Privacy Policy

Mallinckrodt Privacy Policy

Introduction

The privacy and protection of personal information is of importance to Mallinckrodt Pharmaceuticals. This Privacy Policy (Policy) describes how Mallinckrodt LLC and its affiliates and brands collect, use, and share personal information.

Contact Information

The primary data controller is Mallinckrodt Pharmaceuticals Limited, with registered offices at 3, The Causeway, Staines-Upon-Thames, Surrey, TW18 3AG, United Kingdom. In addition, the Mallinckrodt affiliates that employ personnel in both Europe and the US are joint controllers.

Mallinckrodt has put in place a data protection governance structure to ensure the data privacy rights and freedoms of Data Subjects are protected.

If you have any questions, comments, or complaints concerning our privacy practices, please contact us at privacy@mnk.com.  

 Types of Data We Collect

Personal Information means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person.

The following provides examples of the types of data that we collect from you and how we use the information.

Context

Types of Data and Purpose for Collection

Account Registration

We may collect your name and contact information when you create an account.

Demographic Information

We may collect personal information from you, such as your age or location.

Email Interconnectivity

If you receive email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners it contains.

Employment

If you apply for a job posting, or become an employee, we may collect personal information necessary to process your application.  This may include, among other things, your Social Security Number.

Feedback/Support

If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply.

Mailing List

When you sign up for one of our mailing lists we may collect your email address or postal address.   

Online Forms and Submissions

We collect information you submit to us on our websites or through online forms and registrations to process your requests, for example grant applications.

Order Placement

We may collect your name, billing address, shipping address, e-mail address, and phone number when you place an order.

Conduct of Normal Business Operations

We may collect your name, address, email, phone number, and banking details in the conduct of our legitimate day to day business activities.

Surveys

When you participate in a survey we may collect additional information that you provide through the survey.  If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless expressly indicated on the face of the survey we do not use survey information to market products or services to survey participants. If you are provided a separate privacy policy on part of a survey or study, the terms of that policy shall govern your information.

Seminars and Event Management

When you register for or attend a seminar or medical symposium, we may collect your name, contact information, job title, professional specialty, and dietary preference.

 

Third Party Tracking

Some of our websites may participate in behavior-based advertising.  This means that a third party may be allowed to use technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests.  If occurring, that advertising may appear either on our websites, or on other websites.  You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser.

Web logs

We may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit. Web logs may be used for things like monitoring website usage levels, diagnosing problems, and detecting cybersecurity threats.

Device Information

We may collect information about the device accessing the website such as MAC address, device type, and device identifiers.

Cookies

We may use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to your device while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them).  Among other things, cookies allow us to provide you with a more personal and interactive experience and to improve our marketing efforts. Persistent cookies may be removed by following instructions provided by your browser.  If you choose to disable cookies some areas or features of our websites may not work properly. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

Video Teleconferencing

(WebEx)

When you accept a teleconference call invitation, we will use your email address to register and manage the call and collect Personal Information relating to the management of this call. This information is retained for no longer than is required.

Where video conferencing is enabled, we also process video imagery of you.

While our teleconference system, (WebEx), does have a call session recording feature, the default is for this function to be disabled. A teleconference organizer may record a call session.

Clinical Trials

Third parties may process your personal data on our behalf as part of a formal clinical trial. Personal data collected by the Third party may include your name, address, health related information, age and biometric data relating to the trial.

Pharmacovigilance and Regulatory Requirements

We may process personal data to meet our regulatory pharmacovigilance requirements. Personal data may include your name, address, email address and in some cases, health related data.

Provision of Professional Education

We may process your personal data to assist in the provision of professional education regarding our products. This may include your name, address, email address and telephone number.

Call Center

We may process your personal data when providing customer service or product support via a call center. Personal data processed may include your name, address, email, phone number, and call recording.

Safety and Physical Security

As the safety of life is of the utmost importance to us, we may process your personal data to protect your health and safety while attending our sites. Personal information processed may include your name, address, age, location and contact details.

Provision of Voice Mail Services

We may process your personal data in the provision of voice mail services operating in support of day to day business operations. Personal data may include your name, phone number, email address and other details as may be provided by you, the caller.

 

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

Purposes of the Processing of Your Personal Information

In addition to the uses described above, we may use your personal information, sometimes combined with non-personal information, in the following ways:

  • To identify you when you visit our websites.
  • To provide the products, information, and services you request.
  • To improve and personalize your experience with us.
  • For order processing and to streamline your checkout process.
  • To conduct analytics and solve problems.
  • To respond to your inquiries related to support, employment, or other requests. 
  • To send marketing, sales and promotional materials, including information relating to our products, services, sales, newsletters, tips, or promotions.
  • In some instances, to provide you with advertisements.
  • For internal administrative purposes, as well as to manage our relationship with you.
  • For hiring purposes if you contacted us in connection with a job opportunity.
  • To monitor for cybersecurity threats.
  • To exercise our legitimate interests. Where we use legitimate interest as the legal basis for processing, we recognize Data Subjects always have a choice. To this end, we will keep you informed through a relevant privacy notice and facilitate your right to opt-out.

 

Sharing Of Personal Information

In addition to the specific situations discussed elsewhere in this Policy, we may disclose personal information in close relation to the purposes specified above to trusted third parties, collectively referred to as “Recipients.”

  • Affiliates and Acquisitions. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  If another company acquires our company, business, or our assets, we will also share your personal information with that company.
  • Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.
  • Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal or regulatory process, or to comply with relevant laws.  We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, for audit purposes, or a violation of our policies.
  • Service Providers. We may share your personal information with service providers that are committed to/or under appropriate statutory obligations of confidentiality.  Among other things service providers may help us to administer our website, conduct surveys, send communications and newsletters, register you for seminars, accept grant applications, provide call center services and provide technical support. These service providers may collect, store, analyze, or otherwise process information on our behalf.

 

Transfers to Other Countries

Some of the personal data we collect may be transferred to Recipients who are established in other countries, such as the United States. Transfers of EU personal data are based on an adequacy decision, standard contractual clauses, or your consent.

 Retention

We retain personal information for as long as reasonably deemed required for legal or business purposes. During these periods, we take all appropriate steps to ensure that the privacy of your personal data is maintained. For further details please contact privacy@mnk.com.

Your Rights and Choices

For Data Subjects in the EU, pursuant to and to the extent allowed by applicable law, you have the right to request access to, rectification, erasure, restriction of the processing concerning your personal data or to object to relevant processing activity and to receive in a structured, commonly used and machine readable format, such data relating to you.

Requests to exercise your rights must be sent to privacy@mnk.com.

Data Subjects in the EU also have the right to lodge a complaint with a Supervisory Authority. Mallinckrodt’s Lead Supervisory Authority is the Information Commissioners Office in the United Kingdom. Contact details are available at https://ico.org.uk/global/contact-us/.

California Residents.  California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us at privacy@mnk.com.

 

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While Mallinckrodt implements appropriate technical and organizational security measures to protect your personal information from unauthorized access, use, or disclosure, due to the public nature of the internet, however, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Cookies and Other Web Devices

Each website can send its own cookie to your web browser if your browser's preferences allow it. Cookie settings can be controlled in your internet browser to automatically reject some forms of cookies. If you view our websites without changing your cookie settings, you are indicating you consent to receive all cookies from the website. If you do not allow cookies, some features and functionality of our site may not operate as expected.

Mallinckrodt may use Adobe Flash technology (including Flash Local Stored Objects "Flash LSOs") that allow Mallinckrodt to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Site, and collect and store information about your use of the Site. Some of our websites or emails also use pixel tags, web beacons, clear GIFs, or other similar technologies to measure the success of marketing campaigns, and compile statistics about usage and response rates, and other purposes.

Mallinckrodt may use other web devices to track website usage and views. Please address any questions or concerns about our cookie or web device usage to the “Contact Information” contained in this Policy.

Miscellaneous

The following additional information relates to our privacy practices:

  • Minors. Our websites are not for individuals under age 13. Those individuals should not access a website or provide personal information to us.
  • Third Party Applications/Websites.  We have no control over the privacy practices of websites or applications that we do not own.
  • Changes to This Policy.  We may change our Policy and practices over time.  To the extent that our Policy changes in a material way, the version of the Policy that was in place at the time that you submitted personal information to us will generally govern that information.   

 

Last Revised: October 5, 2018