WEBSITE PRIVACY STATEMENT
Scope | Your Consent |
Personal Information | Aggregate Information |
Automatic Tracking Technologies | Your Choices | Uses of Information |
How We Share Information | Links to Other Websites |
Children | How Do We Protect Your Personal Information |
Users Outside the United States | Access and Correction |
Additional Privacy Information on Individual Websites | Updates to
this Website Privacy Statement | Contact Us
At Cephalon, we understand that numerous laws and regulations around the world govern data protection and we respect the fact that protecting your
privacy is important. We also recognize that health and medical information is particularly sensitive. For those reasons, we want to explain our website
By using a Cephalon website you agree to the terms of this Website Privacy Statement. Whenever you submit information to us through a Cephalon website,
you consent to the collection, use, and disclosure of that information in accordance with this Website Privacy Statement, including agreeing that we may
contact you through a variety of means such as e-mail, postal mail, phone, or text message unless you opt out of these communications by contacting us.
At our websites, we collect your personal information (information that can be used to identify you, such as your name, address, telephone number,
e-mail address or similar information) only when you choose to give it to us voluntarily through forms on the website, by responding to our questions and
surveys, or when you access or download tools or coupons. For example, you may choose to register to receive a product coupon, additional product information
or information about a disease state that interests you.
You should also be aware that any communication you submit or that may be posted to any publicly viewable interactive feature such as a blog or testimonial
page is a public communication and may be viewed by the general public. Therefore, you acknowledge and agree that you do not expect privacy or confidentiality
of the content you submit to such services over our websites, whether or not it includes personal information about you. If you display your personal information
in any communication submitted to such services or features, other individuals may collect and use your personal information. While we attempt to remove personal
information from postings to our websites, we cannot guarantee that they will not be viewable or accessible. We are not responsible for, nor can we guarantee the
protection of, any personal information you disclose in a communication submitted to such services or features for posting or contained in an email or other
communication submitted to us for such posting, and thus, you acknowledge that if you disclose personal information in any such material, you do so at your own risk.
We gather aggregate data about visitors to our Web sites for product and service development and improvement activities. We also use it for market analysis.
We may provide information from our Web sites in aggregate form, with identifying information removed, to third parties. When aggregate health information is
provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used.
Automatic Tracking Technologies
As you navigate through a Cephalon website, certain anonymous information can be passively collected (that is, gathered without your actively providing the
information) using various technologies (some of which are described in more detail below), such as cookies, Internet tags or web beacons, and navigational
data collection processes (log files, server logs, clickstream). Your Internet browser automatically transmits to this site some of this anonymous information,
such as the URL of the Web site you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using.
- Web Server Logs and IP Addresses: A web server log is a file where website activity is stored, such as a user's date of visit, length of visit,
what pages the user visited on our websites, etc. Web server logs also capture IP addresses. An IP address is a number assigned to your computer whenever you
access the Internet that allows computers and servers to recognize and communicate with each other.
- Cookies: A cookie is a piece of information that is placed on your computer when you access certain websites that uniquely identifies your browser
to the server. Most web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being
placed on your computer. Note, however, that some portions of our websites may not work properly if you refuse to accept cookies.
- Web Beacons: On certain web pages or e-mails, Cephalon may utilize a technology called a "web beacon" (also known as an "action tag" or "clear
GIF technology"). Web beacons help analyze the effectiveness of websites by measuring, for example, the number of visitors to a site or how many visitors clicked
on key elements of a site.
In some cases, Cephalon may use tracking technologies in ways that identify you personally, but only after you have entered personal information, such as
into a form or data field, on our websites. We may use these tracking technologies to remember your personal preferences and selections, such as personal
information that you have entered into data fields on our websites, answers that you have provided in response to our surveys, sections of our websites that
you visit frequently, or to confirm whether you have read or clicked on certain e-mail communications we send to you so that we can make our communications
more useful and interesting to you.
You have certain choices when using our websites. You could choose not to submit personal information by not entering it into any forms or data fields on
our websites and not downloading or requesting materials or using any available personalized services. You could also decide not to make a post or submission
to any interactive features we make available such as blogs, message boards, surveys or questionnaires. Certain websites may ask for your permission for certain
uses of your personal information and you can agree to or decline those uses. If you receive certain communications from us, such as product or health related
information or market research surveys, we may send you emails or other communications. You will be able to unsubscribe from these communications at any time by
following the instructions included in each communication. If you decide to unsubscribe from a communication, we will work to remove your information promptly,
although we may require additional information before we can process your request.
Uses of Information
If you provide us with personal information we may use the information to contact you (such as by e-mail, regular mail, or telephone) to provide you with
information or materials you request, product or health-related information that we believe may be of interest to you, to learn about and develop products
and services (e.g. market research), or to do technological maintenance. Uses of your personal information may be described at the point where you are asked
to provide personal information on a website. We may also use information collected via a site to improve the content of our site, to customize the site to your
preferences, for our marketing and research purposes, and for any other purpose specified. In addition, we may make full use of all information acquired through
this site that is not in personally identifiable form. For example, we may use aggregate information to help improve our websites, or our products and services
or to do market research and analysis.
How We Share Information
Cephalon may share personal information about you with various outside companies, service providers, or vendors working on our behalf as well as with
co-promotion or co-marketing partners. We may also share personal information with our company's affiliates operating in the United States or in other countries.
We may also disclose personal information: (i) in connection with the sale, assignment or other transfer of the business of the site to which the data relates;
(ii) to respond to requests of government or law enforcement agencies or where required or permitted by applicable laws, court orders, or government regulations;
or (iii) where needed for corporate audits, to investigate or respond to a complaint or security threat, or to otherwise protect our interests or those of our
customers and business partners.
Cephalon will not sell or otherwise transfer the personal information you provide to us on our websites to any third parties, other than affiliates, for
their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.
On some Cephalon websites, if you choose to use our referral function to tell a friend about our site, our site will ask you for your friend's name and
e-mail address as well as your information. The form automatically sends your friend a one-time e-mail inviting him or her to visit the site. We do not access
or store this information, except to send this invitation.
Links to Other Websites
As a useful resource to our visitors, Cephalon provides links to other websites. We try to choose websites that we believe are useful and of high quality.
However, because websites can change very quickly, we cannot guarantee, and do not monitor, the content of any website to which we provide a link or reference.
In addition, Cephalon shall assume no liability for the content of non- Cephalon sites. Links to other sites are provided only as a convenience to users of our
site. Before using the linked Web sites, please review their Internet privacy statements to understand how they use and protect personally identifiable
Cephalon does not knowingly collect or solicit personal information from anyone under the age of 13. Our websites are not intended or designed to attract
children. If you are under 13, please do not send any personal information about yourself to Cephalon. If you believe that we might have any information from
or about a child under 13, please contact us at email@example.com and we will delete such information.
How Do We Protect Your Personal Information
We take reasonable precautions to maintain the protection of personally identifiable information collected through this Web site and used in accordance
with this Website Privacy Statement. In addition to technical safeguards, we also use physical controls and procedures to safeguard your personally identifiable
information. However, Cephalon does not warrant or represent that its level of security meets or exceeds any specific standards. You should keep in mind that no
Internet transmission is 100% secure or error-free nor is stored data free from vulnerabilities. We cannot guarantee the security of our databases, websites or
services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet. We are not responsible
for the actions of third parties.
Users Outside the United States
If you are accessing our websites from outside of the United States, please note that we may store personal information we collect about you in the
United States or we may transfer it to any other country. The data protection laws in countries to which such personal information is transferred or stored,
including the United States, may or may not provide a level of protection equivalent to the laws in your home country.
Access and Correction
To keep your personally identifiable information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to
update or correct personally identifiable information in our possession that you have previously submitted via this site.
Additional Privacy Information on Individual Websites
If a Cephalon website has particular provisions relating to privacy that are in addition to those stated here, those provisions will be disclosed to you
on the page on which your personal information is collected.
Updates to this Website Privacy Statement
Cephalon reserves the right to modify, add or remove portions of this Website Privacy Statement at its discretion by updating this posting. You are bound
by any such revisions and should therefore periodically visit this page to review the most current privacy statement especially before you provide any personal
If you have any questions about Cephalon's Website Privacy Statement, the information practices of our websites or you want to revise or update your personal
information, you may contact us as follows:
Attn: Chief Compliance Officer
41 Moores Road
PO Box 4011
Frazer, PA 19355 USA
Last Updated: May 2011
US-EU SAFE HARBOR PRIVACY STATEMENT
It is the policy of Cephalon, Inc. and its global subsidiaries and affiliates (the "Company") to respect Personal Data, including Sensitive Personal Data,
that is collected or maintained by or on behalf of the Company. In furtherance of this commitment, the Company has certified to the US-EU Safe Harbor Agreement
regarding Personal Data collected in the European Economic Area (EEA) and transferred to the United States. The Company adheres to the Safe Harbor privacy principles
as agreed to by the U.S. Department of Commerce and the European Commission and as outlined in this US-EU Safe Harbor Privacy Statement (the "Safe Harbor Statement").
This Safe Harbor Statement sets forth the principles under which the Company manages the processing of Personal Data collected in the EEA and subsequently
transferred to the United States.
"Personal Data" means any information that identifies or describes an identified or identifiable living natural person. "Personal Data" may include, for
example, name, signature, employee identification number, social security number, telephone number, insurance policy number, job title, financial information,
account numbers, or any other information that is capable of being associated with a particular identifiable individual. Personal Data does not include aggregate
data that have been divorced from individually identifiable characteristics.
"Sensitive Personal Data" is a subset of Personal Data, and includes information pertaining to an individual's racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, information related to an individual's health or sex life, as well as biometric identifiers, such
as finger and voiceprints, and information as to commission or alleged commission of a criminal offense or any related proceedings.
Safe Harbor Principles
Notice: The Company notifies data subjects (such as employees, clinical data subjects, customers and health care professionals) about the identity
of the data controller or its representative, the purpose(s) for which it collects, processes and maintains the data, and any further information as may be required
by the circumstances under which the data are collected including the types of Personal Data the Company collects about data subjects, the recipients or categories of
recipients of the data, the proposed transfer of such data to third countries, the types of third parties to which it discloses such data and the right of access to the
data. Notice is provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before the Company uses or discloses the
information for a purpose other than that for which it was originally collected.
Choice: In the event Personal Data are to be used for a new purpose incompatible with the purposes for which the data were originally collected or
subsequently authorized or transferred to the control of a third party that is not acting as an agent of the Company, data subjects are given notice of such use and,
where feasible and appropriate, an opportunity to decline to have their data so used or transferred. In the event that Sensitive Personal Data are to be used for a new
purpose or transferred to the control of a third party not acting as an agent of the Company, the data subject's explicit consent will be obtained prior to the new use
or transfer of the data, unless such new use or transfer is (1) in the vital interests of the data subject or another person; (2) necessary for the establishment of the
Company's legal claims or defenses; (3) required to provide medical care or diagnosis; (4) necessary to carry out the Company's obligations in the field of employment
law; or (5) related to data that are manifestly made public by the data subject.
Onward Transfers: The Company only transfers Personal Data to a service provider, vendor or other third party acting as a processor of Personal Data
for the Company (an "agent") where the agent has provided assurances that the agent provides at least the same level of privacy protection as is required by these privacy
principles. Where the Company has knowledge that one of its agents is using or sharing Personal Data in a way that is contrary to these principles, the Company will
take reasonable and appropriate steps to prevent or stop such processing. The Company will only transfer Personal Data to a non-agent third party where such transfer is
consistent with applicable laws and with the notice provided to the data subjects at the time the Personal Data were collected.
Security: The Company takes reasonable and appropriate precautions to protect Personal Data in its possession and control from loss, misuse,
alteration, destruction, or unauthorized access or disclosure.
Access: Data subjects have reasonable access to their Personal Data, and may request corrections, deletions, or additions, as appropriate, except
where the burden or expense of providing such access would be disproportionate to the risks to the individual data subject's privacy or where the disclosure of such
information would jeopardize the integrity of the Company's research effort.
Data Integrity: The Company limits the collection, usage, and retention of Personal Data to that which is germane to the relevant purposes and takes
steps to ensure that any Personal Data are accurate, complete, current and reliable for the intended use.
Enforcement: The Company has put in place mechanisms to verify its ongoing compliance to these privacy principles. Any Company employee found to
have violated the privacy principles in this Safe Harbor Statement will be subject to appropriate corrective actions.
Dispute Resolution: The Company is committed to resolving any disputes that may arise by internal investigation and resolution of the issue.
Should the Company's efforts to resolve an issue be unsuccessful, the Company will facilitate the resolution of such disputes including through the submission of
disputes to an independent party.
Cephalon participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in safe harbor,
we have agreed to the TRUSTe Dispute Resolution Requirements
for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have complaints regarding our compliance with the Safe Harbor you should first
contact us at firstname.lastname@example.org or at the Company's headquarters at 41 Moores Road, Frazer, Pennsylvania 19355.
If contacting us does not resolve your complaint, you may raise your complaint by contacting
TRUSTe here, by fax at 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing
TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you
would like the particulars of your complaints shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, please
visit TRUSTe or request this information from TRUSTe at any of the addresses listed above.
The TRUSTe dispute resolution process shall be conducted in English.
For human resources data we have agreed to cooperate with Data Protection Authorities. Any questions, comments or complaints about the data practices
(including without limitation compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) of a hosted
online OnBoarding software customer or partner for whom the Company processes data should be addressed to that customer or partner.
Within the European Union, any questions, concerns or comments about this Safe Harbor Statement may be directed to the Data Protection Officer at the relevant office
of the Company or to the European Legal Department. The Company agrees to cooperate with EU Data Protection Authorities regarding any unresolved dispute.
Limitation on Scope of Principles
Adherence by the Company to these privacy principles may be limited to the extent necessary to meet the Company's regulatory, legal, governmental, or national
How to Contact Us
Please contact us with any questions concerning this Safe Harbor Statement or any of the Company's privacy practices at:
Attn: Chief Compliance Officer
41 Moores Road
Frazer, Pennsylvania 19355
Changes to this US-EU Safe Harbor Privacy Statement
This US-EU Safe Harbor Privacy Statement may be amended consistent with the requirements of Safe Harbor. When we do update the US-EU Safe Harbor Privacy Statement,
we will also revise the "Last Updated" date at the bottom of this document. Any material changes to this privacy statement will also be posted on the Company's website,
Last Updated: April 2011