This Policy is solely related to the Services you receive from Genmab and does not provide notice regarding any activity, information sharing, or other interaction with a healthcare provider or healthcare insurance company.
For purposes of this Policy, “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. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
THE INFORMATION WE COLLECT
In the twelve (12) months preceding the date of this Policy, We may have collected your Personal Information when you used our Services (i.e. when you interacted with patient services website or called into the MyNavCare Patient Support Center). We will continue to collect Personal Information from the same sources.
The categories of Personal Information We may have collected from these sources during the 12 months preceding the date of this Policy, and will continue to collect, include the following, in addition to unstructured Personal Information you may voluntarily provide to Us:
- Personal identifiers: such as name, address, contact details, national identification document information, IP address, account and password information.
- Geolocation data: when you interact with the patient services website
- Financial information: such as household income
- Internet or other electronic activity information: such as information about your computer, mobile device, browser, and cookie information.
- Protected class information: such as age and birth date
- Audio, electronic, visual or similar information: such as patient support call recordings
PURPOSE FOR COLLECTION AND HOW WE USE INFORMATION
We use the information We collect to provide you the Services, to enhance your experience when using our Services, and to improve our Services.
Additionally, We use Personal Information, including about your use of our Services, to monitor or improve our Services; for internal business analysis; to prevent fraud, activities that violate our Legal Notice or that are illegal; and to protect our rights and the rights and safety of our users or others.
THIRD-PARTY DATA SHARING AND DISCLOSURE
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of Personal Information We have disclosed to third parties for a business purpose in the past twelve (12) months:
|Categories of Personal Information||Categories of Third Parties with Which We disclosed Personal Information for a Business Purpose|
|Personal identifiers: name, address, contact details, national identification document information, IP address, account and password information||Service providers that facilitate scheduling and email communications, provide security services and cloud-based data storage, and assist with other IT-related functions, and in general service providers that assist Us with the provision of patient services.|
|Geolocation data||Service providers that facilitate IT-related functions in our patient services website.|
|Financial information, such as household income||Service providers that assist Us with the provision of patient services.|
|Internet or other electronic network activity information: information about your computer, mobile device, browser and cookie information||Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, and provide analytics information|
|Protected class information: such as age and birth date||Service providers that assist Us with the provision of patient services.|
|Audio, electronic, visual, or similar information: such as patient support call recordings||Service providers that assist Us with the provision of patient services, particularly the MyNavCare Patient Support Center.|
Additional Information About How We May Share Personal Information
We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, to our advisors, such as our accountants or lawyers, 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 share your Personal Information with 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.
Categories of Personal Information We Sold to Third Parties in the Preceding 12 Months
We do not knowingly sell the Personal Information of persons under the age of 16.
COOKIES AND OTHER TRACKING 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 websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
RIGHTS SPECIFIC TO CALIFORNIA RESIDENTS
If you are a California resident, you have certain rights that are described in this section of the Policy.
Your Right to Request Disclosure of Information We Collect and Share About You
We are committed to ensuring that you know what Personal Information We collect. To that end, you can ask Us for any or all of following types of information regarding the Personal Information We have collected about you prior to our receipt of your request:
- 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 your Personal Information.
Your Right to Request Deletion of Personal Information We Have Collected About You
Upon your request, We will delete the Personal Information We have collected about you, except for situations where the CCPA (California Consumer Privacy Act) authorizes Us to retain specific information, including when it is necessary for Us to provide you with services that you requested; perform a contract We entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits Us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to Us or that are reasonably aligned with your expectations based on your relationship with Us. We will act on your deletion request within the timeframes set forth below.
Your Right to Ask Us Not to Sell Personal Information We Have Collected About You
Opting Out of the Sale of Personal Information
You can direct Us not to sell your Personal Information by submitting an opt-out request through our Data Request Form, or by contacting Us at [email protected]. We will act on your request within the timeframes set forth below.
Global Privacy Control
We also recognize opt-out signals communicated through the browser-based extension offered through the Global Privacy Control, a non-profit that is in the process of developing a technological tool that can be used universally to signal a user’s privacy preferences. However, please note that, due to the technical limitations of the Global Privacy Control’s extension, requests made through their extension apply only to the device on which the request is made (e.g., a specific computer) and will only work with the browser used to activate the opt-out setting (e.g., Duck Duck Go).
Exercising Your Rights and How We Will Respond
We will first acknowledge receipt of your request within ten (10) business days of receipt of your request. We will then provide a substantive response to your request as soon as We can, generally within forty five (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.
We usually act on requests and provide information free of charge, but We may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow Us to refuse to act on certain requests. When this is the case, We will endeavor to provide you with an explanation as to why.
Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination
If you exercise any of the rights explained in this Policy, We will continue to treat you fairly. If you exercise your rights under this Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Verification of Identity – Access or Deletion 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.
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, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your Personal Information, the agent will need to provide Us with your signed permission indicating the agent has been authorized to submit the opt-out 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.
HOW WE PROTECT YOUR INFORMATION
We take very seriously the security and privacy of the Personal Information that We collect pursuant to this Policy. Accordingly, We implement reasonable security measures designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our systems or the systems of the third parties with which We may share your information, nor can We guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to Us may not be secure, and you should therefore take special care in deciding what information you send to Us via e-mail.
We do not control how third parties use your information, but you can opt out of certain third-party activities at the links below.
To opt out of Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.
To opt out of certain ad functions, please visit: https://youradchoices.com/control.
Do Not Track Mechanisms
We do not respond to “Do Not Track” settings or other related mechanisms at this time.
This Policy is effective as of the last updated date stated at the bottom of this Policy. We may change this Policy from time-to-time with or without notice to you. By using the Services after We make any such changes to this Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Policy in effect at the time We collect the information. Please refer back to this Policy on a regular basis.
Our Sites may contain 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 third-party websites. We recommend that you review the privacy policies posted on any platform or website that you may access through our Sites.
HOW TO CONTACT US
Genmab US, Inc.
Attention: Legal Department
777 Scudders Mill Road
Plainsboro, NJ 08536
POLICY LAST UPDATED: March 2023