Last Updated: June 25, 2020
What is – and is not – personal information? What is meant by “de-identified” information and “aggregated” information?
When we use the term “personal information”, we are referring to information that can be readily used to identify a specific person. Examples of personal information that we might collect from you include your name and your street or e-mail address. All of those items of information can be used to identify you.
Information that relates to you, but cannot be used to identify you, is not “personal information.” So, for example, your state of residence is a piece of information about you, but it is not, by itself, “personal information.” However, if we collect your street address and your state of residence and we put them together in our systems, we would treat both pieces of information as “personal information” because, when taken together, they can be used to identify you.
Why does Arbor collect personal information?
We collect personal information in order to provide you with our products and services. We also collect personal information to improve your experience as a user of our website and to improve others’ experience as well. Sometimes the personal information that we collect enables you to use online resources or obtain communications about topics of interest to you. We also analyze the personal information we collect so that we can identify and offer new products and services.
How do we collect personal information?
Direct Collection. We collect personal information from you when you voluntarily provide it to us by, for example, filling in an online form or participating in an interactive display. Contact details—your name, street address, e-mail address, telephone number, birth date, etc.—are often collected in this manner. So is health status, so that we can provide you with information that is more likely to be relevant to you.
Indirect Collection, including Cookies, Web Beacons and Similar Technologies. As you navigate our website, we collect information from you indirectly based on your online behavior. We collect your Internet Protocol (IP) address which identifies the device used to access our website. We also collect Cookies. Cookies store information about your preferences, record user-specific information on which pages of our website you access or visit, and help us personalize or customize our web page content based upon your browser.
We may use Google Analytics, a third party provider of analytics tools or a similar third party service to analyze information about visits to our website. For information about opting out of Google Analytics please visit: https://tools.google.com/dlpage/gaoptout.
Our site does not recognize so-called “do not track signals” sent by some browsers, so if you want to manage cookies placed by our site, please use your browser’s cookie settings as discussed above. Arbor Pharmaceuticals does not track its customers over time and across third party websites to provide targeted advertising.
Third Party Links and Websites
Does Arbor collect personal information from children?
No. Our websites are not directed at children under the age of 18 and we do not knowingly collect the personal information of minors. If we are made aware that we have inadvertently collected the personal information of a minor, we will delete it immediately. Where requests for information about a medication are permitted by law, people requesting information about a medicine that is indicated for use in children must be 18 years old or older.
How does Arbor store and secure personal information?
We strive to protect personal information as it is transmitted from your computer to our online resources and servers. Due to the open nature of the Internet, we cannot guarantee that our interactions with you, and yours with us, will be free from unauthorized access by third parties. We protect our servers and data with a firewall and endeavor to protect personal information in our possession, custody or control from unauthorized access, disclosure, alteration or destruction. Employees and business partners with access to your personal information must have a business-related “need to know” in order to perform their job functions for us. However, we also depend on you to help secure your information by protecting your own copies of passwords and related access codes for our online resources.
Does Arbor disclose your personal information to third parties?
Does Arbor sell your personal information to third parties?
No. Arbor does not sell your personal information to third parties. The personal information we collect is used only for the purpose of providing products and services to you. We may sell aggregated information, as defined above in this policy, to third parties.
Can you choose whether and when to share personal information with Arbor?
Yes. If you do not want to provide any personal information to Arbor online, you can decline to enter personal information into forms or data fields on websites. You can also refuse to use personalized services offered by online resources. However, you do need to bear in mind that some online resources are only available to people who do choose to provide their personal information.
If you do provide some personal information online, some Arbor online resources may ask you if we can use and disclose your personal information to add you to contact lists, and to identify other services and promotions of possible interest. You can manage proposed additional uses of personal information about you by giving or withholding permission (e.g., by “checking” or “un-checking” boxes or “radio buttons” on Web forms). You can also opt out of receiving future email communications from Arbor by using the “unsubscribe” feature on emails you receive from Arbor.
Point of Contact
Arbor Pharmaceuticals, LLC
Six Concourse Parkway, Suite 1800
Atlanta, GA 30328
California Residents: Your Rights
California residents (“you” or “your”) have specific rights regarding their personal information (“personal information” or “PI”) under the California Consumer Privacy Act (“CCPA”). This section describes your CCPA rights and explains how to exercise them. Please note that the CCPA does not apply to certain information, including HIPAA-regulated protected health information and clinical trial information and our processing of these categories of information is not addressed below.
Categories of Personal Information Collected, Disclosed, or Sold in the Last Twelve (12) Months
You have the right to know the categories of personal information Arbor Pharmaceuticals has collected, disclosed, or sold about its consumers within the last twelve (12) months. The chart below offers a comprehensive overview of the types of personal information we collect, with whom it is shared, and for what purposes.
|Category||Examples||Collected||Source||Purpose of Collection||Third Parties to Whom Disclosed|
|A. Identifiers.||A real name, postal address, unique personal identifier, online identifier, email address, Social Security number, Phone number.||YES||Forms submitted via mail or email to our facilitating vendors||To communicate with consumers and physicians, including responding to inquires and to facilitate Patient Assistance and Copay assistance programs||Third party vendors who manage programs on Arbor’s behalf and Federal regulatory agencies|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, address, or telephone number medical information. Some personal information included in this category may overlap with other categories.||YES||Forms submitted via mail or email to our facilitating vendors||To communicate with consumers and physicians, including responding to inquires and to facilitate Patient Assistance and Copay assistance programs||Third party vendors who manage programs on Arbor’s behalf and Federal regulatory agencies|
|C. Protected classification characteristics under California or federal law.||Age, medical condition,.||YES||Forms submitted via mail or email to our facilitating vendors||To facilitate Patient Assistance Programs, coupon programs, and adverse event reporting.||Third party vendors who manage programs on Arbor’s behalf and Federal regulatory agencies|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. 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.||NO due to clinical trial exception|
|F. Internet or other similar network activity.||Information on a consumer’s interaction with a website or advertisement.||YES||Third party Data Analytics providers||To improve website and advertisement targeting. This data is de-identified and aggregated. Arbor never has access to any individual data.||Digital Advertising agencies|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES||Inbound calls may be subject to recording||To facilitate Patient Assistance Programs, coupon programs, compliants, general business inquiries and adverse event reporting.||Third party vendors who manage programs on Arbor’s behalf and Federal regulatory agencies|
|I. 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.||NO|
|J. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Arbor Pharmaceuticals discloses certain information to you about our collection, use, disclosure and sale of your personal information over the past twelve (12) months. Once we receive and confirm your request, to the extent you have requested them, we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information was collected;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we shared that personal information, if any;
- The specific pieces of personal information we have collected about you (also called a data portability request); and/or
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
- Sales, identifying the personal information categories that each category of recipient purchased.
Right to Request Deletion of Personal Information
You have the right to request that Arbor Pharmaceuticals delete any of the personal information that we have collected from you and maintain, subject to certain exceptions. Once we receive and confirm your request, we will either delete, de-identify, or aggregate your personal information, unless not doing so is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the you have previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Sale of Personal Information
Arbor Pharmaceuticals does not sell your personal information. We may, as permitted by the CCPA, sell aggregate consumer information, which is information that relates to a group or category of consumers, from which individual consumer identities have been removed, and that is not reasonably linkable to any consumer or household.
Exercising Your Rights to Know and Deletion
To exercise your rights please submit a request to CCPAPrivacy@ArborPharma.com or call the following toll-free telephone number 1-844-916-1298.
In order to submit a consumer request, a consumer must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide contact information that will allow us to confirm information and make additional inquiries to allow us to properly understand, evaluate, and respond to your request.
Only you, or someone legally authorized to act on your behalf (i.e., your authorized agent), may make a request related to your personal information. You may also make a request on behalf of your minor child. Arbor Pharmaceuticals may require an agent to provide verification that they are acting on your behalf when they submit a request related to your personal information.
Arbor Pharmaceuticals will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of services.
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
Attn: Jeff Burris, Chief Privacy Officer
Postal Address: Six Concourse Parkway, Suite 1800 Atlanta, GA 30328