Effective Date: January 22, 2020
1.What type of Personal Information do we collect?
“Personal Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location, or factors specific to physical, physiological, genetic, economic, cultural or social identity. We may collect and process the following Personal Information about you:
2.How do we obtain your Personal Information?
We collect Personal Information from a number of sources, including:
3. What are the legal bases for collecting and processing your Personal Information?
We collect and use your Personal Information with your consent for the specific purpose identified in the individual notice given at the point of collection or in order to manage or fulfill our contractual relationships. For example, in some circumstances, processing of your Personal Information is necessary to fulfil our or your (at your request) obligation in a commercial, employment or service contract. In addition, we may need to collect and process your Personal Information to comply with our legal obligations and/or fulfill our legitimate interests.
We are committed to collecting and processing your Personal Information in a lawful and transparent manner. For further details on the legal bases Acadia assigns for particular data collection and use, please reference the below table.
|Use of your Personal Information||Categories of Personal Information we Process||Categories of Personal Information we Process Source of the Personal Information||Legal Basis|
|Sharing for the provision of products or services||Contact information||You||Contract: To allow for the secure transfer and processing of personal data|
|Reviewing requests to participate in research studies and screening eligibility for enrollment||Contact information, research study participant qualification information, and other information relevant to your eligibility and qualifications to participate in research studies sponsored or conducted by Acadia||You and your health care provider||Legitimate interest: To ensure research subjects are eligible and appropriate for the studies we sponsor or conduct|
|Respond to inquiries and fulfill requests||Contact information and other information you provide, such as your requests||You||Legitimate interests: To provide you with information you need and other services you request and to efficiently communicate with you|
|Register you for events and deliver event-related materials||Contact information and other information you provide, such as your preferences for the event||You||Legitimate interests: To enable your attendance at our events and to deliver you event materials
Contract: As may be described on the registration page for the event
|Recruiting personnel for employment||Contact information, recruitment information, and other information relevant to potential recruitment by Acadia||You, your references, your former employers||Pre-contractual Measures: To recruit and evaluate potential candidates to join Acadia
Legal obligations: To comply with applicable legal obligations, including for employment law purposes
Legitimate interest: To make the best recruitment decisions for Acadia
|Perform website analytics||Technical information and other information we collect, such as demographics, behavior tracking, and event tracking||First and third party analytics cookies||Consent: To understand more about our Site visitors (what pages you view, how long you visit, your devices, etc.) in order to improve our services|
|Obtain your subscription preferences and send marketing communications, surveys, questionnaires, or event related materials||Contact information and other information you provide, such as your topic preferences and areas of interest||You||Consent: To provide you with marketing communications, surveys, questionnaires, information you need and services you request and to efficiently communicate with you|
|Conduct surveys and questionnaires||Contact information and other information you provide, such as your survey answers||You||Consent: To evaluate and take action with regard to your feedback and comments about Acadia|
4.How do we use your Personal Information?
Subject to applicable privacy laws, the Personal Information we collect from you may be used for the following business purposes:
5.Technical Information and Do Not Track Policy
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Acadia leverages third-party analytics and market performance tools in the administration of its consumer and professional websites. As a result, we have employed best practices and policies to respect browsers using the DNT signal. Acadia respects this tag through applied policies in software developed for Acadia as well as our use of tools to help provide better services and messaging to consumers and healthcare professionals. Acadia assumes no liability for policies of or failure to comply with the DNT signal by our partners or vendors.
6.How will we share your Personal Information?
We will share your Personal Information within Acadia, at your direction, as disclosed to you at the time of collection, or in the following circumstances:
7.International Transfer of Personal Information
For those individuals located in the EEA or Switzerland, Acadia and its controlled United States subsidiaries have certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks for the transfer of personal data from the EEA and Switzerland to the United States, as described in our Privacy Shield Notice. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and to view our certification, please visit www.privacyshield.gov.
8.Third Party Websites and Services
In order to comply with the law, you understand that we may not be permitted to comply with your request to amend or remove Personal Information that was provided to us by you or a healthcare provider regarding a consumer product complaint, an adverse event or reaction involving medicine, medical products or medical devices or required disclosures of your Personal Information as required by court order or other legal or regulatory process (“Legal Requirements”).
We implement technical and organizational measures designed to ensure your Personal Information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with our services. If you would like to know more about how we protect your Personal Information, you can contact our Data Protection Officer using the information listed below.
11.Retention of Personal Information
We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements. If you would like to know more about how long we keep your Personal Information, you can contact our Data Protection Officer using the information listed below.
Our services are not directed to or intended for use by individuals under the age of 16, and we request that these individuals do not use this Site or provide us with any Personal Information. Consistent with the requirements of applicable laws and regulations, if we learn that we have received Personal Information directly from a child under age 16 without his or her parent or legal guardian’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.
For EU residents, if you wish to receive marketing-related emails from us, please tick the “I agree” box at the bottom of any marketing email. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any marketing email or by emailing us using the information in the section “Contact Us.” Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
14.How can you access your Personal Information?
You may request access and modifications to the Personal Information, other than information described under Legal Requirements, we maintain about you by contacting us using the contact information below. We will respond to your inquiry within 30 days. If you wish to exercise any of your rights (including the rights of individuals in the EEA discussed below) or advise us of any changes to your Personal Information, please contact our Data Protection Officer using the contact information provided below. Under the European Union’s General Data Protection Regulation (“GDPR”), a response to a Data Subject Access Request will be provided free of charge, unless the request is deemed to be manifestly unfounded, excessive or repetitive in character. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.
15.What are the special rights of individuals in the European Economic Area?
If you are located in the EEA and we maintain your Personal Information, you have the following additional rights (under the GDPR) with regard to your Personal Information. Note that some of these rights may not be exercisable if you are a patient.
16.Special Notice to California Residents
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.
Acadia Pharmaceuticals Inc.
12830 El Camino Real, Suite 400
San Diego, CA 92130
If you are located in the EEA and have a question about your Personal Information, please contact our Data Protection Officer: