Almirall’s Consumer Health Privacy Notice

Almirall, LLC (“Almirall,” “we,” or “us”), a company belonging to Almirall Group, respects your privacy and recognizes the need for appropriate protection and management information you may share with us. 

The purpose of this Consumer Health Privacy Notice (“Notice”) is to provide additional notices related to health information or health data (“Health Information”) as defined by Washington and Nevada law (“applicable laws”).

This Notice applies to all Almirall’s operations as well as websites, mobile applications and digital services ("services") that link to or post it.

This Notice is supplemental to our Privacy Statement (Privacy policy | Almirall.us). We reserve our right to update this Notice from time to time.

 

1. Scope

For purposes of this Notice, Health Information has the definition given in the applicable laws, including information that identifies or is reasonably capable of being associated or linked, directly or indirectly, with a particular consumer and that identifies the consumer’s past, present, or future physical or mental health status.

This Notice applies only to residents of Washington and Nevada and individuals whose Health information is processed in Washington or Nevada.

This Notice does not apply to the personal information that we collect and process about Almirall employees and other individuals about whom Almirall collects personal information for HR-related purposes. It does not apply to Health Information that is used to engage in public or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws. This Notice does not apply to Protected Health Information or circumstances under HIPAA.

 

2. Health Information Practices

Categories of Health Information

The categories of Health Information we may collect will depend on how you interact with Almirall and the information you choose to provide. We may collect:

  • Health conditions, treatments, diseases, or diagnosis.
  • Social, psychological, behavioural, and medical interventions.
  • Health-related surgeries or procedures.
  • Use or purchase of prescribed medication.
  • Bodily functions, vital signs, symptoms, or measurements of other types of consumer health data.
  • Diagnoses or diagnostic testing, treatment, or medication.
  • Reproductive or sexual health information.
  • Biometric data.
  • Genetic data.
  • Data that identifies a consumer seeking health care services.
  • Other information that may be used to infer or derive data related to the above or other health information.

 

Purposes for Collection of Health Information

Where permitted by law, we may use the Health Information for the following purposes:

  • To operate our business and services (e.g. including but not limited to newsletters and email alerts, provision of troubleshooting, responding to your inquiries, communicate with you, and similar service and support purposes).
  • For analytics purposes, gathering statistical information to continually improve design and functionalities (e.g. including but not limited to better understand how users access and use our services, products, or similar operations).
  • In furtherance of our commercial purposes, including enabling commercial transactions, providing our products and services to you, marketing, and advertising.
  • Customization and personalization. To tailor the content that we may send you and that we may display on the services, including to offer personalized help and instructions, and to otherwise personalize your experience.
  • To fulfil our legal functions or obligations, such as maintaining and auditing compliance.
  • Helping to ensure security and integrity of our systems, including detection and prevention of security incidents.
  • To detect or prevent harmful behaviour such as identity theft, fraud, harassment, or deceptive activities, or activities that are illegal under applicable law.
  • General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

 

Sources of Health Information

We may collect Health Information from a variety of sources, including from:

  • Directly from you or an authorised representative.
  • Government entities.
  • Public records.
  • Non-exempt data from research partner.
  • Data resellers.
  • Marketing vendors.
  • Business service providers.
  • Tracking technologies, like cookies.

 

Our Sharing of Consumer Health Data

We may share or disclose Health Information indicated in the section titled Categories of Health Information with:

  • We may transmit your Health Information to our affiliates outside the United States (“Almirall Affiliates”), such as parent company or subsidiaries, for storage purposes only. All such transmissions remain on the systems of Almirall Affiliates and are not shared with outside parties.
  • We may disclose Health Information to our processors for our business purposes or at your direction to provide you with products and Services that you request.
  • We may share Health Information in the context of business transactions if we, or any portion of our assets, are acquired or we undergo another transaction in our business
  • We may disclose Health Information to the extent necessary to respond to subpoenas, court orders, or other legal processes; in response to a request for cooperation from law enforcement or a government agency; for pharmacovigilance and safety obligations; or to otherwise comply with our other legal and regulatory obligations.

 

Your Rights and Choices

You have the following rights with respect to your Health Information:

  • The right to confirm whether we are collecting, selling or sharing your Health Information.
  • The right to withdraw consent for us to collect or share your Health Information.
  • The right to request that we delete your Health Information.
  • The right to correct your Health Information.

 

There may be certain exceptions that apply to your request. To exercise your rights, you or your authorized representative may submit a request via email (dataprivacyus@almirall.com), postal mail (101 Lindenwood Dr., Suite 400, Malvern, PA 19355), or via telephone 1-844-366-3782.

You may be entitled, in accordance with applicable law, to appeal a refusal to take action on your request. To do so, please contact us by using one of the methods listed above. You will not be discriminated against for exercising any of your rights.

We will always handle your health information in accordance with this Notice in effect at the time it was collected unless we provide you with the new notice and/or obtain your consent or authorization, as appropriate.

 

Last Updated: April 2024