PRIVACY POLICY
Fosun Pharma USA, Inc. Privacy Notice
Last modified: 5/28/2024
Introduction
Fosun Pharma USA, Inc. (“Fosun” or“we” or “us”) respects your privacy and are committed to protecting it through our compliance with this Privacy Notice.
This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect, use, maintain, disclose, or otherwise process about you when you visit the website RevisitES-SCLC.com (the “Website”) and our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information.
This Privacy Notice applies to information we collect:
- on our Website;
- when we communicate with you in person (such as at a conference) or over the telephone;
- in email, text, and other electronic messages between you and Fosun through any medium; and
- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Notice.
This Privacy Notice does not apply to information collected by:
- us through any other means, including on any other website operated by Fosun or any third-party (including our affiliates and subsidiaries);
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice regularly for updates.
1. Children Under the Age of 18
Our Website not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on our Website, including your name, e-mail address, or telephone number. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at inquiry@fosunpharmausa.com.
2. Information We Collect About You and How We Collect It
Throughout this Privacy Notice, the term “Personal Information” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Information does not include any deidentified or aggregated information.
Generally
We collect Personal Information from various sources, including:
- directly from you when you provide it to us;
- automatically as you navigate through or otherwise use the Website; and
- from our parent, affiliates, and subsidiaries where applicable.
Information You Provide to Us
We collect the following types of Personal Information directly from you when you access or use our Website: name, e-mail address, telephone number, address, and professional or employment related information. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence or interactions with us.
The Personal Information that you directly provide us is collected through:
- information that you provide by filling in forms on our Website, including when requesting further information; and
- information you provide to us at other points of contact.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain Personal Information about your interaction with our Website, including information about your equipment, browsing actions, and patterns. This includes:
- details of your visits to, and use of, our Website. This includes: browsing history, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on or through the Website; and
- information about your computing device and internet connection, i.e., your IP address, operating system, device make and model, and browser type.
The information we collect automatically may include Personal Information. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences;
- record your activities on our Websites for analytics and debugging purposes;
- customize our Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you select this setting you may be unable to access certain parts of our Website. Our Website may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. You can find more information about cookies at http://www.allaboutcookies.org. By continuing to allow cookies (see Choices About How We Use and Disclose Your Information), you hereby consent to our recording of use of the Website or other communications you may have with our Website.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Fosun, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Website Interaction and Performance Monitoring Tools. Our Website may also use interaction and/or performance monitoring tools (sometimes call tracking scripts or analytics tools). These tools execute code in your web browser to help us collect data about your use of and interactions with the pages and content on our Website. This may include recording your mouse movements, keystrokes, navigation pathways, other actions that you take our Website, and information automatically transmitted from your web browser to our Website such as information about your operating system, computer hardware, and browser preferences. By using our Website, you hereby consent to our recording your mouse movements, keystrokes, navigation pathways, other actions that you take or communications you may have with our Website and other use of such tools.
- Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Website. Google Analytics uses cookies, to help our Website analyze how users use our Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third-parties, including analytics providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
3. How We Use Your Personal Information
We use information that we collect about you or that you provide to us, including any Personal Information:
- to provide and personalize our Website and its content to you;
- to provide you with information, including information regarding Extensive-Stage Small-Cell Lung Cancer, the ASTRIDE ES-SCLC investigational study, insights into unmet treatment needs, and legislative advocacy;
- to support, develop, troubleshoot, and debug our Website, products, and services;
- to personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including via email;
- to help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business;
- for internal testing, research, analysis, and product development, including to develop and improve our Website, and to develop, improve, or demonstrate our products and services;
- for detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- for debugging to identify and repair errors that impair existing intended functionality;
- to notify you about changes to our Website;
- in any other way we may describe when you provide the information;
- to fulfill any other purpose for which you provide it; and
- for any other purpose with your consent.
4. Disclosure of Your Personal Information
We do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Notice. However, we may use or disclose aggregated, deidentified information about our users without restriction.
We may disclose Personal Information that we collect, or you provide as described in this Privacy Notice:
- to our parent, subsidiaries, and affiliates;
- to contractors, service providers, business partners, and other third parties including our data hosting and data storage partners, analytics providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms;
- to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fosun’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Fosun about our Website’s users is among the assets transferred;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Fosun, our customers, or others.
5. Choices About How We Use and Disclose Your Information
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When practicable, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information as confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Information we have collected about you. We have created mechanisms to provide you with control over your Personal Information:
- Cookies. You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, however, if you disable or refuse cookies in this manner, please note that some parts of our Website may then be inaccessible or not function properly. If you do not disable these technologies, you explicitly consent to our use of your Personal Information on our Website in this way.
- Informational Content. By providing your contact information, you are consenting to the use of such information to contact you about issues that may be of interest to you, such as information regarding Extensive-Stage Small-Cell Lung Cancer, the ASTRIDE ES-SCLC investigational study, insights into unmet treatment needs, and legislative advocacy. If you wish to change your choice, you may do so by (1) clicking the unsubscribe link contained in the email you received; or (2) sending us an email stating your request to inquiry@fosunpharmausa.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
6. Accessing, Correcting, and Deleting Your Personal Information
You may send us an email at inquiry@fosunpharmausa.com to request access to, correct or delete any Personal Information that we have collected about you. We may not accommodate a request to change or delete your Personal Information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Information. Please see Jurisdiction-Specific Privacy Rights for more Information.
7. Jurisdiction-Specific Privacy Rights
The law in some jurisdictions may provide you with additional rights regarding our use of Personal Information. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Privacy Notice.
Your California Privacy Rights
If you are a resident of California, you have the additional rights described in the California Privacy Addendum.
Your Texas Privacy Rights
If you are a resident of Texas, you have the additional rights described in the Texas Privacy Addendum.
8. Do Not Track Signals
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
9. Data Security
The transmission of information via the internet is not completely secure. Although we have implemented measures to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website or through our Applications. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.
10. Changes to Our Privacy Notice
We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website’s home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.
Your continued use of our website following the posting of changes constitutes your acceptance to such changes.
11. Contact Information
If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Information described in this Privacy Notice, have any requests related to your Personal Information pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.
Fosun Pharma USA, Inc.
104 Carnegie Center, Suite 204
Princeton, NJ 08540
609-250-2802
Fosun Pharma USA, Inc. Privacy Notice Addendum for California Residents
Last modified: 5/28/2024
1. Introduction
This Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Fosun Pharma USA, Inc.’s (“Fosun” or “we” or “us”) Privacy Notice and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”) and any terms defined in the CPRA have the same meaning when used in this California Privacy Addendum.
This California Privacy Addendum applies to information that we collect as described in our Privacy Notice that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CPRA) are not considered Personal Information and this California Privacy Addendum does not apply to such information.
This California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are part of our California workforce and would like additional information about how we process your Personal Information.
This California Privacy Addendum also does not apply to certain Personal Information that is excluded from the scope of the CPRA, such as the California Confidentiality of Medical Information Act or certain clinical trial data.
2. Information We Collect About You and How We Collect It
Fosun’s Website collects, and over the prior twelve (12) months has collected, the following categories of Personal Information about Consumers:
Personal Information Category
Applicable Pieces of Personal Information Collected
Identifiers.
A real name; telephone number; e-mail address; address; and other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name; address; telephone number; education information; employment information.
Education or employment information.
Education information; employment information.
Internet or other similar network activity.
IP address; browsing history; information on a Consumer’s interaction with a website, application, or advertisement.
Geolocation data.
We collect IP-based information about your physical location or movements. This IP-based information can only identify your physical location or movements to a geographic region, such as town, city, state, and country, but cannot be used to identify your precise physical location or movements.
At your choice, you may also provide additional categories of Personal Information when you contact us or interact with us in person. We will not intentionally collect additional categories of Personal Information without providing you notice.
As further described in To Whom Do We Sell or Share Your Personal Information, we may “sell” any categories of Personal Information for monetary or other valuable consideration; we do not “share” any categories of Personal Information for cross-context behavioral advertising. Under CPRA, “sell” broadly means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information by Fosun to a Third Party for monetary or other valuable consideration. “Share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information by Fosun to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. “Third Party” means a person or entity which is not a Consumer or a Service Provider; “Service Provider” means a person or entity that processes Personal Information on behalf of Fosun and that receives Consumer’s Personal Information from or on behalf of Fosun for a business purpose, pursuant to a written contract meeting CPRA’s requirements.
3. Sources of Personal Information
We collect Personal Information about you from the sources described in our Privacy Notice.
4. Purposes for Our Collection of Your Personal Information
We limit the collection, use, retention, and sharing of Personal Information to that which is reasonably necessary and proportionate to achieve the business purpose for which the Personal Information was collected or processed (for example, please refer to the “How We Use Your Personal Information” and “Disclosure of your Personal Information” sections of our Privacy Notice).
Additionally, pursuant to the CPRA, we may use, “sell” for monetary or other valuable consideration, or disclose the Personal Information we collect. Over the prior 12 months, we have used, “sold” for monetary or other valuable consideration, or disclosed the Personal Information we have collected, for the purposes described in our Privacy Notice as well as the following additional purposes:
- Short-term, transient use, provided the Personal Information that is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Performing services on behalf of Fosun, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
We do not “share” any categories of Personal Information for cross-context behavioral advertising. Fosun will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
5. Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes
Fosun may disclose your Personal Information to Third Parties for one or more business purposes. In the preceding twelve (12) months, Fosun has disclosed the following categories of Personal Information for one or more of the business purposes described below to the following categories of Third Parties:
Personal Information Category
Categories of Third Party Recipients
Identifiers.
Business partners; affiliates, parents, and subsidiary organizations of Fosun.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Business partners; affiliates, parents, and subsidiary organizations of Fosun.
Education or employment information.
Business partners; affiliates, parents, and subsidiary organizations of Fosun.
Internet or other similar network activity.
Analytics services providers.
Geolocation data.
Analytics services providers.
We disclose your Personal Information to the categories of Third Parties listed above for the following business purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity of our products, services, and IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
- Performing services on behalf of us, including providing customer service, providing analytic services, providing storage, or providing similar services on behalf of us.
- Debugging to identify and repair errors that impair existing intended functionality.
- Providing information, marketing services, except for cross-context behavioral advertising, to Consumers, including information regarding Extensive-Stage Small-Cell Lung Cancer, the ASTRIDE ES-SCLC investigational study, insights into unmet treatment needs, and legislative advocacy.
- Undertaking internal research for technological development and demonstration.
In addition to the above, we may disclose any or all categories of Personal Information to any Third Party (including government entities and/or law enforcement entities) as necessary to:
- Comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
- Comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury; or
- Exercise or defend legal claims.
6. To Whom Do We Sell or Share Your Personal Information
“Sale” of Your Personal Information for Monetary or Other Valuable Consideration
We do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of analytics cookies on our Website is considered a “sale” of Personal Information as the term “sale” is broadly defined in the CPRA to include both monetary and other valuable consideration. Using this broad definition, our “sale” is limited to our use of third-party analytics cookies and their use in understanding how people use and interact with our Website(s). Our “sales” of your Personal Information in this matter is subject to your right to opt-out of those sales (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information).
In the preceding twelve (12) months, Fosun has “sold” for monetary or other valuable consideration the following categories of Personal Information to the following categories of Third Parties:
Personal Information Category
Categories of Third Parties To Whom Your Personal Information is Sold
Internet or other similar network activity.
Analytics services providers.
Geolocation data.
Analytics services providers.
“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising
Fosun does not “share” your Personal Information for the purpose of cross-context behavioral advertising.
Sale or Sharing of Personal Information of Minors Under the Age of 16
We do not have any actual knowledge that we “sell” the Personal Information of minors under the age of 16 for monetary or other valuable consideration and we do not have any actual knowledge that we “share” such Personal Information for cross-context behavioral advertising without affirmative consent as required by the CPRA. More information on how minors under the age of 16 may change their choice regarding the “sale” or “sharing” of their Personal Information can be found in Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.
7. Consumer Data Requests
The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CPRA Privacy Rights.
- Right to Know. You have the right to request that Fosun disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” Consumer Request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information came from; (c) our purposes for collecting this Personal Information; (d) the categories of third parties with whom we have shared your Personal Information; and (e) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
- Access to Specific Pieces of Information (Data Portability). You also have the right to request that Fosun provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third party about you (a “Data Portability” Consumer Request). If you make a Data Portability Consumer Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. We will not disclose any Personal Information that may be subject to another exception under the CPRA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
- Correction. You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may request that we correct the Personal Information we have about you as described below under Exercising Your CPRA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Information is subject to another exception under the CPRA.
- Deletion. You have the right to request that Fosun delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Consumer Request (see Exercising Your CPRA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CPRA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.
- Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not do any of the following as a result of you exercising your CPRA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CPRA Privacy Rights
To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:
- Calling us at: 609-250-2802
- Emailing us at: inquiry@fosunpharmausa.com
If you fail to make your Consumer Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.
Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.
All Consumer Requests must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent. Making a Consumer Request does not require you to create an account with us. We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.
Authorized Agents
You may authorize your agent to exercise your rights under the CPRA on your behalf by providing them with written authorization or with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized to exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
8. Your Choices Regarding our “Sale” of Your Personal Information
“Sale” of Your Personal Information
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information for monetary or other valuable consideration at any time (the “right to opt-out”). We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
How You May Opt-Out of Our Sale of Your Personal Information
Fosun does not ‘sell’ your Personal Information in exchange for money. However, we will, in this space, offer services imminently permitting you to opt out of any such sale or sharing of your Personal Information.
9. Personal Information Retention Periods
We will keep your Personal Information for no longer than is necessary for the purpose(s) it was provided for. Further details of the periods for which we retain Personal Information are available on request. However, we may retain any or all categories of Personal Information when your information is subject to one of the following exceptions:
- When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated;
- When necessary for us to exercise or defend legal claims;
- When necessary to comply with a legal obligation;
- When stored in the same document or record with other Personal Information. Your Personal Information will be deleted upon the expiration of the last exception that applies to such document or record; or
- When necessary to help ensure the security and integrity of our Website and IT systems.
10.Changes to This California Privacy Addendum
Fosun reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
11.Contact Information
If you have any questions or comments about this California Privacy Addendum, the ways in which Fosun collects and uses your information described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 609-250-2802
Email: inquiry@fosunpharmausa.com
Postal Address: Fosun Pharma USA, Inc.
104 Carnegie Center, Suite 204
Princeton, NJ 08540
Fosun Pharma USA, Inc. Privacy Notice Addendum for Texas Residents
Last modified: 5/28/2024
1. Introduction
This Privacy Addendum for Texas Residents (the “Texas Privacy Addendum”) supplements the information contained in Fosun Pharma USA, Inc.’s (“Fosun” or “we” or “us”) Privacy Notice and further describes our collection and use of Personal Information (as defined below). This Texas Privacy Addendum applies solely to all visitors, users, and others who reside in Texas (“Consumers” or “you”). We adopt this Texas Privacy Addendum to comply with the Texas Data Privacy and Security Act (“TDPSA”) and any terms defined in the TDPSA have the same meaning when used in this Texas Privacy Addendum. We may update this Texas Privacy Addendum at any time as necessary in the event of changes to the TDPSA.
This Texas Privacy Addendum applies to information that we collect as described in our Privacy Notice that is linked or reasonably linkable to an identified or identifiable individual, including pseudonymous data used in conjunction with additional information that reasonably links the data to an identifiable individual (“Personal Information”). However, publicly available information that we collect from government records and deidentified data (when deidentified as described in the TDPSA) are not considered Personal Information and this Texas Privacy Addendum does not apply to such information.
2. Personal Information We Collect and Disclose About You
The following chart outlines the Personal Information that we may collect about you and the categories of third parties to whom we may disclose your Personal Information.
Personal Information We Collect
Categories of Third Parties to Whom We Disclose Personal Information
Identifiers, such as name, e-mail address, telephone number, and address.
Business partners; affiliates, parents, and subsidiary organizations of Fosun.
Education or employment information, such as education information and employment information.
Business partners; affiliates, parents, and subsidiary organizations of Fosun.
Internet or network activity information, such as IP address, browsing history, and interactions with the Website.
Analytics services providers.
Geolocation data. We collect IP-based information about your physical location or movements. This IP-based information can only identify your physical location or movements to a geographic region, such as town, city, state, and country, but cannot be used to identify your precise physical location or movements.
Analytics services providers.
Fosun will not collect additional categories of Personal Information without providing you notice.
Sources of Personal Information
We collect the categories of Personal Information listed above from you, operating systems and platforms, our affiliates and subsidiaries, and others as permitted by law.
Processing of Your Personal Information
We limit the collection of Personal Information to what is adequate, relevant, and reasonably necessary in relation to the purposes for which the Personal Information is processed. We may process the Personal Information we collect, for one or more of the purposes described in our Privacy Notice (for more information, see How we use the Personal Information we collect). We will not process Personal Information for purposes that are neither reasonably necessary to nor compatible with the purposes for which the Personal Information is processed as described in our Privacy Notice without your consent.
We do not knowingly process the Personal Information of minors under 18 years of age without parental or lawful guardian consent.
Sale of Personal Information
The TDPSA defines the sale of Personal Information as the “sharing, disclosing, or transferring of personal data for monetary or other valuable consideration by the controller to a third party.” Although we do not monetize your Personal Information, we may disclose Internet or network activity information and Geolocation data to data analytics providers for the following purposes, which could be deemed to be a “sale” of Personal Information under the TDPSA:
- Analytics, measurement, and improvement; and
- Customization and personalization.
You may opt-out of certain sales as described below.
3. Your Rights and Choices
The TDPSA provides Texas residents with specific rights regarding their Personal Information. This section describes your TDPSA rights and explains how to exercise those rights. For more information on how you can exercise your rights, please see Exercising Your TDPSA Privacy Rights.
Confirmation and Access
You have the right to confirm whether we process your Personal Information and to request access to that Personal Information we have collected and maintain about you. You may exercise this right as described below.
Correction
You have the right to correct any inaccuracies in your Personal Information processed by us, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information. We may also not be able to accommodate your request to change the Personal Information if we believe it would violate any law or legal requirement or cause the Personal Information or the information associated with the Personal Information to be incorrect.
Deletion
You have the right to request that we delete your Personal Information. We cannot delete your Personal Information except by also deleting your user account, however we may not accommodate a request to erase your Personal Information if we believe the deletion would violate any law or legal requirement or cause any information associated with the Personal Information to be incorrect.
Portability
To the extent we maintain your Personal Information in a digital format, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Information in portable, and to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another controller without hindrance.
Opt-Out of Certain Processing
To the extent applicable, you have the right to opt-out of processing your Personal Information for the purposes of: (i) targeted advertising; (ii) the sale of your Personal Information; or (iii) profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer. For more information on how to Opt-Out, please see How You May Opt-Out of the Sale of Your Personal Information. You may exercise this right yourself or through your Authorized Agent.
Please note, however, that Fosun does not process Personal Information for purposes of targeted advertising or profiling within the meaning of the TDPSA.
4. Exercising Your TDPSA Privacy Rights
To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:
- Calling us at: 609-250-2802
- Emailing us at:inquiry@fosunpharmausa.com
- Writing to us at: Fosun Pharma USA, Inc., 104 Carnegie Center, Suite 204, Princeton, NJ 08540
Personal information provided in response to a request to exercise these rights may be provided free of charge at least twice per Texas resident annually. If applicable, you may also make a Consumer Request on behalf of your minor child. For requests to opt out, you may also authorize an Authorized Agent to make the request on your behalf. To designate an Authorized Agent, see Authorized Agents below.
All Consumer Requests must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person. This may include:
- Verifying Personal Information that we may already have about you, such as your name, address, telephone number, and/or other similar information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We are unable to fulfill your request or provide you with Personal Information if we cannot authenticate that the Personal Information that is the subject of your request relates to you through commercially reasonable efforts. In this case, we may request additional information, which we will only use to authenticate you.
Making a verifiable consumer request does not require you to create a password-protected, online account with us.
Response Timing and Format
We will generally process these requests within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. If we cannot comply with your request, we will provide you with an explanation of the reasons we cannot comply with a request.
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.
Appeals Process
You may appeal a refusal by us to take action on your request to exercise any of the above rights within a reasonable period of time after we provide you notice of such refusal by contacting us through the contact information listed below.
Within 45 days after we receive your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including any explanations for the reasons for the decision. If your appeal is denied, you may lodge a complaint with the Texas Attorney General available at: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.
Non-Discrimination
We will not discriminate against you for exercising any of your TDPSA rights. Unless permitted by the TDPSA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services.
- Provide you a different level or quality of goods or services.
Authorized Agents
You may authorize your agent to exercise your right to opt out under the TDPSA. We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
How You May Opt-Out of the Sale of Your Personal Information
To exercise the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration, you (or your Authorized Agent) may click the link on our homepage, “Do Not Sell or Share My Personal Information.” You can find more information about cookies at http://www.allaboutcookies.org.
Your Privacy Choices
You do not need to create an account with us to exercise your opt-out rights. You may be required to provide us with additional contact information so that we may verify your request. We will only use Personal Information provided in an opt-out request to review and comply with the request.
Personal Information of Children
Fosun understands the importance of protecting children’s privacy in the interactive online world. Our Website is not designed for, or intentionally targeted at, children under 18 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 18. No one under the age of 18 should submit any Personal Information on our Platform, and if we learn that we have collected or received Personal Information from a child under 18, we will delete that information. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided us with their Personal Information, you may contact us to request the Personal Information be deleted.
5. Changes to This Texas Privacy Addendum
Fosun reserves the right to amend this Texas Privacy Addendum at our discretion and at any time. When we make changes to this Texas Privacy Addendum, we will post the updated addendum on the Platform and update the addendum’s effective date. If we make a material change to this Texas Privacy Addendum, we will email you at the email address listed in your online account.
Your continued use of our Platform and Services following the posting of changes constitutes your acceptance of such changes.
6. Contact Information
If you have any questions or comments about this Texas Privacy Addendum, the ways in which Fosun collects and uses your information described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under Texas law, please do not hesitate to contact us at:
Phone: 609-250-2802
Email: inquiry@fosunpharmausa.com
Postal Address: Fosun Pharma USA, Inc.
104 Carnegie Center, Suite 204
Princeton, NJ 08540