Revised as of November 28, 2012
Who We Are
Thank you for your trust in Novartis Pharmaceuticals Corporation (Novartis), and for taking the time to read our Privacy Statement. We are an affiliate of the Novartis Group, a world leader in healthcare with core businesses in pharmaceuticals, consumer health, generics, vaccines and diagnostics. This Privacy Statement tells you how we protect the privacy of personal information that you may provide to us.
"Safe Harbor" Certification for Privacy
As part of our commitment to privacy, Novartis has voluntarily certified to the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. This means that Novartis has voluntarily implemented a set of privacy standards that are approved by the United States and European and Swiss governments for companies in the United States. Only a small percentage of US companies have certified to the Safe Harbor privacy standards. More information about our Safe Harbor privacy standards is provided in the link below.
The purpose of this privacy statement is to explain what Novartis does with personally identifiable information that you provide to us, such as your name, address, age, and information relating to your medical conditions. We want you to know how your personally identifiable information will be protected, who we may share it with, and for what purposes.
Reason for Collection of Your Information
Many of Novartis' services to customers, such as browsing our product and health websites, do not require any form of registration or identification. You can freely visit many of our websites without telling us who you are. However, some of our services, such as programs that you sign up for to receive free information, require registration. (Some fields are required and some are optional.) This allows us to send you information that you request or contact you about Novartis products and services on either a one-time basis, or longer.
Personal Information Collected From You
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, gender, e-mail address, and information about your medical conditions. Novartis limits the collection and processing of personal information to what is necessary to fulfill the purposes for which it is to be used.
Consolidation of Information Collected From You
Many of our customers register for more than one Novartis program or service, through our websites, by calling Novartis, or through a third-party such as their healthcare provider. When you register with us more than once, we may combine your personally identifiable information as well as any anonymous computer information collected (see below) and store it collectively. This helps us keep track of all of your preferences in one organized place, and helps us provide information to you based on a more informed review of your requests and medical conditions of interest.
Safe Harbor Privacy Standards
Please visit the Safe Harbor Privacy Statement
Novartis takes reasonable steps to ensure that personal data collected is reliable for its intended use, accurate, complete, and current.
Collection of Anonymous Computer Information
When you visit our websites, we do not collect any personally identifiable information about you without your permission. However, we do collect anonymous information about you if your computer is set to allow that type of collection. (You can turn off the ability to collect some of this information on most computers.) This type of anonymous information allows us to evaluate customer interest in our websites and perform other market research activities, such as your browsing habits on our site. It also allows us to track customers who come to our websites based on website advertisements about Novartis products or services. (For those who are interested in the details, some of the typical computer techniques we may use are "cookies", "internet tags" which are also called "action tags", "single-pixel GIFs", clear GIFs, "invisible GIFs, and "1-by-1 GIFs). If you would like more information about web tags and cookies associated with on-line advertising or how to opt-out of third-party collection of information, please visit the Network Advertising Initiative website, an independent website not sponsored by or affiliated with Novartis.
Consent to Provide Your Information to Novartis
We request your consent to collect your personally identifiable information when you seek to register for a Novartis program or service. In doing so, we also explain, for that program or service, what you are registering to receive and how we plan to use your personal information. We also offer you the option of discontinuing your consent ("opting out" or "unsubscribing") if you later decide that you no longer want to participate in that program or receive additional information from us. If we wish to use this information for purposes incompatible from those for which the data was initially collected, we will offer an effective way to opt out of the secondary use.
Sharing Your Information With Third-Parties
Novartis will not share your personal information with third-parties (other marketers) for their own separate use unless we have obtained your opt-in consent to do so. When you provide personally identifiable information to Novartis, it will be accessible to some of Novartis' business partners, such as companies we retain to fulfill requests for information, answer telephone calls from consumers, or provide assistance to us on specific programs or projects such as newsletters. In addition, Novartis enters into business relationships with other companies, such as for joint marketing of a product, or for the sale of a Novartis medication. In those cases, the other companies may also have access to your personally identifiable information. Novartis requires third-parties to whom it discloses personal data to protect personal information using substantially similar standards to those required by Novartis. We also require that they do not use your personal information for any separate use that is not specifically authorized by Novartis.
There may also be instances where Novartis may be required to share your information with third-parties who have not been retained by us (directly or indirectly), such as with health authorities to report possible adverse drug experiences, during inspections or audits, 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 Novartis Group of Companies
The information that you provide to Novartis may sometimes be shared with other departments within Novartis, as well as Novartis subsidiaries and affiliates within the Novartis global group. This may mean that your personally identifiable information may be transferred outside of the US to Novartis affiliates or companies in other countries. Other departments within the Novartis group, and other Novartis companies that may receive your information will abide by substantially similar privacy requirements relating to your personally identifiable information.
Security of Your Information
We use appropriate technical, administrative and physical safeguards to protect data that pertains to you from loss, misuse or alteration. In addition, we take steps to ensure that our safeguards take into account new known threats. Of course, no organization can guarantee the absolute security of personal information. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100% secure or error-free. Accordingly, we also caution you to guard your own computer and password against unauthorized access by others.
Transfer of Your Information
When Novartis transfers personal information to countries other than the country where the information was provided, we do so in compliance with applicable privacy laws. We protect personal information entrusted to us no matter what country it is stored in or transferred to and have appropriate procedures in place to help ensure the security of your personal information. As noted above, we also adhere to the US Department of Commerce's Safe Harbor standards concerning the transfer of personal data from the European Union and Switzerland to the United States of America.
Protection of Children
Novartis will not knowingly collect, use or disclose personally identifiable information from a minor under the age of 13, without obtaining prior consent from a person with parental responsibility (parent or guardian). Novartis abides by the Children's Online Privacy Protection Act (COPPA) in the United States, and respects similar laws of other countries that protect the privacy of children. Should a child whom we know to be under 13 provide personally identifiable information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving information about him or her.
Our privacy practices are periodically reviewed by our auditors to verify compliance with this Privacy Statement.
Updating 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.
In addition, Novartis complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. In addition, in order 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 the identity of the requesting individual.
Updated Novartis Privacy Policies
This Privacy Statement becomes effective on November 28, 2012. Novartis may update this Statement from time to time. We encourage you to review our Privacy Statement periodically.