(Updated and Effective: August 2018)
DISCLAIMER: The content appearing on Tolero websites or web-based resources is presented exclusively for informational purposes. You understand and agree that Tolero does not use this site to provide medical advice, financial advice, or legal advice. You will not rely on any statements made on this site as though it were professional advice. The site may provide selected information concerning diseases and their treatment. Such information is not intended nor provided as medical advice. Such information is not a substitute for the advice of a trained health care professional. If you have or suspect having any health problems or conditions, you should consult your general practitioner or other qualified health provider.
1. WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT AND USE IT?
Information You Provide: Certain areas of our websites and online resources allow you to submit your information to us. We may collect information that either directly identifies you or could reasonably be used in combination with other publicly available information to identify you, including your name, contact information, email address, and other information in combination with such identifiers. We may use and disclose the information you provide to send you requested information or other information we think may be of interest to you (including marketing communications), respond to your inquiry, improve our website, verify your relationship with us, and/or take other actions that may be necessary to respond to your request or fulfill the terms of a contract we have with you. We also use this information within Tolero to improve our products and communications, or to develop new products, services, and communication strategies.
Information We Collect Automatically: We also automatically collect other basic information about you which does not directly identify you but which may correspond with you, your browser, or a particular device. This may include your internet protocol address, your internet service provider, information about cookies in your browser, geographic location and your software and hardware attributes (e.g., browser and device type). We also automatically collect information about how you interact with our website, including the duration of your visit, the actions you take, the pages you view, the time spent on our site, the top search terms used, and the most effective ad traffic campaign drivers. We use and disclose the information we automatically collect to learn more about how our website and online resources are used and to otherwise improve and administer the site. We also use and disclose this information to enable us to deliver information and advertisements tailored to your interests and preferences, based on your use of the site. Please see the section titled “Analytics and Marketing,” below, for more details. We automatically collect information using the techniques described below:
Cookies. Our website may use a tracking technology called a “cookie.” A cookie is a small data file that a website can place on your computer’s hard drive, where your internet browser files are kept. Cookies enable a site to “remember” the information a visitor has previously inputted, or in some cases, certain other sites that the user has visited. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. Further information concerning the use of third-party cookies on our site can be found below, in the section titled “Analytics and Marketing.”
Web Beacons. On certain web pages or in emails we send to you, we may utilize a technology called a “web beacon” (also known as an “action tag” or “clear GIF technology”). We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.
Social Plugins. This site may use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit our site, the operator of the social plugin may be able to place a cookie on your computer, which enables that operator to recognize individuals who have previously visited our site. If you are logged into the associated social media website (e.g., Facebook) before browsing on our website, the social plugin allows that social media website to receive information about your visit to particular pages on our website. The social plugin may collect this information for any such visitors who have logged into social networks, whether or not they specifically interact with the plugin on our website (e.g., by clicking “Like” or “Share”). The social plugin may also allow the social media website to share information about your activities on our website with other users of their social media website. For more information about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.
Analytics and Marketing
Opting Out of Certain Analytics and Marketing Activities
The Digital Advertising Alliance maintains a website where consumers can opt-out from receiving interest-based advertising from some or all of the advertising companies participating in the program (www.AboutAds.info/choices/). The Network Advertising Initiative also maintains an opt-out page (http://optout.networkadvertising.org) where consumers can opt-out of receiving interest-based advertisements from companies participating in that program.
You may find information about Google Analytics and Google’s privacy notice by visiting Google’s website here: www.google.com/policies/privacy/partners/. If you would like to opt-out of having your data used by these cookies, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/. This opt-out applies only to Google Analytics and will not affect the functioning of other forms of analytics.
Combining Information: Where permitted by law, we may combine the information we collect automatically with other information you share with us through this website. Where permitted by law, we may also combine information collected through our website and online resources with Tolero’s offline records and information provided by third parties. We use this consolidated information to improve our website and online resources, enhance our marketing activities, better design our offerings, and facilitate other business functions.
Our Response to Do Not Track Signals: Certain web browsers and other programs may be used to signal your preferences to Tolero about how or whether Tolero or third parties may collect information about your online activities. Currently, our websites and online resources do not respond to such signals.
2. DOES TOLERO DISCLOSE YOUR INFORMATION TO THIRD PARTIES?
We disclose the information we collect through our websites, as described in this notice.
Affiliates: We may share the information we collect with our affiliates, including our parent company, our subsidiaries, and other affiliated entities.
Service Providers: We may disclose information to third parties who provide us with various business services, including monitoring and maintaining the website and preparing newsletters and mailings for the purposes described in this notice.
Business Partners: We may also share information with third parties with whom we are working to provide you with services or information.
Legal Purposes: We may also disclose information we collect in special cases, including when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interfering with our rights and property or those of any other person. We may also disclose information when we believe the law requires it and in any situation that involves threats to any person’s physical safety. We also disclose information where required by law, including when required by laws, court orders, or government regulations.
Transactions Involving Tolero: If all or part of Tolero is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no information that is transferred will be used or shared in a manner inconsistent with this notice without your consent. Your information may also be included among the assets affected by financing agreements undertaken by Tolero. Your continued use of this website would, however, signify your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.
Aggregated Information: Tolero may share aggregated or de-identified information about use of our sites for any lawful purpose, but such information will not identify you or any other individual personally.
3. WILL TOLERO TRANSFER YOUR INFORMATION INTERNATIONALLY?
Our website and online resources are owned and operated in the United States, but the information you provide may be accessible by our affiliates and vendors in other countries. If you are visiting this site from a country other than the United States, your information will cross an international boundary. The level of protection for your information in the United States may not be the same as the level of protection in your country. By using this site, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.
4. IS THE WEBSITE INTENDED FOR CHILDREN?
Our website and online resources are not intended for children. We do not knowingly collect personally identifiable information from children under 13 years of age. However, if the parent or the guardian of a child has reason to believe that a child under 13 has provided us with personally identifiable information, the parent or guardian of that child should contact us at this form to request deletion of this data from our files. Anyone under 18 years old should seek their parent’s or guardian’s permission prior to disclosing any personally identifiable information to Tolero.
5. HOW CAN YOU CONTROL AND UPDATE YOUR PERSONAL INFORMATION WITH TOLERO?
Tolero wants to keep only accurate information about you.
Updating or Correcting Your Information:To update or correct your contact information, please contact us at this form.
6. HOW DOES TOLERO KEEP YOUR INFORMATION SECURE?
Tolero takes certain steps to protect your information from unauthorized access. However, no internet transmission is ever completely secure or error free. In particular, emails sent using this website or another online resource may not be secure. You should take special care before deciding to send us information via email. If you create an account on Tolero’s site, it is your responsibility to protect your access credentials from unauthorized access or use.
7. IS TOLERO RESPONSIBLE FOR THE WEBSITES IT LINKS TO?
We are not. We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy notice does not apply to any sites that are not affiliated with Tolero, even if you access them via a link on our site. You should review the privacy policies of any third-party site before providing any information.
8. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have any questions or concerns about the way your information is used and handled, please contact us at this form, or write to:
In care of: Sunovion Pharmaceuticals Inc.
Attn: Data Protection Officer, Legal Affairs
84 Waterford Drive
Marlborough, MA 01752
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to the address provided above. Be sure to include your name and address. If you would like a response via email, please include an email address. Otherwise, we will respond by postal mail within the time required by law.
9. WHAT ELSE DO YOU NEED TO KNOW?
We reserve the right to amend this policy at our discretion. When changes are made, we will post the updated policy and the date of the revision. By continuing to use the Tolero web site after the posting of such changes, you accept the Policy as modified.
Our Policy on Cookies and Other Tracking Technologies
Cookies save you the trouble of reentering certain information in some registration areas, help to deliver content-specific information to you, and track which sections of the site are most popular. A “cookie” is actually a file that our web server or the web server of one of our third-party partners may send to your computer when you access one of our sites. This file is then stored on your computer.
How does our site respond to web browser “Do Not Track” signals?
Certain web browsers and other programs may be used to signal your preferences to Tolero about how or whether Tolero or third parties may collect information about your online activities. Currently, our web sites and online resources do not respond to such signals.
What choices do you have about cookies?
The Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).
Your California Privacy Rights: California Civil Code Section 1798.83, permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to the address provided above. Be sure to include your name and address. If you would like a response via email, please include an email address. Otherwise, we will respond by postal mail within the time required by law.
9. WHAT ELSE DO YOU NEED TO KNOW?
We reserve the right to amend this notice at our discretion. When changes are made, we will post the updated notice and the date of the revision. By continuing to use the Tolero website after the posting of such changes, you accept the notice as modified.