IRONSHORE PRIVACY POLICY


EFFECTIVE DATE: July 2022

Ironshore ("we," "us," or "our") values your privacy. This Privacy Policy ("Policy") describes how we collect, use, and disclose information that we obtain about visitors to any Ironshore operated websites on which this Policy is posted (each a “Site”), Sites that post a link to this Policy, services available through our Sites (collectively, the "Services"), or applications owned or controlled by Ironshore.


By visiting the Sites, or using any of our Services, you agree that your Personal Information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Ironshore Terms of Service are incorporated by reference into this Policy.


Personal Information Ironshore Collects


Personal Information you provide to us:


From Sites or Events: We may collect Personal Information that you choose to send to us or provide to us; for example, if you are a health care provider, to register and receive more information, we may ask for your name, email address, mailing address, and health care provider unique identifier (eg, NPI). If you are a consumer user, we may ask for your name, email address, mailing address, and information about your current treatment program. Similar information may be collected if registering to attend an Event directly through our Sites. If you contact us through our Sites, we will keep a record of our correspondence.


Personal Information we automatically collect:

We may automatically collect the following information about your use of our Sites or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system, and the language settings on your browser; web pages you view; links you click; your device’s IP address and your general location (city and country); the length of time you visit our Sites and/or use our Services; and the referring URL, or the webpage that led you to our Sites.  We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other Personal Information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information. We may also rely on analytics and tools used to prevent spam and other security risks related to the use of abusive automated software. 


Personal Information collected from third parties:

In addition to information we collect directly from you, we may also collect information about you from third-party sources. The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies. Be sure to check those policies and adjust your settings to meet your preferences.

How we use Your Personal Information

We will use your Personal Information we collect through our Sites:

  • For purposes detailed at the time you submitted your Personal Information, for example, to receive requested information, issue updates, newsletters, or promotions, and/or provide credentialed access to an online event.
  • To improve our Sites and enhance user experience through content presentation, location customization, and personalized help and instructions.
  • For trend monitoring, marketing, and advertising.
  • To better understand how users access and use our Sites and Services for research and analytical purposes.
  • To administer surveys and questionnaires.
  • To protect our own rights and interests, such as resolving any disputes, enforcing our Terms of Service, or responding to legal process.

How we Share Your Personal Information

We may share your Personal Information with third-party vendors, consultants, and other service providers we employ to perform tasks on our behalf, but only in ways described in this Policy. Companies that assist us with website analytics, tools used to prevent spam and other security risks, online activities, and CRM services are examples of third parties we may share Personal Information with. While we will share your Personal Information with third parties only in ways described in this Policy, under no circumstances does Ironshore sell your Personal Information in exchange for monetary consideration.

Your Personal Information may be shared in the following limited circumstances:

  • Affiliates: We may disclose the information we collect from you to our affiliates and subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
  • Third Parties: We may disclose the information we collect from you to our third-party partners for use in patient programs, joint marketing efforts, etc.
  • Service Providers: We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf.
  • Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information, including Personal Information, in connection with the evaluation of and entry into such transactions. Similarly, if we or our assets are acquired, or if we must engage in bankruptcy proceedings, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by a third party.
  • In Response to Legal Process: We may need to disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, eg, in response to a court order or subpoena.
  • To Protect Us and Others: We may disclose the information we collect from you in response to an investigation, or to prevent/take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Ironshore is involved.
  • Aggregate and De-Identified Information: We do conduct research or analysis on users’ demographics, interests, and behaviors based upon information provided to us during use of our Site and Services. We may combine your information with information collected from other individuals to produce anonymous, aggregated statistical information. Aggregated data does not include personally identifiable information. We use this demographic information, such as the percentage of visitors within certain age brackets, to improve content. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.

How Long we Store Your Personal Information

We store your Personal Information for different time periods depending on the category of Personal Information. Some information may be deleted automatically based on specific schedules, such as marketing information. We may retain information for business practices based on our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, or enforcing our legal rights.

Our Use of Cookies and Other Tracking Mechanisms

Cookies. Cookies are alphanumeric identifiers that are stored on a user’s computer or device by the website or application for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities on our Site and Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. You can update privacy and security settings on your device to, for example, hide your IP address from trackers or block all cookies. The Help portion of the toolbar on most browsers will tell you how to control cookies through that browser. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function. Learn More

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive or device, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags) in connection with our Services to, among other things, track the activities of Site visitors and users, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and, to the extent permitted, our applications. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your name and contact information with these third-party analytics providers.

Do Not Track. Do not track (DNT) is a preference you can set in your web browser to let websites you visit know that you do not want to be tracked. You can disable or enable this setting by visiting the preferences settings menu of your web browser. Currently, some of our Sites do recognize DNT requests while others do not. You may, however, disable certain tracking as discussed in this section (eg, by disabling cookies). You may also opt-out of targeted advertising by following the instructions under the “Interest-based Advertising” section of this Policy.

Interest-based Advertising

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (eg, social networking platforms). This enables us and these third parties to target advertisements for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including limited Personal Information, so that they can better target you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI   will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Sites or on other websites. You may continue to receive advertisements, for example, based on the website that you are viewing (ie, contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.


Social Media Features


Our Sites and application may include social media features, such as Facebook “Like” button and widgets, such as “Share This Button,” that run on our website or application. These features may collect your IP address, which page you are visiting on our Site or application and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or directly on our Site or application. Your interactions with these features are governed by the Privacy Notice of the company providing it.

Third-Party Links

Our Sites and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead governed by the privacy policies of those third-party websites. We are not responsible for the information practices of these websites. We do not endorse any of these linked sites, the services or products described or offered on such linked sites, or any of the content contained on the linked sites. We encourage you to seek out and read each linked site’s privacy notices to understand how the Personal Information about you is used and protected.

Security of my Personal Information

We have implemented safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.  

Access to my Personal Information

If you’d like to update your contact information with us, please email privacy@ironshorepharma.com. Our privacy office will examine your request and respond to you as quickly as possible. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Sites for a period of time. We may also still use any aggregated or de-identified Personal Information that does not identify any individual and may use your Personal Information as necessary to comply with our legal obligations and resolve disputes.


California residents: California residents have specific rights under the California Consumer Privacy Act. For more information and to exercise your rights, please see section titled “Your California Privacy Rights - The California Consumer Privacy Act” below.

Communications Choices


We may send periodic promotional emails to you. You may opt-out of such promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Children Under 13

Our Services are not designed for children under 13 and we do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not send any Personal Information about yourself to us. If you believe that we might have any information from or about a child under 13, please contact us at privacy@ironshorepharma.com. If we discover that a child under 13 has provided us with Personal Information, we will delete such information from our systems.

Your California Privacy Rights – The California Consumer Privacy Act (“CCPA”)

Under the CCPA, California residents have certain rights regarding the Personal Information businesses have about them. This includes the rights to request access or deletion of your Personal Information, as well as the right to direct a business to stop selling your Personal Information.

Personal Information disclosed for business purposes:

Ironshore shares and has shared in the preceding 12 months personal information as necessary for specific “business purpose” as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and specified in the section “How we Share Your Personal Information” This includes sharing personal identifiers, commercial information, customer relationship management, consulting, email, and feedback. While Ironshore does not sell Personal Information in exchange for any monetary consideration, we do share Personal Information for other reasons that could be deemed a “sale,” as defined by CCPA (Cal.Civ.Code 1798.140(t)(1)). This includes sharing personal identifiers and commercial information with advertising networks, website analytics companies, and CRMs.

CCPA Rights

Right to opt-out of sale: You have the right to direct Ironshore not to sell, or for our purposes, share, your Personal Information. With respect to cookies, you can always customize your settings at any time. Please note that we may still use aggregated and de-identified Personal Information that does not identify you or any individual. We may also retain Personal Information as needed to comply with legal obligations, enforce agreements, and resolve disputes.

Right to request disclosure: You have the right to request disclosure about what categories of Personal Information Ironshore has disclosed for a business purpose about you and the categories of their parties to whom the Personal Information was disclosed. Below is a complete list of the Personal Information you can include in your request:

  • Categories of Personal Information Ironshore has collected about you
  • Categories of sources from which Ironshore collected Personal Information
  • The business or commercial purpose for collecting or sharing Personal Information
  • Categories of third parties with whom Ironshore shares Personal Information
  • Specific pieces of Personal Information Ironshore has collected about you
  • Categories of Personal Information that Ironshore disclosed about you for business purposes

If you would like to exercise your right to request disclosure, please submit the following information to privacy@ironshorepharma.com and our team will review and respond as quickly as possible (allow up to 30 days for a response):

  • Confirmation you are a California resident
  • Type of user, ie, platform user, marketing recipient, authorized agent, employee, etc.
  • Country
  • First and last name
  • Email address
  • Request Details

Right to non-discrimination: Ironshore will not discriminate against you for exercising any of the rights afforded to you.

Handling your requests: Ironshore is committed to responding to verifiable consumer requests within the required timeframes. If more time is needed to process your request, we will inform you of the reason and extension period in writing via email or mail, whichever is preferred. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, our response will include an explanation regarding why we are unable to comply with a request. Ironshore does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or clearly unfounded. If we determine that a request warrants a fee, we will inform you of this decision and provide a cost estimate prior to completing the request.

California and Delaware DNT Disclosures

California and Delaware law require us to indicate whether it honors your browser’s DNT settings concerning targeted advertising. Currently, some of our Sites do recognize DNT requests while others do not.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:

Ironshore

Attn.: Compliance

430 Davis Drive, Suite 250

Morrisville, NC 27560

Privacy Office: privacy@ironshorepharma.com

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will inform you of material changes to this Policy by either placing a notice on our Site and/or sending an email if you have registered your email with us when we are required to do by applicable law.

Have a question, contact us today.

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