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Healthcare Professionals Privacy Notice

Last Updated on February 8, 2024 

Arrowhead Pharmaceuticals, Inc. (“Arrowhead”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Notice for Healthcare Professionals (“HCPs”, “you”, or “your”) (“Privacy Notice”) describes our practices regarding the collection, use, and disclosure of your Personal Information (as defined below) when you visit our websites (including arrowheadpharma.com) (collectively, the “Website”), and interact with us offline. This Privacy Notice also describes your privacy rights in connection with Personal Information we collect about you, including the rights of California residents and individuals located in the European Economic Area (“EEA”) or the United Kingdom (“UK”).

This Privacy Notice will not apply to Personal Information collected and processed by us:

  • should you participate in a clinical trial that we sponsor;
  • if you are an individual other than a HCP;
  • should you apply for a job with us; or
  • in the course of your employment with us.

By accessing the Website, you agree to our Terms of Use the collection and use of your Personal Information as described in this Privacy Notice.  However, this does not equate to consent for the processing of your Personal Information for purposes of EEA and UK data protection laws.

For purposes of this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The term does not include aggregated information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Notice at Collection: Personal Information We Collect

We collect the following categories of Personal Information:

  • Personal identifiers: name, residential and business address, home and business telephone number(s), email address(es), and National Provider Identifier (NPI), IP address;
  • Characteristics of protected classes and demographic information: military or veteran status, age (over 40);
  • Commercial and financial information: payment information, account information, and details of any financial relationship with us, information about prescriptions written, inquires or requests for assistance regarding our products or services;
  • Professional or employment-related information: name of your practice, academic background, professional designation, medical specialty, licensing and disbarment status, publications and information about public speeches, and additional Personal Information you provide in your curriculum vitae or other similar documents or communications;
  • Education information: academic background and credentials;
  • Internet or electronic network information: your browser type, operating system, domain names visited, click activity, referring websites, the date and time and length of visit of your visit to our Websites or other websites or mobile applications;
  • Audio and visual information: recordings of calls made to our information and support lines; audio and visual recordings of presentations given by you; and
  • Inferences drawn from any above data to create profile reflecting an HCP’s interest as they relate to the types of products and educational offerings provided by Arrowhead.

We have collected the same categories of Personal Information in the 12 months prior to the date of this Privacy Notice.

Notice at Collection: Purposes for Collection of Personal Information

We collect and otherwise process your Personal Information, and may have previously processed your Personal Information for the following purposes:

  • Facilitating your registration and attendance at events we sponsor
  • Providing you with promotional information about our products and events
  • Providing you with scientific information about our research and products
  • The administration of advisory boards and other committees that we convene
  • Coordinating your participation as a speaker at events we sponsor, including any compensation or honorarium
  • Responding to your inquiries about our products, policies and programs
  • Processing patient requests to participate in programs we offer or administer
  • Satisfaction of our reporting obligations under applicable law or by virtue of our membership in industry certification organizations

Notice at Collection: No Sale or Sharing of Personal Information

We do not sell Personal Information and we do not share Personal Information for use in cross-context behavioral advertising.  

Notice at Collection: Retention Periods

We retain the categories of Personal Information we collect for as long as we need for a legitimate business purpose. The criteria used to determine the retention periods include: (i) how long the Personal Information is needed to provide / receive the services and operate the business; (ii) the type of Personal Information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the Personal Information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation or data that must be retained for the purposes of litigation or disputes).

Sources From Which We Collect Personal Information

We collect Personal Information from you when you: (i) attend or register to attend an event sponsored by us; (ii) participate in one of our advisory boards or speak at an event on our behalf; (iii) request information from us about our products or services; (iv) apply for a grant, donation or sponsorship; (v) respond to one of our surveys; or (vi) otherwise interact with us including, via the Website. We may also collect your Personal Information from patients, other HCPs or medical professionals, dispensing entities, from data brokers specializing in HCP data, and from publicly available sources. We will continue to collect Personal Information from these same types of sources. 

Sensitive Personal Information

We do not use or disclose sensitive Personal Information under this Privacy Notice to create profiles about or infer characteristics about individuals.

Automated Decision-Making / Profiling

We do not process your Personal Information on the basis of any automated decision-making including profiling.

Cookies and Other Technologies

We collect some of the Personal Information above through “cookies” and other similar technologies.  Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website.  For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Additionally, we use Google Analytics to evaluate the use of our Website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects Personal Information, review Google’s Privacy Policy.

How We Use The Personal Information We Collect

We have set out below, a description of the ways we use your Personal Information (referred to as “processing purposes” below), and, for HCPs located in the EEA or the UK, we explain which of the legal bases we rely on.

Categories of Personal InformationProcessing Purposes  Legal Basis (where you are located in the EEA or the UK)
Where you register to attend and/or attend a sponsored event:
Personal identifiers; Audio and visual information; travel and accommodation informationThe administration and conduct of the relevant event, including to respond to your enquiries and communicate with you about the event which may involve the recording of calls.Where we have a legitimate interest to ensure the effective administration and conduct of the relevant event.
Personal identifiers; Audio and visual informationEnabling the creation, distribution, broadcast or other use of any recordings made during the event   Where we have a legitimate interest to promote the event, to leverage the learnings from the event, and to more generally operate and improve our business
Personal identifiersTo invite you to future events and to send you other promotional information about our products (where permitted by law).   If you wish to stop receiving marketing or market research communications from us you can unsubscribe via the link at the bottom of the relevant e-mail or contact us using the contact details below.If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. In other instances, we will send marketing communications to you where this is in our legitimate interest.
Personal identifiersThe storage of your Personal Information in databases for use when sending invites to future events.Where we have a legitimate interest to manage our business and the conduct of future events.
All categories of Personal InformationCompliance with and satisfaction of legal obligations and regulatory requirements for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organizations.To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States).    
Where you participate in an Arrowhead advisory board:
Personal identifiers; Professional or employment information; Education information; Audio and visual informationThe administration and conduct of the relevant advisory board, including to respond to your enquiries and communicate with you about the advisory board which may involve the recording of calls.Where we have a legitimate interest to ensure the effective administration and conduct of the advisory board.
Personal identifiers; Audio and visual informationEnabling the creation, distribution, broadcast or other use of any recordings made during the advisory board   Where we have a legitimate interest to leverage the learnings from the advisory board, and to more generally operate and improve our business
Personal identifiers; Professional or employment information; Education informationThe storage of your Personal Information in databases for use when selecting HCPs for future advisory boards.Where we have a legitimate interest to manage our business and the conduct of future advisory boards.
All categories of Personal InformationCompliance with and satisfaction of legal obligations and regulatory requirements in the context of safety data reporting activities, and for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organizations.To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States).  
Where you are engaged to speak on our behalf:
Personal identifiers; Professional or employment information; Education information; Audio and visual informationThe administration and conduct of the relevant event, including to respond to your enquiries and communicate with you about the event which may involve the recording of calls or the event.Where we have a legitimate interest to ensure the effective administration and conduct of the relevant event.
Personal identifiers; Audio and visual informationEnabling the creation, distribution, broadcast or other use of any recordings made during the event.  Where we have a legitimate interest to promote the event, to leverage the learnings from the event, and to more generally operate and improve our business.
Personal identifiers; Commercial and financial information; Professional or employment information; Education informationMeeting our contractual obligations under the speaker agreement with you including, to pay you for your speaking services.Where necessary for performance of a contract.
Personal identifiers; Professional or employment information; Education informationThe storage of your Personal Information in databases for use when selecting speakers for future events.Where we have a legitimate interest to manage our business and the conduct of future events.
All categories of Personal InformationCompliance with and satisfaction of legal obligations and regulatory requirements for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organizations.To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States).  
When you contact us or we communicate with you:
Personal identifiers; Audio and visual informationTo respond to your enquiries and communicate with you including, where these relate to, for example, requests for funding, grants, early access programs.Where we have a legitimate interest to manage our business, and to process and respond to your communications.
Audio and visual informationTo make and use recordings of calls made to our information and support lines.Where we have a legitimate interest to manage our business, and to process and respond to your communications.

If you are located in the EEA or the UK: You have a right to object to the processing of your Personal Information where that processing is carried out for our legitimate interests. Please note however, that we may not be able to fulfil such requests in all instances.

Disclosure of Your Personal Information For Business Purposes

The following chart describes the categories of Personal Information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Notice:

Categories of Personal InformationCategories of Third Parties to Which We Disclosed Personal Information for Business Purposes
Personal identifiers:name, residential and business address, home and business telephone number(s), email address(es), National Provider Identifier (NPI), IP address.Service providers that manage customer information and provide patient support services, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services, provide analytics information, and provide legal and accounting services.  
Protected class information: military or veteran status; age (over 40).  Service providers that manage customer information and provide patient support services.
Commercial and financial information: payment information, account information, and details of any financial relationship with us, information about prescriptions written, inquires or requests for assistance regarding our products or services.  Service providers that manage customer information and provide patient support services, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services, provide market research and analytics information, and provide legal and accounting services.  
Professional or employment-related information: name of your practice, academic background, professional designation, medical specialty, licensing and disbarment status, publications and information about public speeches, and additional Personal Information you provide in your curriculum vitae or other similar documents or communications.  Service providers that manage customer information and provide patient support services, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services, provide market research and analytics information.  
Education information: academic background and credentials.Service providers that manage customer information and provide patient support services, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services, provide market research and analytics information.  
Internet or electronic network information: your browser type, operating system, domain names visited, click activity, referring website and the date and time and length of your visit to our Websites or other websites or mobile applicationsService providers that manager customer information and provide patient support services, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services, provide market research and analytics information.
Audio and visual information: recordings of calls made to our information and support lines; audio and visual recordings of presentations  Service providers that manage customer information and provide patient support services, provide access to audio or video recordings.
Inferences drawn from any above data to create profile reflecting a health care professional’s interests as they relate to the types of products and educational offerings provided by Arrowhead.  Service providers that manage customer information and provide patient support services, advertise and market our products and services, provide market research and analytics information.  

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of Personal Information to the categories of third parties identified above for the following purposes: to manage customer information and provide patient support services, to facilitate email communications, provide copies of recorded presentations, manage contacts, work with vendors and suppliers, manage our Website and secure our systems, prevent fraud and other illegal activities and for marketing and analytics.   

We may also disclose HCP Personal Information with third parties we consult and engage as part of our clinical research and compliance activities, such as research partners, ethics committees, and professional advisors, and clinical research monitors and research organizations. 

We may also disclose Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your Personal Information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your Personal Information to a third party in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring.

Security

We take reasonable steps, consistent with generally accepted industry standards, including technical, administrative and physical safeguards to protect Personal Information we process from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, no system is fully secure and we cannot guarantee the security of your Personal Information.  

International Transfers of Personal Information

We are located in the U.S. All Personal Information collected via the Website will in turn, be processed in the U.S. Where we disclose Personal Information originating in the EEA/UK to a third party (e.g., a service provider) located outside of the EEA/UK we will as deemed necessary, enter into a data transfer agreement (e.g., standard contractual clauses) with that third party, seek to rely on the third party’s Binding Corporate Rules or otherwise make the transfer in reliance on a derogation under EEA/UK data protection laws (e.g., where the transfer is necessary for the defence of legal claims). If you would like further information in relation to, or a copy of, the relevant safeguards, you can contact us using the details set out below.

Children’s Privacy

The Website and other HCP-related data processing activities are not directed to minors under the age of 16.  We do not have actual knowledge that we collect Personal Information from minors. 

Third Party Links

Our Website may contain social media buttons or links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those social media platforms or third-party websites.

Your Data Privacy Rights

1.         EEA/UK Data Privacy Rights

If you are located in the EEA or the UK, you have the following data privacy rights which may be subject to limitations / restrictions:

  • The right to request access to your Personal Information;
  • The right to request that your Personal Information be corrected or deleted;
  • The right to request that we restrict our processing of your Personal Information;
  • The right to object to the processing of your Personal Information where it is carried out (i) for our legitimate interests – unless we can demonstrate compelling legitimate grounds for the processing; and/or (ii) for direct marketing purposes;
  • The right to withdraw consent to the processing of your Personal Information; and
  • The right to request that Personal Information be provided to you or a third party in a machine-readable format.

Please contact us using the details set out below in case you wish to exercise any of the above rights.

You also have the right to file a complaint with the competent data protection authority if you have any reason to believe we have not properly handled your Personal Information or have not respected your rights.

2.         California Data Privacy Rights

If you are a California resident, you may have specific rights regarding your Personal Information, in accordance with California law.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) gives California residents rights described below with respect to their Personal Information.

Your Right To Request Disclosure of Information We Collect and Share About You

  • Specific pieces of Personal Information we have collected about you;
  • Categories of Personal Information we have collected about you;
  • Categories of sources from which such Personal Information was collected;
  • Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
  • Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting or selling your Personal Information.

Your Right To Request Deletion of Personal Information We Have Collected About You 

You have the right to ask us to delete Personal Information we have collected from you.  We will do so, subject to the exceptions in the CCPA and other applicable laws.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct Personal Information we hold that you believe is not accurate. We will take steps to determine the accuracy of the Personal Information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the Personal Information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request. 

Exercising Your Rights and How We Will Respond

To exercise any of the rights above, or to ask a question, contact us at 626-304-3400 or email us at dpo@arrowheadpharma.com or use the contact details set out at the end of this Privacy Notice.

For requests for access, deletion, or correction we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances

If we expect your request is going to take us longer than normal to fulfill, we will let you know.

Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination

If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly. If you exercise your rights under this Privacy Notice, you will not be treated differently than others.

Verification of Identity – Access, Deletion or Correction Requests

We will ask you for identifying information and attempt to match it to information that we maintain about you. 

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial. 

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.  

If you would like to designate an agent to act on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.  

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year. We do not provide Personal Information to third parties for their marketing purposes.

California Do Not Track (DNT) Signals 

We do not recognize “Do Not Track” (DNT) signals. 

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at peopleservices@arrowheadpharma.com.

Changes to Our Privacy Notice

We may change this Privacy Notice from time to time. You will be informed about any material changes through a notice on our Website.

Contact Us

Questions, comments and requests regarding this Privacy Notice are welcomed, including requests relating to exercising any of your data privacy rights.

If you reside in the EEA, please contact our EEA Data Protection Representative using the following contact details:

Kaleidoscope Data Privacy Consultants Limited
The Black Church, St Mary’s Place, Dublin DO7 P4AX
Call: +353 (0) 153 14430
Email: contact@kdpc.ie

If you reside in the UK, please contact our UK Data Protection Representative using the following contact details:

Kaleidoscope Consultants Limited
East Side, Kings Cross, London N1C 4AX
Call: +44 (0)20 3637 1111
Email: general@kdpc.uk

If you reside in the U.S., please contact Arrowhead Pharmaceuticals using the following contact details:

Arrowhead Pharmaceuticals, Inc.
177 East Colorado Boulevard, Suite 700, Pasadena, CA 91105
Email: dpo@arrowheadpharma.com