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CMP External Privacy Policy

Protecting your personal Data, as defined below, is a priority for CMP, the data controller in this Statement, and its affiliates (together herein “CMP” or “we”). This Statement of Privacy (this “Statement”) applies to CMP’s Processing of Data through www.cmppharma.com and other websites owned by CMP (“Sites”) and in general. The Processing may be conducted by CMP, its service providers, or third parties acting as service providers for CMP. By using the Sites or engaging in our programs, you consent, to the extent allowed by law, to the Data practices described in this Statement including the sharing of Data.

This Statement was last reviewed on December 12, 2024. When we change this Privacy Policy in a material way, we will update this effective date. We will also provide you with notice of changes and obtain your consent to any such changes where and as required by applicable law. Please check back periodically for updates to this Statement. CMP Pharma Inc. is located at 8026 E Marlboro Rd, Farmville, NC 27828.

We use the term “Data” herein to mean information that may be used to identify you personally, or your household in some jurisdictions; this includes, for example, name, email address, physical address, telephone number, and any other information that can be used to reasonably identify you. Further information on what Data we Process is provided below.

We use the term “Process” herein to mean any action taken with your Data as described further in this Statement.

Our Sites may contain links to third-party websites/content/services that are not owned or controlled by CMP. CMP is not responsible for how these third-party properties operate or treat your Data, so we recommend that you read the privacy policies and terms associated with these third-party properties carefully.

What Data Do We Process?

Sites and programs may Process Data, such as your:

  • Name
  • Identifiers, including third party identifiers
  • Contact information
  • Communications sent to CMP
  • IP address and device ID
  • Site interactions
  • Data submitted to the Site
  • Inferences
  • Geolocations

If you are a healthcare provider, we may also Process additional Data like your NPI number and Data related to your employment, our interactions with you, and your product purchases.

CMP may Process additional Data as permitted by law.

How Do We Collect Your Data?

  • Forms: When you complete and submit or update a form, registration, survey, or profile (collectively, “Form”), we collect the Data that you included in the Form for the business purposes described in the Form and in this Statement.
  • Cookies and Tracking Technology: When you visit our Sites, we or third parties use cookies and other identifiers to collect information about your online activity and usage, including your IP address to keep track of your browsing patterns and to build a demographic profile.
  • Publicly Available Data: Where permitted by applicable law, we may augment the Data we have about you with information obtained from third-party publicly available sources. For example, to verify licensure of healthcare professionals, we may use Data in conjunction with information lawfully obtained from a licensing board.
  • Event Interactions: If you attend an event where CMP participates through educational or marketing activities, CMP may be provided with your Data related to that event either by you directly or through the event organizers.

How Do We Process Your Data?

CMP may Process your Data for the following purposes, or as otherwise permitted by applicable law:

  • To facilitate the activity described to you at the point of collection of the Data or that you have requested such as responding to communications which you direct to CMP or our service providers.
  • To provide and deliver services, products, and information, including through our events.
  • To maintain, improve, and operate our Sites.
  • To create, maintain, customize, and secure any account that you have with us.
  • To perform or enforce contracts with you or with third parties.
  • To tailor marketing programs and campaigns, conduct marketing research analysis and surveys.
  • To serve advertisements to you.
  • To perform activities necessary to ensure compliance with applicable laws, including to comply with regulatory monitoring and reporting obligations such as those related to adverse events, product complaints, patient safety, and financial disclosures, to respond to requests from government authorities, and to protect the legal interests of yours, ours or third parties, such as to protect against fraud.
  • In the event that some or all of our assets are acquired by or merged with a third-party entity or in connection with a proposed or actual merger, acquisition, sale, or other change of control, we may use or transfer some or all of the Data that we have collected about you to determine whether to proceed with the transaction and execute the transaction if we decide to do so.

How Do We Share You Data?

We may share your Data in the following situations, or as otherwise permitted by applicable law:

  • Our Affiliates: CMP and its subsidiaries, affiliates, and its parent company may share your Data amongst and between each other for the purposes set forth in this Statement.
  • Our Service Providers: We share your Data with affiliated and unaffiliated service providers as necessary for them to provide services to us, subject to appropriate confidentiality and data protection agreements. Service providers assist us with data analysis, customer service, web hosting, marketing, website development, government and regulatory compliance reporting, and other activities related to the management of our business and provision of our products and services.
  • Advertising and Third-Party Marketing/Analytics: Cookies, pixels, and other tracking technologies are used on the Sites for marketing and analytics. These may send Data to third parties. Some laws interpret this transfer as a sale of data. You may opt out of the continued use of these pixels and cookies in the link to our cookie management tool below.
  • Legal Compliance: We will share Data for legal reasons as we believe required or advisable.
  • Professional Advisors: We may disclose Data to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services they provide to us.
  • Mergers and Acquisitions: We may provide Data to a potential or actual buyer in connection with a proposed or actual merger, acquisition, sale, or other change of control, as described above.
  • Other Disclosures with Your Consent: We may ask you to share your Data with other recipients not described elsewhere in this Statement.

How Do We Protect Your Data

CMP takes reasonable measures to secure your Data from unauthorized access, use, or disclosure. CMP uses the SSL/TLS Protocol method for this purpose. When Data is transmitted to other Sites, it is protected using encryption, such as the Secure Sockets Layer (SSL) or Transport Layer Security (TLS) protocol. These steps help protect Data from unauthorized access, use, disclosure, alteration, or destruction. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at [email protected]

Cookies, Pixels, and Track Technology

Information about your computer hardware and software may be automatically collected by CMP or third-party tracking technology on our Sites. This Data can include information such as your IP address, browser type, domain names, access times and referring website. This information is used for activities like the operation of the service, to maintain the quality of the service, and to provide general statistics regarding use of the CMP Sites and programs. For example, cookies can help to personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies can be uniquely assigned to you.

You have the ability to continue to allow or decline cookies and many types of tracking technology. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the CMP services or Sites you visit. You may opt-out of marketing and analytics cookies by clicking on the cookie management tool link below. You may not out-out of necessary cookies, which are cookies which are required to allow the Site to function.

CMP may also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about your use of our Sites and report on activities and trends. This service may also collect information regarding your use of other Sites, apps and online resources. You can learn about Google’s practices by going to http://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/

Children Under Thirteen

CMP does not knowingly collect Data from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this Site or CMP programs.

Your Rights and Privileges

You may have specific rights related to your Data depending on the applicable jurisdiction. Please reach out to CMP at [email protected] to exercise your rights. These rights may include rights like the right to access, correct, and delete your Data which CMP Processes. In order to ensure compliance in the process of supporting your rights, CMP may require that you verify your identity as reasonably necessary. You may also have the right to opt out of certain processing such as the processing of sensitive Data or automated decision making with your Data. Please also contact CMP at the email address provided to exercise those rights.

Opt-Out & Unsubscribe from Marketing

We respect your privacy and give you an opportunity to opt-out of receiving marketing information. Users may opt-out of receiving any or all marketing communications from CMP by contacting us at [email protected] by calling us toll-free at 1-800-227-6637.

Contact Information

CMP welcomes your questions or comments regarding this Statement. If you believe that CMP has not adhered to this Statement, please contact CMP at:

Address:

CMP Pharma, Inc.
8026 East Marlboro Road
Farmville, North Carolina 27828

Email Address:
[email protected]

Telephone number:
(252) 753-7111

Additional State Specific Privacy Notices: California, Colorado, Connecticut, Utah, Texas, Oregon, and Virginia residents

The following provisions apply to the Data of California, Colorado, Connecticut, Utah, Texas, Oregon, and Virginia residents processed by CMP, whether collected online or offline. These provisions supplement the other sections of the Statement. Based on your state of residence other privacy laws might apply. To determine the applicability of such laws, each request will be evaluated individually, on a case-by-case basis.

Sharing Data for Advertising Purposes

CMP may use your Data for advertising purposes. For example, we may gather information via a retargeting cookie placed on your internet browser. The information we receive allows us to serve you ads on other websites, based on your visit to our Sites. If you would like to opt-out of the sharing of your Data to show you advertisements on other websites, please email [email protected].

Individual Consumer Rights

Right of Access – The right for a consumer to access (a) the categories and specific pieces of Data we collect, use, disclose, sell, or share about you, (b) the categories of sources from which we collected your Data, (c) our purposes for collecting or selling Data, (d) the categories of your Data (if any) that we have either sold, shared, or disclosed for a business purpose, (e) the categories of third parties with which we have sold or shared Data, (f) or some combination of similar information.

Right of Correction – The right for a consumer to request that incorrect or outdated Data be corrected.

Right of Deletion – The right for a consumer to request that we delete the Data we have collected from or maintain about them.

Right of Restriction – The right for a consumer to limit our use and disclosure of their Data.

Right of Portability – The right for a consumer to request their Data be disclosed in a common file format.

Right to Opt-Out of Sales – The right for a consumer to opt out of our sale(s) or sharing (if any) of your Data.

Right Against Discrimination – The right for a consumer not to receive discriminatory treatment for the exercise of the privacy rights conferred by applicable laws.

Right Against Automated Decision-Making: The right for a consumer not to have a decision made about them based solely on an automated process without human input.

How to Exercise Your Consumer Rights

Based on your state of residence, you may have some or all of the rights included above in the “Individual Consumer Rights” Section of this Statement. Consumers must submit their privacy requests by emailing us at [email protected] or by contacting us at 1-866-271-8587. Only you, or someone legally authorized to act on your behalf, may make a privacy request. We will verify and respond to your request consistent with data protection laws. We may need to verify your identity before completing your privacy request. We may request additional Data from you, such as your home address, email address and government issued ID, to protect against fraudulent requests.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Authorized Agent Requests

You may authorize someone to make a privacy request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf.

In California, authorized agents must be registered with the California Secretary of State to conduct business in California or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s Data, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.

Appeals

If you are a resident of the above listed U.S. States, you may have the right to appeal CMP’s refusal to act on a submitted privacy request. To submit an appeal, please email [email protected]

Data Retention

We will keep your Data for as long as we are permitted based on the purpose(s) for which it was obtained. We decide how long we need Data on a case-by-case basis, and we may consider the following criteria to determine an appropriate retention period: (a) the length of time we have an ongoing relationship with you and provide a website, information, product, or service to you; (b) whether there is a legal obligation to which we are subject; or (c) whether retention is advisable in light of our legal position.

CCPA Regulations §999.317(g)(2) Metrics Requirement

Request Type Received Complied with in
Whole or in Part
Denied Median Number of Days
to Respond
Requests to know 0 0 0 N/A
Requests to delete 0 0 0 N/A
Requests to opt-out 0 0 0 N/A

Data Categories We Collect and Disclose

Listed below are the categories of Data about California, Colorado, Connecticut, Utah, Texas, Oregon, and Virginia residents that we may Process for a business purpose. For more information about the categories of third-parties with whom we sell or share your Data, refer to the “How Do We Share You Data?” Section above.

In particular, we have collected, disclosed, sold, or shared the following categories of Data from our consumers within the last twelve (12) months:

Category Examples Collected? Disclosed for a Business Purpose? Sold or Shared?
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, National Provider Identifier (NPI), Medicare provider number, driver’s license number, passport number, or other similar identifiers. YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

Legal Compliance

YES, SHARED
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

Legal Compliance

YES, SHARED
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES YES

Within Our Family of Companies

Service Providers

NO
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, including prescribing data. YES YES

Within Our Family of Companies

Service Providers

YES, SHARED
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. YES YES

Within Our Family of Companies

Service Providers

Legal Compliance

NO
Internet or other similar network activity. Website navigation, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

YES, SHARED
Geolocation data. Physical location or movements. YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

YES, SHARED
Audio/Visual. Audio, electronic, or visual recordings, or similar information. NO

(Except in instances where explicit consent is granted.)

NO NO
Professional or employment-related information. Current or past job history or performance evaluations. YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

Legal Compliance

YES, SHARED
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES YES

Within Our Family of Companies

Service Providers

NO
Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES YES

Within Our Family of Companies

Service Providers

Third-Party Advertisers

YES, SHARED
Sensitive Personal Information. Personal Information including your Social Security number, driver’s license number, state identification card number, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, or union membership status. YES YES

Within Our Family of Companies

Service Providers

NO