INTRODUCTION
Neurim Pharmaceuticals (1991) LTD. and its subsidiaries and affiliates (collectively, “Neurim”) operate a variety of websites designed to provide you with information and services, including but not limited to health information resources, corporate news, patient assistance programs, and product information. Some of Neurim’s websites also enable healthcare professionals to receive product information and samples. Neurim is committed to honoring the privacy and information security of visitors to our web sites. Whether you are a patient, healthcare provider, investor, customer, or job applicant, respect for the privacy of your personal information is very important to us. This policy describes how we collect, use, protect, and disclose the personal information that you share with us when you visit any of our websites. Neurim websites are committed to collecting, maintaining, and securing your personal information in accordance with the terms of this policy. Because we rely on third party commercial software and programs to operate our servers, we may inadvertently collect personal information due to certain automatic functions or features contained in such software or due to certain software changes or upgrades. We encourage you to read this Privacy policy in its entirety before submitting any information on the website. By logging into Neurim web-sites and by providing any information, Neurim assumes you acknowledge, understand and agree with the provisions of this Privacy policy.
WHAT INFORMATION DO WE GATHER?
Neurim will not collect personally identifiable information about you unless you provide it voluntarily. You can use our websites without telling us who you are or providing us with any personal information. However, depending on which website you visit and which information or services you seek, you may not be able to receive certain information unless you agree to provide us with personally identifiable information. For example, we may collect information from physicians and other healthcare providers who register on our websites in order to verify their licensure status and identity. The type of information collected from you will be based on the specific program that you register for, as indicated at the time of your registration. The information that we may ask you to provide may include your first and last name, your mailing address, your age, birth date, email address, and information about your medical condition. Neurim limits the collection and processing of personal information to what is necessary to fulfill the purposes for which it is to be used. Neurim will request your consent to collect your personally identifiable information when you register for a program or service. We will also offer you the option to opt out of receiving further communications from Neurim (“opting out” or “unsubscribing”) if you later decide that you no longer want to participate in that program or receive additional information from us.
USE OF COOKIES AND OTHER TAGS
Non-personally identifiable information and data may be automatically collected through the standard operation of Neurim’s Internet service or through the use of “cookies” or “Internet tags” and other similar techniques. For more information please refer to our Cookie Policy in this website.
DATA INTEGRITY AND SECURITY
Neurim takes reasonable steps to ensure that personal data collected are reliable for their intended use, accurate, complete, and current. We use appropriate technical, administrative, and physical safeguards to protect data that pertain to you from loss, misuse, or alteration. In addition, we take reasonable steps to ensure that our safeguards take into account new known threats. However, due to the open communication nature of the Internet, no organization can guarantee the absolute security of personal information. We cannot guarantee that communications between you and Neurim, and Neurim and you, will be free from unauthorized access by third parties. Users of our and any web site use the web site at their own risk.
SHARING YOUR INFORMATION WITH THIRD PARTIES
Neurim will not share your personal information with third parties for their own separate use unless we have obtained your opt-in consent to do so. When you provide personally identifiable information to Neurim, it will be accessible to some of Neurim’s business partners, such as companies we retain to fulfill requests for information, answer telephone calls, or provide assistance to us on specific programs or projects. In addition, Neurim may enter into business relationships with other companies. In those cases, the other companies may also have access to your personally identifiable information. Neurim requires third parties to whom it discloses personal data to protect personal information using substantially similar standards to those required by Neurim. We also require that they do not use your personal information for any separate use that is not specifically authorized by Neurim. There may also be instances where Neurim may be required to share your information with third parties who have not been retained by Neurim, such as with health authorities to report possible adverse drug experiences, during inspections or audits, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or as ordered or directed by courts or other governmental agencies. Many entities receiving personally identifiable information under these conditions have privacy requirements that apply to their handling of your information.
SHARING YOUR INFORMATION WITHIN THE NEURIM GROUP OF COMPANIES
The information that you provide to Neurim may sometimes be shared with other departments within Neurim, as well as Neurim subsidiaries and affiliates within the Nuerim global group. This may mean that your personally identifiable information may be transferred outside your place of residence to Neurim affiliates or companies in other countries. Other departments within the Neurim group, and other Neurim companies that may receive your information, will abide by substantially similar privacy requirements relating to your personally identifiable information.
Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. If adverse event or other safety related information was provided by you, it may be forwarded to drug safety department, processed in accordance with an applicable regulations and submitted to the health authority in a completely anonymized way. We do not share this information without your permission for any other purpose.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
CORRECTING AND ACCESSING YOUR INFORMATION
We encourage you to update the information you provide to us, such as providing us with a new mailing or email address, a name change, or a change in the medical conditions that you have notified us about. This will help us continue to provide information to you that best meets your needs. Neurim complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. To protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of your identity. Please submit request to info@neurim.com.
CHILDREN’S ONLINE PRIVACY
While in some instances we may collect personal data about children with the consent of a parent or guardian for the provision of our Services such as clinical activities or for patient support programs, we do not otherwise knowingly solicit data from, or market to, children. If a parent or guardian becomes aware that his or her child has provided us with personal information, he or she should contact us as described in the “How to Contact Us” section below. We will take reasonable steps to delete such information from our database within a reasonable time.
LINKS AND THIRD-PARTY WEBSITES
Neurim’s websites may contain links or references to third-party websites not affiliated with us as a convenience to you. This Privacy policy does not cover the practices of those websites. Once you have used these links to leave the Neurim website, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion and your responsibility, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Neurim website.
ACCESS AND CHOICE
We offer individuals to choose (opt-out) whether their personal information is (a) to be disclosed to a third party or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals are provided with clear and conspicuous, readily available, and affordable mechanisms to exercise their choice. For sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin; etc.), individuals are given affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice.
If your personal information changes you may contact info@neurim.com . We will respond to your request to access within 30 days.
DATA RETENTION
Neurim retains personal information we collect for as long as needed to provide Service to our customers, subject to our compliance with this Policy. We may further retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
UPDATES TO PRIVACY STATEMENT
The foregoing terms are effective as of November 2018. Neurim may update this Privacy policy from time to time based on, among other things, changes in applicable laws, development of new websites, and advances in technology. Neurim reserves the right to modify, add, or remove portions of this Privacy policy at any time at our sole discretion. If we decide to revise this policy, we will post the revised policy at this site. We encourage you to review the policy each time you visit our site. Your continued use of the website following the posting of changes to these terms means you accept these changes and agree to the updated policy. If you do not agree with the terms of this Privacy policy, please do not use the website. This Privacy policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.
HOW TO CONTACT US
If you have any questions about our Privacy policy, its implementation, the accuracy of your personal information, or the use of the information collected, please contact us at info@neurim.com.
You can also mail us at:
27 Habarzel St
Tel-Aviv 69710
Israel
Tel: +972 3 768 4911
Fax: +972 3 649 4568