research vendors);
- Adverse event reporting reporters or subjects;
- Government officials; and
- Publicly available sources.
3. What are the legal bases for collecting and processing your Personal Information?
In certain jurisdictions, we are required to have a legal basis in order to process your Personal Information. The legal basis that applies will depend on your relationship to us and the nature of our processing activity:
- We may collect and use your Personal Information with your consent for the specific purpose identified in a notice given to you at the point of data collection.
- We may process your Personal Information or in order to manage or fulfill our contractual relationships. For example, in some circumstances, processing of your Personal Information is necessary to fulfil our or your (at your request) obligation in a commercial, employment or service contract.
- We may process your Personal Information for our legitimate business interest. Where we rely on legitimate interests, we have conducted legitimate interest assessments to ensure that our interests and yours are balanced.
- We may need to collect and process your Personal Information to comply with our legal obligations.
We are committed to collecting and processing your Personal Information in a lawful and transparent manner. For further details on the legal bases Acadia assigns for particular data collection and use in jurisdictions where we are required to have a legal basis to process your Personal Information, please reference the below table.
Please note that this section only applies to residents of jurisdictions where we are required to have a legal basis to process individuals’ Personal Information. It does not apply to residents of other jurisdictions, such as the U.S.
Use of your Personal Information
| Use of your Personal Information | Categories of Personal Information We Process | Source of the Personal Information | Legal Basis |
|---|---|---|---|
| Disclosure for the provision of products or services | Contact information | You | Contract: To allow for the secure transfer and processing of personal data |
| Reviewing requests to participate in research studies and screening eligibility for enrollment | Contact information, research study participant qualification information, and other information relevant to your eligibility and qualifications to participate in research studies sponsored or conducted by Acadia | You and your health care provider | Legitimate interest: To ensure research subjects are eligible and appropriate for the studies we sponsor or conduct |
| Respond to inquiries and fulfill requests | Contact information and other information you provide, such as your requests | You | Legitimate interests: To provide you with information you need and other services you request and to efficiently communicate with you |
| Register you for events and deliver event-related materials | Contact information and other information you provide, such as your preferences for the event | You | Legitimate interests: To enable your attendance at our events and to deliver you event materials Contract: As may be described on the registration page for the event |
| Recruiting personnel for employment | Contact information, recruitment information, and other information relevant to potential recruitment by Acadia | You, your references, your former employers | Pre-contractual Measures: To recruit and evaluate potential candidates to join Acadia Legal obligations: To comply with applicable legal obligations, including for employment law purposes Legitimate interest: To make the best recruitment decisions for Acadia |
| Perform website analytics | Technical information and other information we collect, such as demographics, behavior tracking, and event tracking | First and third party analytics cookies | Consent: To understand more about our Site visitors (what pages you view, how long you visit, your devices, etc.) in order to improve our site |
| Obtain your subscription preferences and send marketing communications, surveys, questionnaires, or event related materials | Contact information and other information you provide, such as your topic preferences and areas of interest | You | Consent: To provide you with marketing communications, surveys, questionnaires, information you need and services you request and to efficiently communicate with you |
| Conduct surveys and questionnaires | Contact information and other information you provide, such as your survey answers | You | Consent: To evaluate and take action with regard to your feedback and comments about Acadia |
4. How do we use your Personal Information?
Subject to applicable privacy laws, the Personal Information we collect from you may be used for the following business purposes:
- to perform or enter into a contract;
- to comply with applicable laws, regulations, codes, court order or other legal obligations (e.g., pharmacovigilance obligations, financial disclosure requirements);
- to send communications (including documents and electronic messages or alerts) regarding our products and services and related materials;
- to respond to and fulfill inquiries and requests;
- to provide our products or services offered through the Site;
- to perform website analytics and understand usage trends to personalize your access to the Site;
- to recruit study participants;
- to identify and authenticate you;
- to conduct research and development activities for our products and services;
- to conduct market research relating to our products and services;
- to provide patients assistance;
- fraud and security monitoring;
- to enforce these privacy principles and to protect our rights or property; or
- for any other administration of legal and/or business processes that are in Acadia’s legitimate interest unless such use is prejudicial to your rights or your liberties.
We may also aggregate or de-identify your Personal Information so that it can no longer be used to identify you. This aggregated or de-identified information may be used for any purpose permitted by law and is no longer subject to this Privacy Policy.
5. How will we disclose your Personal Information?
We disclose Personal Information within Acadia, at your direction, as disclosed to you at the time of collection, or in the following contexts:
Service Providers
We disclose Personal Information to our service providers that help us run and manage our organization and process personal information solely on our behalf. The categories of service providers to which we disclose personal information may include delivery services, program enrollment and benefits verification providers, marketing and data analytics providers, email marketing vendors, financial institutions, clinical research organizations, central laboratories, clinical database companies, payroll and benefit companies, and specialty pharmacies, information technology providers, among others.
Third Party Marketing & Analytics Providers
We disclose Personal Information to third party marketing and analytics providers via cookies and similar tracking technologies (“Cookies”) to promote our products and better understand the interests of consumers who may be interested in our products.
Third Party Collaborators
We disclose Personal Information to other companies with which we collaborate regarding particular products or services. These may include our co-promote partners for products that we jointly develop and/or market.
Authorized/legal representatives, family members, and caregivers
For patients, we disclose Personal Information to authorized representatives, family members, and caregivers as appropriate to provide product support and assistance and provide you with products and services you have requested.
Health care providers
For patients, we disclose Personal Information about you to health care providers to provide product support and assistance concerning your care, when you have authorized such disclosure. For health care professionals and caregivers, we disclose Personal Information about you as appropriate when assisting a patient in the coordination of care, use of a product or service, or benefits verification.
Health insurance providers or other payors
For patients, we disclose Personal Information about you to health insurance providers or other payors as appropriate to provide product support and assistance concerning your care, when you have authorized such disclosure. For healthcare professionals and caregivers, we disclose Personal Information about you as appropriate when assisting a patient in the coordination of care, use of a product or service, or benefits verification.
We may also disclose the categories of Personal Information listed in this Privacy Policy in the following contexts:
Corporate Transaction
In the event Acadia is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose Personal Information as part of that transaction.
For Legal Purposes
We may disclose Personal Information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to report adverse events related to an Acadia product or service; (iii) to investigate violations of law; (iv) to protect the legitimate rights, privacy, property, interests or safety of Acadia, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use; (v) to respond to an emergency; of (vi) to otherwise comply with laws and regulations, judicial and administrative orders, or lawful requests from government authorities.
6. How can you request access, amendment, or deletion of your Personal Information?
If you wish to request access to the Personal Information we maintain about you, or that we amend or delete such information, you may do so by clicking here or following the instructions in the “Contact Us” section below. We will address your request in accordance with applicable laws. Please understand that we may not be permitted to comply with requests to amend or remove Personal Information that relate to consumer product complaints; adverse events or reactions involving medicine, medical products or medical devices; or other information that we are required to maintain in accordance with a court order or other legal or regulatory process.
7. Your Marketing Choices
If you are a recipient of marketing-related communications from us, you can unsubscribe at any time by following the opt-out instructions in the communication or by contacting us using the information in the “Contact Us” section below. Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
8. Additional Technical Information
We collect Personal Information via Cookies when individuals use our Site, such as IP address, browsing history (including without limitation search terms and clickstream data), device type, operating system information and other usage information about your use of the Site. We collect this information to analyze trends and statistics, market our products and services, customize individuals’ use of our site, and manage our site administration. In some jurisdictions, we use Cookies that are not strictly necessary for the functioning of our Site only with Site visitors’ consent via our cookie banner. In other jurisdictions, we may use Cookies that are not strictly necessary for the functioning of our Site without prior consent, depending on applicable legal requirements. In all cases, Site visitors may choose to decline Cookies that are not strictly necessary for the functioning of our Site at any time by clicking “Cookies Settings” on our cookie banner or in the footer of our Site. Site visitors may also be able to use tools provided by their browser or device to limit and/or delete Cookies stored on their device.
Please see our Cookies Policy for more information about our collection of Personal Information via Cookies.
9. Security
We implement technical and organizational measures designed to safeguard your Personal Information from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure.
10. Retention of Personal Information
We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.
11. Children’s Privacy
Our services are not directed to or intended for use by individuals under the age of 16, and we request that these individuals do not use this Site or provide us with any Personal Information. Consistent with the requirements of applicable laws and regulations, if we learn that we have received Personal Information directly from a child under age 16 without his or her parent or legal guardian’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.
12. International Transfer of Personal Information
Acadia is committed to complying with this Privacy Policy and data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. Acadia is located in the United States, and we recognize that the laws in the United States may be different and, in some cases, not as protective as the laws in other countries. By providing us with your Personal Information and using our Site, you acknowledge that your Personal Information may be transferred and processed outside of your home country. In this case, be assured that Acadia will take all the necessary measures to ensure that any international transfers of your personal information comply with applicable data protection and privacy laws. If you would like to know more about how we protect your Personal Information, you can contact us using the information in the “Contact Us” section below.
For those individuals located in the EEA, UK or Switzerland, Acadia complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce, and as described in our Data Privacy Framework Notification. Acadia has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Acadia has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles and/or the UK Extension to the EU-US DFP, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/
13. Third Party Websites and Services
When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.
14. Additional Information for Individuals in the European Economic Area, Switzerland, the United Kingdom, and Serbia
Acadia is the data controller of the Personal Information collected under this Privacy Policy.
If you are located in the EEA, Switzerland, United Kingdom, or Serbia, and we maintain your Personal Information, you have the following additional rights with regard to your Personal Information:
- Right to be informed: You have the right to obtain from our Data Protection Officer for Europe, UK and Serbia confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, all necessary information to make the process transparent.
- Right to access and receive: You may request a copy of or access to the Personal Information we hold about you here. Under the European Union’s General Data Protection Regulation (“GDPR”) (and similar laws in Switzerland, the United Kingdom and Serbia), a response to a Data Subject Access Request will be provided free of charge, unless the request is deemed to be manifestly unfounded, excessive or repetitive in character. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.
- Right to portability: You may request that we transfer your Personal Information to a third party in a machine-readable format.
- Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.
- Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it.
- Right to erase: You may have the right to request that we delete all or some of your Personal Information. This right may be limited if we have collected your Personal Information for research purposes.
- Right to withdraw consent: You have the right to withdraw any consent you have previously given to Acadia at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.
- Right to complain: You have the right to lodge a complaint with your Supervisory Authority or with the Supervisory Authority where the alleged violation took place.
- You may exercise these rights by clicking here.
15. Additional Information for Canadian Residents
This section provides additional information for Canadian residents about the Personal Information we collect from you and how you can exercise your privacy rights. We maintain appropriate policies and procedures regarding our collection, use, and protection of Personal Information we collect about you. Among other things, our policies and procedures address our maintenance and destruction of Personal Information, define the roles and responsibilities of our personnel with respect to Personal Information handling, and document our processes for handling complaints regarding the protection of Personal Information.
To access Personal Information we maintain about you, request correction or deletion of your Personal Information, or withdraw your consent to the communication or use of your Personal Information (to the extent applicable), Canadian residents may contact us by calling (844) 422-2342 or by clicking here to submit your request through our web portal.
Personal Information we collect about Canadian residents, including via our Site and other means, may be transferred and processed outside of Canada, including in the U.S. Acadia will take all necessary measures to ensure that any international transfers of Canadians’ Personal Information comply with applicable data protection and privacy laws. Canadian residents may also contact our Privacy Officer at privacy@acadia-pharm.com for more information or with any privacy-related complaints or inquiries.
16. Additional Information for California Residents
If you are a California resident, you can learn more about the Personal Information we collect from or about you through both your online and offline interactions with our products or services in the Supplemental Notice for California Consumers. To quickly access details for each category of individuals for which we collect information, please click the applicable link below:
Website Visitors
Patients
HCPs and Caregivers
Applicants
Employees and Contractors (Current and Former)
Acadia Pharmaceuticals Privacy Policy Supplemental Notice for California Consumers
| Why? | The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information Acadia Pharmaceuticals collects about them, including whether it is being sold, shared, or otherwise disclosed to third parties. The CCPA also grants certain rights to California residents, including the right to correct inaccurate personal information, the right to delete their personal information (subject to certain exceptions) and the right to prevent Acadia Pharmaceuticals from selling their personal information. Companies are prohibited from retaliating or discriminating against consumers for exercising their rights under the CCPA. All companies need to collect and disclose consumers’ personal information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons. This Supplemental Notice provides the information required under the CCPA and applies to both Acadia Pharmaceuticals’ online and offline activities. For more information about how we collect, use, and disclose information through our websites and online services, please review our Privacy Policy. |
| What? | The types of personal information we collect and disclose depends on your relationship and interaction with Acadia Pharmaceuticals. Please review the Consumer Type below that applies to your relationship or interaction with Acadia Pharmaceuticals to learn about the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting, selling, or sharing the personal information, and the categories of third parties to whom we disclose personal information. If you interact with Acadia Pharmaceuticals in more than one way, please review each Consumer Type below that applies to you in order to learn about the personal information we collect and how we use and disclose it in connection with each particular relationship. In addition to the purposes for collecting and disclosing personal information described under each Consumer Type below, Acadia Pharmaceuticals collects and discloses any and all personal information (regardless of your relationship or interaction with us) as necessary or appropriate to: comply with laws and regulations; monitor, investigate potential breaches of, and enforce compliance with Acadia Pharmaceuticals policies and procedures and legal and regulatory requirements; comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and exercise or defend the legal rights of Acadia Pharmaceuticals and its employees, affiliates, customers, contractors, and agents. |
| Disclosure About Direct Marketing | California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to other entities for their own direct marketing purposes in the preceding calendar year. We do not disclose to third parties for their own marketing purposes the categories of personal information listed in California’s “Shine the Light” law, such as names, addresses, email addresses, and telephone numbers. |
| Personal Information | In this Supplemental Notice, “personal information” (or “PI”) means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly. In the charts below, we use the following categories of personal information to describe the personal information we collect, use, and disclose about consumers: Identifiers Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, phone number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Biometric Information Biometric information, including an individual’s physiological, biological, or behavioral characteristics (including DNA) to the extent it can be used to establish individual identity. Biometric information consists of, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template (such as a faceprint, a minutiae template, or a voiceprint) can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. Commercial Information Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Education Information An individual’s education information, including academic information and records. Electronic and Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call or profile photograph). Geolocation Data An individual’s precise geolocation data. Inferences Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies). Network Activity Data Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. Professional Information An individual’s professional or employment-related information. Protected Characteristics Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion. Sensitive Personal Information Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s 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; a consumer’s precise geolocation; a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; a consumer’s citizenship and immigration status; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; a consumer’s genetic data. Sensitive Personal Information also includes the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Other Identifiable Information An individual’s written signature; health insurance information, including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history; medical information, including any information in possession of or derived from a health care provider, health care service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment; and financial information, including bank account number, credit or debit card number, or other financial information. |
| Sources of Personal Information | Received From . . . Example Collection Methods and Circumstances You (directly) • Program registration/enrollment forms• Account registration forms• Information request forms• Surveys• When you contact us• Order formsYour devices Automatically collected as you navigate our sites. Health care providers • For patients: When you authorize your health care provider to disclose information to us so that we can provide certain patient support services. • For patients: When your health care provider reports to us information relating to adverse effects you have experienced when using our products. • For health care professionals and caregivers: When a health care provider reports your name and contact information to us for purposes of coordinating patient care. Health insurance providers or other payors • For patients: When you authorize your health insurance provider to disclose information to us so that we can provide certain patient support services. • For health care professionals and caregivers: When a health insurer reports your name and contact information to us for purposes of coordinating patient care. Caregivers • For patients: When your caregiver contacts us with questions about your treatment.• For patients: When your caregiver reports to us information relating to adverse effects you have experienced when using our products. • For health care professionals and caregivers: When a caregiver reports your name and contact information to us for purposes of coordinating patient care. Event organizers When you authorize event organizers to disclose attendee information to us. Lead generators When you authorize a third party to disclose your personal information tous so that we can provide you with information and services. Third parties who verify the information that you provide (e.g., consumer reporting agencies) • For patients: When you apply for patient support services that are income dependent. • For vendors and business partners: In the course of due diligence prior to contracting with you, in order to comply with regulatory requirements. Third parties who help us maintain the accuracy and completeness of our records (e.g., data brokers) On a routine basis to ensure that we have up-to-date contact information and to better serve you. |
| Entities to Whom We Disclose PI | We disclose and have disclosed in the past 12 months the categories of personal information listed in this Supplemental Notice within Acadia, at your direction, as disclosed to you at the time of collection, and in the following circumstances: Service Providers We disclose personal information to our service providers that help us run and manage our organization and process personal information solely on our behalf. The categories of service providers to which we disclose personal information may include delivery services, program enrollment and benefits verification providers, marketing and data analytics providers, email marketing vendors, financial institutions, clinical research organizations, central laboratories, clinical database companies, payroll and benefit companies, and specialty pharmacies, information technology providers, among others. Third Party Marketing & Analytics Providers We disclose Personal Information to third party marketing and analytics providers via cookies and similar tracking technologies (“Cookies”) to promote our products and better understand the interests of consumers who may be interested in our products. Third Party Collaborators We disclose Personal Information to other companies with which we collaborate regarding particular products or services. These may include our co-promote partners for products that we jointly develop and/or market. Authorized/legal representatives, family members, and caregivers For patients, we disclose Personal Information to authorized representatives, family members, and caregivers as appropriate to provide product support and assistance and provide you with products and services you have requested. Health care providers For patients, we disclose Personal Information about you to health care providers to provide product support and assistance concerning your care, when you have authorized such disclosure. For health care professionals and caregivers, we disclose Personal Information about you as appropriate when assisting a patient in the coordination of care, use of a product or service, or benefits verification. Health insurance providers or other payors For patients, we disclose Personal Information about you to health insurance providers or other payors as appropriate to provide product support and assistance concerning your care, when you have authorized such disclosure. For healthcare professionals and caregivers, we disclose Personal Information about you as appropriate when assisting a patient in the coordination of care, use of a product or service, or benefits verification. We may also disclose the categories of personal information listed in this Supplemental Notice in the following contexts: Corporate Transaction In the event Acadia is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose personal information as part of that transaction. For Legal Purposes We may disclose personal information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to report adverse events related to an Acadia product or service; (iii) to investigate violations of law; (iv) to protect the legitimate rights, privacy, property, interests or safety of Acadia, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use; (v) to respond to an emergency; of (vi) to otherwise comply with laws and regulations, judicial and administrative orders, or lawful requests from government authorities. |
| Your Rights | If you are a California resident, you have the following rights under the CCPA with respect to your personal information: Right to Notice. Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it. This Supplemental Notice is intended to satisfy this requirement. You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting, selling, or sharing the personal information, and the categories of third parties to whom we disclose personal information. Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you. Right to Correction. You have the right to request that we correct any inaccurate personal information that we maintain about you. Right to Deletion. You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information. Right to Opt-Out of the Sale & Sharing of Personal Information. We sell and share network activity information, such as online browsing information and interactions with our websites or advertisements, and we have sold and shared this category of personal information in the past 12 months. We sell and share this category of personal information to marketing and analytics providers to analyze and better understand consumers’ needs, preferences, and interests, and to advertise and promote our products and services. Under the CCPA, a “sale” is the disclosure of personal information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary consideration. We do not have actual knowledge that we sell or share personal information of consumers who are under 16 years of age. You have the right to opt out of the sale or sharing of your personal information. To do so, you can click “Cookies Settings” in the footer of our websites and click “Reject All.” You can also exercise your rights by calling (844) 422-2342 or by clicking here to submit your request through our web portal. Right To Limit the Use of Sensitive Personal Information. We use and disclose sensitive personal information as detailed in the charts below, which includes processing for purposes other than those specified in the CCPA regulations. You have the right to limit the use and disclosure of your sensitive personal information to the purposes specified in the CCPA regulations. To do so, you can contact us as provided immediately below. You can exercise your rights by calling (844) 422-2342 or by clicking here to submit your request through our web portal. Further, to the extent we collect sensitive personal information via network activity information, you can opt out of the sale or sharing of your sensitive personal information, by clicking “Cookies Settings” in the footer of our websites and click “Reject All.” VERIFICATION: We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, right to correction, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully. 1. When you submit a request, please indicate the specific reason why you are contacting us. We will assess what personal information we have about you that we can use to verify your request and let you know how to proceed. You may also authorize someone else to submit these requests on your behalf. To do so, you may execute a power of attorney pursuant to California Probate Code sections 4121 to 4130. You may also authorize a third party to submit these requests on your behalf by providing that third party with your signed permission to do so. If you authorize a third party to submit requests on your behalf, we may need to contact you directly to verify your identity. Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above. Opt-Out Preference Signals. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by law, we treat such opt-out preference signals as a valid request to opt-out of sale and sharing for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of sale and sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. Please note, however, that our websites do not currently respond to the “Do Not Track” signal. |
| Retention of Personal Information ? | We will keep your personal information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and all applicable legal requirements. |
| Questions? | Call (844) 422-2342 or email us at privacy@acadia-pharm.com to contact us with questions regarding this Supplemental Notice. California residents who are unable to review or access this Supplemental Notice due to a disability may contact us to request access this Supplemental Notice an alternative format. |
Website Visitors
| Categories of PI Collected | Sources of PI | Purposes for Collecting or Disclosing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
| Identifiers Geolocation Data Network Activity Data Professional Information Protected Characteristics Other Identifiable Information | Directly from you From your device | To deliver information, content, products or services that you request. To provide marketing communications about our products and services, or those of third-parties, that may be of interest to you. To understand how you use our products, services, and sites in order to improve and further develop our products and services and the content, features, performance, and support available through our sites. To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of our sites. To protect our rights or the rights, property, and safety of others. | Service providers Third Party Marketing & Analytics Providers Public authorities |
Patients
| Categories of PI Collected | Sources of PI | Purposes for Collecting or Disclosing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
| Identifiers Biometric Information Commercial Information Electronic and Sensory Data Geolocation Data Inferences Network Activity Data Sensitive Personal Information Protected Characteristics Professional Information Other Identifiable Information | Directly from you From your device Your health care provider Your health insurance provider or other payor Caregivers Event organizers Lead generators Third parties who verify the information that you provide (e.g., consumer reporting agencies) Third parties who help us to maintain the accuracy and completeness of our records (e.g., data brokers) | To deliver information, content, products or services that you request. To provide marketing communications about our products and services, or those of third-parties, that may be of interest to you. To understand how you use our products, services, and sites in order to improve and further develop our products and services and the content, features, performance, and support available through our sites. To provide legal or service-related notices about our products, services, and sites. To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of our sites. To protect our rights or the rights, property, and safety of others. To comply with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities. | Service providers Third Party Marketing & Analytics Providers Authorized/legal representatives, family members, and caregivers Your health care provider Your health insurance provider or other payor Public authorities |
Health Care Professionals (HCPs) and Caregivers
| Categories of PI Collected | Sources of PI | Purposes for Collecting or Disclosing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
| Identifiers Commercial Information Education Information Electronic and Sensory Data Geolocation Data Inferences Network Activity Data Professional Information Protected Characteristics Professional Information Other Identifiable Information | Directly from you From your device Patient(s) under your care Product distributors (Other) health care professionals Health insurance providers or other payors Event organizers Lead generators Third parties who verify the information that you provide (e.g., consumer reporting agencies) Third parties who help us to maintain the accuracy and completeness of our records (e.g., data brokers) Publicly available sources (e.g., social media) | To deliver information, content, products or services that you request. To provide marketing communications about our products and services, or those of third-parties, that may be of interest to you. To understand how you use our products, services, and sites in order to improve and further develop our products and services and the content, features, performance, and support available through our sites. To provide legal or service-related notices about our products, services, and sites. To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of our sites. To protect our rights or the rights, property, and safety of others. To comply with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities. | Service providers (Other) health care professionals Third Party Marketing & Analytics Providers Health insurance providers or other payers Public authorities |
Applicants
| Categories of PI Collected | Purposes for Collecting or Disclosing PI |
|---|---|
| Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | Evaluate a potential employment or contractor relationship with you. Perform background checks and verify past employment, educational history, and professional standing and qualifications. Evaluate, determine, and arrange compensation, payroll, and benefits. Assess your fitness and physical capacity for work. Contact you regarding your application and potential employment or contractor relationship with us. |
| Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion | Provision of accessibility facilities, equipment, and services. Provide this Privacy Notice and other informational forms to you in an accessible format as needed. |
| Professional or employment-related information. | Perform background checks and verify past employment, educational history, and professional standing and qualifications. Assess your fitness for employment with the company. Evaluate, determine, and arrange compensation, payroll, and benefits. |
| Education information or other academic information. | Perform background checks and verify past employment, educational history, and professional standing and qualifications. Assess your fitness for employment with the company. Evaluate, determine, and arrange compensation, payroll, and benefits. |
| Written signatures. | Execute written contracts, including offers of employment. |
| In addition to the purposes identified above, Acadia Pharmaceuticals may use and disclose any and all personal information that we collect as necessary or appropriate to: | Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti discrimination, immigration, labor and employment, and social welfare laws. Monitor, investigate, and enforce compliance with and potential breaches of Acadia Pharmaceuticals’ policies and procedures and legal and regulatory requirements. Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons. Exercise or defend the legal rights of Acadia Pharmaceuticals and its employees, affiliates, customers, contractors, and agents. |
Employees and Contractors (Current and Former)
| Categories of PI Collected | Purposes for Collecting or Disclosing PI |
|---|---|
| Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | Manage your employment or contractor relationship with us. Compensation, payroll, tax, and benefits planning, enrollment, and administration. Provide you access to Acadia Pharmaceuticals systems, networks, databases, equipment, and facilities. Workforce and performance management, including personnel planning, productivity monitoring, and evaluation. Workforce development, education, training, and certification. Monitor, maintain, and secure Acadia Pharmaceuticals systems, networks, databases, equipment, and facilities. Authenticate your identity and verify your access permissions. Arrange, confirm, and monitor work-related travel, events, meetings, and other activities. Assess your working capacity or the diagnosis, treatment or care of a condition impacting your fitness for work, and other preventative or occupational medicine purposes (including work-related injury and illness reporting). Contact and communicate with you regarding your employment, job performance, compensation, and benefits, or in the event of a natural disaster or other emergency. Contact and communicate with your designated emergency contacts in the event of an emergency, illness, or absence. Contact and communicate with your dependents and designated beneficiaries in the event of an emergency or in connection with your benefits. |
| Health insurance information, including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history. | Assess your working capacity or the diagnosis, treatment or care of a condition impacting your fitness for work, and other preventative or occupational medicine purposes (including work-related injury and illness reporting). For the administration of benefit programs. |
| Financial information, including bank account number, credit or debit card number, or other financial information. | Manage and comply with employment contract. Compensation, payroll, and expense management. Contact and communicate with your dependents and designated beneficiaries in the event of an emergency or in connection with your benefits. |
| Medical information, including any information in possession of or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment. | Assess your working capacity or the diagnosis, treatment or care of a condition impacting your fitness for work, and other preventative or occupational medicine purposes (including work-related injury and illness reporting). For the administration of benefit programs. |
| Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion. | For the administration of benefit programs. Provision of accessibility facilities, equipment, and services. Provide this Privacy Notice and other informational forms to you in an accessible format as needed. |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Assess compliance with company policies or procedures. Gather information for the purposes associated with legal proceedings. |
| Biometric information, including an individual’s physiological, biological, or behavioral characteristics (including DNA) to the extent it can be used to establish individual identity. Biometric information consists of, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template (such as a faceprint, a minutiae template, or a voiceprint) can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | For the security purposes of the employee, company, or both. Monitor, maintain, and secure Acadia Pharmaceuticals systems, networks, databases, equipment, and facilities. Authenticate your identity and verify your access permissions. |
| Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. | Manage access to, use of, and security of Acadia Pharmaceuticals information systems, facilities and property for public safety and health purposes (which may, in some instances, include video monitoring of commonly-shared spaces). Ensure network and information security (e.g., preventing malicious code distribution, information system attacks, preventing damage to computer or electronic communications systems. Conduct internal investigations and other compliance activities (e.g., audit, assessing employee adherence to Acadia Pharmaceuticals policies and procedures). |
| Geolocation data. | For security and building access purposes. Equipment assignment and tracking. Manage access to, use of, and security of Acadia Pharmaceuticals information systems. |
| Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call or employee profile photograph). | Manage access to, use of, and security of Acadia Pharmaceuticals information systems, facilities and property for public safety and health purposes (which may, in some instances, include video monitoring of commonly-shared spaces). Authenticate your identity and verify your access permissions. |
| Professional or employment-related information. | Evaluate, determine, and arrange compensation, payroll, and benefits. Workforce development, education, training, and certification. |
| Education information or other academic information. | Evaluate, determine, and arrange compensation, payroll, and benefits. Workforce development, education, training, and certification. |
| Written signatures. | Execute written agreements with or on behalf of Acadia Pharmaceuticals. |
| In addition to the purposes identified above, Acadia Pharmaceuticals may use and disclose any and all personal information that we collect as necessary or appropriate to: | Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws. Monitor, investigate, and enforce compliance with and potential breaches of Acadia Pharmaceuticals policies and procedures and legal and regulatory requirements. Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons. Exercise or defend the legal rights of Acadia Pharmaceuticals and its employees, affiliates, customers, contractors, and agents. |
17. Changes to this Privacy Policy
Acadia reserves the right to modify this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. This Privacy Policy was last updated as of the effective date listed above.
18. Contact Us
We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below and we will respond to you as soon as reasonably possible.
Acadia Pharmaceuticals Inc.
12830 El Camino Real, Suite 400
San Diego, CA 92130
USA
Email: privacy@acadia-pharm.com
For Individuals Located in the European Economic Area, Switzerland, or the United Kingdom:
Acadia complies with the EU-US DPF, UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF (“DPF”).
In compliance with the DPF, Acadia commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals may click here to submit your personal data request, inquiry or complaint through our web portal, or contact one of the individuals below:
Data Protection Officer for UK, Europe and Serbia:
Data Compliant Limited, 22 Friars Street, Sudbury, Suffolk, CO10 8NP
United Kingdom
Phone: +44 1787 277742
Email: acadiadpo@datacompliant.co.uk
European Data Protection Representative:
MyData- TRUST
Boulevard Initialis, 7 box 3
7000 Mons
BELGIUM
Phone: +32 65 55 41 20
Email: acadia.eudpr@mydata-trust.info
United Kingdom Data Protection Representative:
MyData- TRUST
Waldeck House
Lyne Lane
CHERTSEY
KT16 0AW
United Kingdom
Phone: +44 56 0375 0073
Email: acadia.ukdpr@mydata-trust.info
In compliance with the DPF, Acadia commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on DPF.
Serbian Data Protection Representative:
Karanovic & Partners o.a.d.
Resavska 23
11000 Belgrade, Serbia
Phone: +381 11 3094 200
Fax: +381 11 3094 223
Email: acadia.local.representative@karanovicpartners.com
19. Consumer Health Data Privacy Policy
This Consumer Health Data Privacy Policy applies to “Consumer Health Data,” as that term has been defined under applicable law. Any term appearing in this Consumer Health Data Privacy Policy that has been defined under applicable Consumer Health Data laws shall have the meaning afforded to it therein.
A. Collection of Consumer Health Data
We Collect the following categories of Consumer Health Data from Consumers:
- Individual health conditions, treatment, diseases, or diagnosis;
- Social, psychological, behavioral, and medical interventions;
- Health-related surgeries or procedures;
- Use or purchase of prescribed medication;
- Bodily functions, vital signs, symptoms, or measurements related to health;
- Diagnoses or diagnostic testing, treatment, or medication;
- Gender-affirming care information;
- Reproductive or sexual health information;
- Biometric data;
- Genetic data;
- Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies;
- Data that identifies a Consumer seeking health care services;
- Health-related data that have been derived or inferred from the above.
We Collect and use the above-mentioned categories of Consumer Health Data for the following purposes:
- To deliver information, content, products or services that you request;
- To provide marketing communications about our products and services, or those of third-parties, that may be of interest to you;
- To understand how you use our products, services, and sites in order to improve and further develop our products and services and the content, features, performance, and support available through our sites;
- To provide legal or service-related notices about our products, services, and sites;
- To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of our sites;
- To protect our rights or the rights, property, and safety of others;
- To comply with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities.
B. The Categories of Sources from Which We Collect Consumer Health Data
We Collect Consumer Health Data directly from Consumers, such as when they enquire about our products and services, contact us via the Site, ask to be a research study participant in one of our trials, or in any way engage with us or our personnel. Additionally, we Collect Consumer Health Data from the following sources:
- Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links in our emails;
- Through the use of social media platforms, such that if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
- Third party vendors, which may include those vendors, suppliers, contractors or business partners that provide services for us (e.g. market research vendors);
- Adverse event reporting reporters or subjects; and
- Publicly available sources.
C. The Categories of Consumer Health Data that We Share
We Share all of the categories of Consumer Health Data that we Collect.
D. Third Parties and Affiliates with Whom We Share Consumer Health Data
We Share Consumer Health Data with the following Third Parties:
- Marketing and data analytics services;
- Authorized/legal representatives, family members, and caregivers;
- Health care providers;
- Health insurance providers and other payors; and
- Public authorities, for instance, when doing so is necessary to report adverse events, investigate violations of law, protect our rights, or to otherwise comply with the law.
And the following Affiliates:
- Acadia Pharmaceuticals (Canada) Inc.
E. How to Exercise Your Consumer Health Data Rights
To exercise your rights with respect to your Consumer Health Data, depending on your state of residence, you may contact us at any time through any of the following methods:
- Web Form. You may submit a request on our Privacy Web Form by clicking here.
- Email. privacy@acadia-pharm.com
- Mail. Acadia Pharmaceuticals Inc., 12830 El Camino Real, Suite 400, San Diego, CA 92130 USA
20. Supplement to Consumer Health Data Privacy Policy for Nevada Consumers
This Supplement applies to Nevada Consumers for purposes of providing additional disclosures required by Nevada’s Consumer Health Data privacy law. Terms used herein that are defined terms under Nevada’s Consumer Health Data privacy law shall have the meanings afforded to them therein.
A. Purposes & Manner of Processing. We Collect, use, Process, and Share Consumer Health Data for the purposes and in the manners described in our Consumer Health Data Privacy Policy, which also provides additional disclosures relevant to Nevada Consumers.
B. Review & Revision of Consumer Health Data. If you would like to review and/or revise your Consumer Health Data, you may submit a request to us via the methods listed in our Consumer Health Data Privacy Policy. We will respond to your requests to exercise your rights in accordance with applicable law, but in any case no later than 45 days after receiving your request. We may extend this period up to 45 days only where doing so is permitted under applicable law.
C. Changes to this Supplement. We will notify you before making any changes to our privacy practices with respect to your Consumer Health Data by posting an updated notice on this page, with an updated effective date.
D. Third Party Collection of Consumer Health Data. Please note that some Third Parties may collect Consumer Health Data about you over time and across different websites or online services you may visit.
Effective Date: October 8, 2024