Sentynl Privacy Statement
Effective Date: November 23, 2015
Sentynl Therapeutics, Inc. ("Sentynl," "We" or "Our") are committed to respecting your privacy. This Privacy Statement is intended to answer your important questions about our privacy practices, whether you are looking for health information or are mining the experience of Sentynl to refine your expertise in meeting the needs of your patients.
This Privacy Statement applies to all Sentynl online or digital services activities, including, but not limited to www.Sentynl.com (the “Site”), our other websites, any mobile applications (“Apps”) and digital services on or to which it is posted or linked (collectively, the "Services").
Please carefully read this Privacy Statement to learn more about how we may collect, use, disclose and store information provided and the steps we take to help protect the often sensitive information provided from unauthorized use or disclosure. When you submit information to or through the Services, you consent to the collection, processing and retention of your information as described in this Privacy Statement.
This Privacy Statement is incorporated into and made a part of our Terms of Service. If you have not done so already, please also review Sentynl’s Terms of Service. The Terms of Service contain provisions that limit Sentynl’s liability to users of the Services.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY STATEMENT, THEN PLEASE DO NOT USE ANY OF THE SERVICES.
Please note that this Privacy Statement does not apply to information collected through third-party websites or services that you may access through the Services.
Sentynl is a United States company with primary operations in San Diego County, California (Sentynl’s headquarters). Sentynl may process personal information in global databases that can be accessed by authorized Sentynl personnel worldwide. Transfers of personal information to Sentynl are made in accordance with applicable privacy laws. Regardless of where your personal information is collected or processed, Sentynl maintains appropriate administrative, technical and physical safeguards to protect information about you.
I. INFORMATION WE COLLECT
When you use the Services, we may collect Personal Information and Usage Data.
In this Privacy Statement, “Personal Information" means information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as e-mail address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) certain Usage Data (defined below).
Certain subsets of Personal Information, such as information about health or medical status (pursuant to all applicable laws) and Location Data (defined below), are characterized as sensitive (collectively, “Sensitive Personal Information”) and may be subject to stricter regulation and consent requirements than other information. Before providing it to us, we urge you to carefully consider whether to disclose your Sensitive Personal Information. If you do provide Sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Statement.
“Usage Data” is information about an individual’s activity on or through the Services that, by itself, does not identify the individual, such as browser type, operating system and webpages visited.
We do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual.
If different types of Usage Data and Personal Information are linked together and, once linked, identify an individual person, Usage Data in such limited scenarios may be considered Personal Information.
II. HOW INFORMATION IS COLLECTED AND USED
Sentynl may collect and use information to operate the Services, including:
Information That You Voluntarily Provide When Using the Services. We collect and use the Personal Information that you voluntarily provide to us through the Services. You may use certain Services without registering or identifying yourself but, if you do not register, you may not have access to all of the Services. If you choose to register, we may use the Personal Information you provide to confirm your registration and to respond to requests from you. Upon your request, we may also use the Personal Information to send you special promotions or newsletters with information that may interest you.
If you are a healthcare professional or an institutional healthcare provider (collectively, “Providers”), you are responsible for obtaining any legally required authorization, consent or other permission from your patients prior to providing their Personal Information to Sentynl through the Services. By submitting any Personal or other Information about a patient, you represent and warrant to Sentynl that you have obtained all required permissions to do so.
Through Your Use of Interactive Services. If you choose to participate in our questionnaires and surveys and other interactive Services, we will collect the information, including health-related information and other Sensitive Personal Information that you share to help us better understand how Sentynl products are used in coping with the diseases for which they are marketed.
The information you provide through interactive Services may be combined (subject to all applicable laws) with the Personal Information provided elsewhere in or through the Services. We may combine your and others’ Personal Information to create summary data that we will use for our business purposes, such as research to improve our products and analyses that may help us better market our products.
If you submit health-related Personal Information through the Services to participate in a clinical trial, we may use your Personal Information to assess whether you qualify for enrollment in the trial, to contact you about potential participation in the trial, and to provide you with additional information about the trial.
You may provide information to be published or displayed ("Posted") on public areas of the Services (collectively, "User Contributions"). Your User Contributions are Posted and made available publicly at your own risk. Sentynl does not control the actions of third parties with access to your User Contributions. If you are a Provider and submit Personal Information about a study subject related to his or her participation in a clinical trial, that Personal Information will be processed in accordance with this Privacy Statement. If we determine that the potential study subject is eligible for the trial, we will use the information to contact you about his or her potential participation in the trial and to provide you with additional information.
When you Correspond with Sentynl about Sentynl Products. If you contact Sentynl or use the Services to ask questions or report problems regarding your experience in using one of our products, we may use the information you provide in submitting reports to the U.S. Food and Drug Administration and as otherwise required of us by law. We also may use the information to contact the prescribing physician to follow up regarding an event involving use of our product.
Through Data Collection Tools. Sentynl may also automatically collect information about use of the Services through data collection tools, such as web beacons and cookies.
A "web beacon" is a piece of code that enables us to monitor user activity and website traffic. A "cookie" is a randomly-generated unique numeric code stored in the user’s web browser settings or computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires), as well as the randomly generated unique numeric code.
We may use the information collected through data collection tools to monitor usage patterns, store information about user preferences and to improve the Services. For example, your Personal Information may be used to create customized offers, information and services tailored to your interests and preferences. We may track your activities over time and across third-party websites, apps or other online services to display advertisements on third-party websites. If you do not want us to use your information in this way, please see “Your Privacy Choices” below. For more information about our digital advertising practices, please see “Digital Advertising” below.
When you Use a Mobile Application. When you use an App, we may use data collection tools to collect information about your use of and interaction with the App, such as operating system type, browser type, domain and other system settings, search queries, and the time zone in which the mobile device or tablet is located, metadata and other information associated with other files stored on your device.
We also may collect information about the location of the mobile device or tablet used to access the Services (“Location Data”). Location Data includes: (i) the location of the mobile device or tablet derived from GPS or WiFi use; (ii) the IP address of the mobile device or tablet or internet service used to access the Services; and (iii) other information made available by a user or others that indicates the current or prior location of the user, such as geotag information in photographs.
We will inform you if a specific App or service collects precise Location Data. If you do not want us to collect Location Data from your device, please delete the App or disable the location settings on your device or tablet. Note, however, that disabling the location setting may affect your ability to access and use that App.
When you Connect with Social Media though the Services: Certain Services may link with social media platforms and social media plug-ins (e.g., the Facebook "Like" button, "Share to Twitter" button) (collectively, “Social Media”). When accessing the Services through a Facebook or other Social Media account, Sentynl may (depending on the applicable user privacy settings) automatically have access to information provided to or through the Social Media platform. Sentynl may collect and use this information for the purposes described in this Privacy Statement or at the time the information was collected.
Through Service Providers: Third parties that assist us with our business operations also may collect and use information (including Personal Information and Usage Data) through the Services and also may share the collected information with us. For example, our vendors may collect and share information with us to analyze use of the Services, to help us detect and prevent fraud and to improve user experience.
III. HOW INFORMATION IS SHARED AND DISCLOSED
We may share and disclose information as described at the time information is collected and as follows:
To Perform Services. We may use third parties to perform services requested or functions initiated by users. In addition, we may disclose Personal Information to identify a user in connection with communications sent through the Services. We also may offer users the opportunity to share information with friends and other users through the Services.
With Sentynl’s Third Party Contractors. We may share information, including Personal Information, with our service providers to perform the functions for which we engage them, such as data analysis, system design and maintenance, customer services and for marketing and promotions.
Social Media Plugins. When you use the Services, Social Media operators can place a cookie on your computer to recognize individuals who have previously visited the Services. If you are logged into a Social Media account while using the Services, the social plugins allow that Social Media to receive information that you have accessed and used the Services. The social plugins also allow the Social Media operator to share information about your activities in or through the Services with other Social Media users. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allows you to see your friends' Facebook activity through the Services. Sentynl does not control any of the content from the Social Media plugins. For more information about Social Media plugins, please refer to the privacy statements and other legal notices of the Social Media platform.
Legal Requirements. In certain circumstances, Sentynl may release your Personal Information in response to a court order, subpoena, search warrant, regulation, binding order of a data protection agency, governmental request or other legal or regulatory process. Sentynl may disclose information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sentynl and our customers or others.
Corporate Changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Sentynl or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, Sentynl will use reasonable efforts to notify users before information is transferred or becomes subject to different privacy practices.
IV. LINKS TO OTHER WEBSITES/SERVICES.
V. OUR CHILDREN’S POLICY
The Services are not intended for use by children. If you are under the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that a child under age 13 has provided Personal Information to or through the Services without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and subsequently we will dispose of such Personal Information in accordance with this Privacy Statement.
If you believe Sentynl may have any information from or about a child under age 13, please contact our Compliance Office using the contact information at the end of this Privacy Notice.
VI. YOUR PRIVACY CHOICES
Sentynl aims to provide you with choices regarding the Personal Information you provide to us. This section describes mechanisms that we offer you to control certain uses and disclosures of your information.
When you access any interactive Service, you will be asked to affirmatively choose ("opt in") to provide the requested information. You may always choose not to provide the requested information but then you may not be able to use the Service as intended.
Correct/Update Personal Information. You may correct or update the Personal Information you previously provided to Sentynl, by completing the form located at http://www.Sentynl.com/preferences.
Receive Marketing Communications. When you register for the Services, you may request to receive email containing information about Sentynl that we think you might find useful, including promotions, announcements of new services and products, and newsletters on particular health topics. If you decide, at any time, that you no longer wish to receive these emails you may unsubscribe from our email list by completing the form located at http://www.Sentynl.com/preferences.
Accept and Reject Cookies. Your browser software can be set to reject all cookies, but if you reject our cookies, certain of the functions and conveniences of the Services may not work properly. To learn more about cookies, please check your browser’s help or similar feature or visit allaboutcookies.org.
How We Respond to Browser “Do Not Track” Signals. Some web browsers incorporate a "do-not-track" or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser’s user. As of the Effective Date not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, Sentynl along with many other digital service operators do not currently respond to DNT signals. For more information about DNT signals, visit allaboutdnt.com.
IMPORTANT NOTE: Sentynl cannot comply with a consumer's request to amend or remove information that was provided to Sentynl by a healthcare professional or a consumer regarding an adverse drug event.
VII. HOW INFORMATION IS RETAINED AND SECURED
We retain information as long as it is necessary and relevant for our operations. In addition, we retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. When your Personal Information is no longer needed for Sentynl’s business purposes, we dispose of it subject to applicable law.
We employ security measures intended to help protect the security of all information submitted through the Services. The security of information transmitted through the internet cannot, however, be guaranteed. We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Services. Any access to the Services through your user ID and password will be treated as authorized by you. To help protect your Personal Information, we may suspend your use of all or part of the Services, without notice, if Sentynl suspects or detects any breach of security. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
VIII. CHANGES TO THIS PRIVACY STATEMENT
Sentynl reserves the right to change the terms of this Privacy Statement. If we make any material changes to this Privacy Statement, we will notify you in advance through the Services. If we decide to use Personal Information in a manner that is materially different from the uses described in this Privacy Statement or otherwise disclosed to you, you will have the choice to allow or disallow any additional uses or disclosures of your Personal Information. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Statement. The amended Privacy Statement supersedes all previous versions.
IX. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident under age 18 and are a registered user of any of the Services, then you may request that we remove any of your User Contributions (defined in Section III) you publicly posted on or in the Services. To request removal of your User Contribution, please send a request with a detailed description of the specific User Contribution to the Compliance Office at the contact information below. (You also may be able to log in to your account and delete your own User Contribution.) Sentynl reserves the right to request that you provide information that will enable us to confirm that the User Contribution that you want removed was created and posted by you.
Sentynl will make a good faith effort to delete or remove your User Contribution from public view as soon as reasonably practicable. Please note, however, that your request that we delete your User Contribution does not ensure complete or comprehensive removal of your User Contribution. Your User Contribution may remain on backup media, cached or otherwise retained by Sentynl for administrative or legal purposes or your User Contribution may remain publicly available if you or someone else has forwarded or re-posted your User Contribution on another website or service prior to its deletion. Sentynl may also be required by law to not remove (or allow removal) of your User Contribution.
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding Sentynl’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or send an email to:
Chief Compliance Officer
Sentynl Therapeutics, Inc.
420 Stevens Ave.
Solana Beach, CA 92075
Be sure to include your name, address, and email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by applicable law.