Effective Date: December 9, 2019
1. INFORMATION WE COLLECT
A. Types of Information We Collect
Galderma collects information from you when you use the Services and when you choose to share information with us. This may include “Personal Information” such as: your biographical information (e.g., name, address, email address, user name, telephone or mobile number, date of birth, or gender); user-generated content (e.g., ratings, reviews, comments, video, audio containing your image or voice, or call history); financial account information (e.g., to process payments); geo-location information; unique user identifiers (e.g. VoIP identifier, instant messaging ID, video chat identifier, or social networking login information, third party platform login information); medical or other health related information; and aesthetic information (e.g. treatment history, loyalty program history, treatment date, treatment type, treating healthcare professional). If you apply for a job at Galderma, we will ask for additional personal information, such as your social security number, government-issued identification number, and job history.
B. Information Automatically Collected
Additionally, whenever you visit or interact with the Services, Galderma or its third-party advertisers and/or service providers, may use a variety of technologies such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies to automatically or passively collect information about your online activity. We may automatically collect the following information about you:
- Computer or Device Information. We may automatically collect your Internet Protocol (“IP”) address or other unique identifiers or information from the computer, mobile device, tablet, or other device you use to access the Services, including but not limited to your browser type, device type, operating system, software version, phone model, phone operating system, carrier information, and the domain name from which you accessed the Services.
- Usage Information. We may collect information about your use of the Services, including the date and time you visit the Services, the areas or pages of the Services that you visit, the amount of time you spend viewing or using the Services, the number of times you return to the Services, other click-stream or usage data for the Sites or Apps, emails that you open, forward or click-through to our Services, and other sites that you may visit.
- Use of Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools to better understand who is using the Sites or Apps, how people are using the Sites or Apps, how to improve the effectiveness of the Sites or Apps and related content, and to help us or those third parties serve more targeted advertising to you across the Internet. These tools may combine information from your interaction with the Sites or Apps with information collected from other sources.
To learn more about your advertising choices relating to the collection and use of your information, please see the “Your Choices and Opt-Outs” section below.
C. Information Collected From Other Sources
We may acquire information about you from other sources, such as healthcare professional or select third parties (i.e. business partners, service providers, analytics vendors, and advertising networks). We may use this information to help us maintain the accuracy of the information we collect, prevent fraud, personalize your experience with the Services, target our communications so that we can inform you of our or third party products, services or other offers that may be of interest to you, measure ad quality and responses, and administer the ASPIRE Program; and for other business purposes. We may also combine information about you that we receive from third parties with other information about you that we collect when you use the Services or that you choose to share with us.
2. INFORMATION USE
A. Use by or for Galderma
Galderma may use the information we collect from and about you for the following business purposes:
- To provide you with the Services;
- To fulfill our contractual obligations;
- To respond to your inquiries, fulfill orders, contact and communicate with you when necessary;
- To review the usage and operations of our Sites, Apps, and the ASPIRE Program, develop new products or services, improve the Services, and conduct analyses to enhance or improve our content, products, and services;
- To use and disclose your payment or banking information only to process payments and prevent transactional fraud; and
Galderma may use the information we collect from and about you for the following commercial purposes:
- To administer the ASPIRE Program;
- To provide you with customized content or targeted offers;
- To provide you with information, newsletters and promotional materials from Galderma and, or on behalf of, our marketing partners and affiliates; and
- To use your data in an aggregated non-specific format for analytical and demographic purposes;
Galderma may use information you provide to us for the following additional purposes:
- For other purposes disclosed at the time you provide your information or otherwise with your consent.
Additionally, if you use the Services to connect with third party services, you authorize us to use information from and about you, on your behalf, to interact with these third party services based on your requests.
B. How We Use Your Information for Interest-Based Advertising
For information on your choices with respect to interest-based ads, see the “Interest Based Advertising Choices” section below.
3. INFORMATION WE SHARE WITH OTHERS
We may share your personal information with the following:
- Service Providers: We may share your information with third party service providers that provide business, professional, or technical support functions for us, help us operate our business and the Services, or administer activities on our behalf.
- Healthcare Professional: To administer the ASPIRE Program, we may share your information (including your aesthetic information) with your healthcare professional.
- Select Third Parties: We may share your information with our select partners, affiliates, your healthcare professional(s) and other third parties for their business, operational, promotional, and marketing purposes. These entities’ use of such information is subject to their respective privacy policies. To learn more about your advertising choices relating to the collection and use of your information, please see the “Your Choices and Opt-Outs” section below.
4. YOUR CHOICES AND OPT-OUTS
A. Use of Tracking Cookies
Certain parts of our Sites and Apps require cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features of the Services or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.
B. Interest-Based Advertising Choices
To understand your choices for receiving more relevant advertising provided on the Service or across other websites and online services, please review the information below:
- To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info.
- To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.
Even if you opt out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third parties if they are not a DAA participating company.
C. Unsubscribing from our Marketing Communications
We provide you with the opportunity to opt-out of email marketing communications. To do so, you may:
- Send us an email at unsubscribeUS@galderma.com ;
- Contact us by mail at the address below in the “How to Contact Us” section; or
- Unsubscribe from our email communications at any time by following the instructions contained within the email.
Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties or affiliates with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
5. YOUR CALIFORNIA PRIVACY RIGHTS
A. Your Rights
If you are a California resident, you may take advantage of the following rights:
- You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information that we sold about you, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable. We will respond to your request within 45 days unless we need additional time, in which case we will let you know.
- Subject to certain exceptions, you may request that we delete any personal information that we have collected from you. Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.
- You may request, up to one time each year, information about our sharing of personal information about you with third parties for the third parties' direct marketing purposes. You have the right to opt out of Galderma’s sale of your Personal Information to third parties, and to our affiliated companies that do not share the same brand name, for their direct marketing purposes. Non-affiliated third parties are independent from Galderma and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.
To make such requests, please contact us using our webform, at 1-866-735-4137 extension 7, or by mail at the address in the “How to Contact Us” section below. You must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us.
If you exercise any of the foregoing rights, we will not discriminate against you, such as by denying you access to our products or restricting your access to products of certain pricing or quality.
B. Personal Information Collection and Disclosures
- Identifiers/Biographical Information: These include your name, postal and email address, phone number, unique identifiers.
- Commercial information: Your purchase and usage history, and preferences.
- Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or Galderma advertising.
- Profile Inferences: The inferences that we draw from your information and web activity to create a personalized profile so we can better identify goods and services that may be of interest.
- Financial Information: This includes your bank card and credit card information used to process payments.
- Medical/Health Insurance/Aesthetic Information: This includes treatment history, loyalty program history, treatment date, treatment type, treating healthcare professional.
Categories of Personal Information Sold
- In the last 12 months (from the Effective Date listed at the top of the Policy), Galderma has sold the following categories of personal information: None.
- Galderma does not sell the personal information of consumers under the age of 16 years.
Categories of Personal Information Disclosed
- In the last 12 months (from the Effective Date listed at the top of the Policy), Galderma has disclosed the following categories of personal information for a business purpose: Identifiers/Biographical Information, Commercial Information, Internet/Electronic Activity, Profile Inferences, Financial Information associated with you, and Medical/Health Insurance/Aesthetic Information associated with you.
6. EXTERNAL LINKS
The Site may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
7. PUBLICATION OF USER SUBMISSIONS
Any information you may disclose on our Sites or Apps (e.g., ratings and reviews), in blogs, on message boards, in chat rooms, on social media, or in other public areas becomes public information. Please exercise caution when disclosing personal information in these public areas, including personal health information.
8. CHILDREN’S PRIVACY
We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of 16. If Galderma learns that a child under the age of sixteen has provided personally identifiable information, we will use reasonable efforts to remove such information from our files.
10. HOW TO CONTACT US
Galderma Laboratories, L.P.
14501 North Freeway
Fort Worth, TX 76177
Attention: Chief Privacy Officer