Privacy Policy
Effective Date: August 30, 2021
Acadia Pharmaceuticals Inc. (“Acadia”, “we”, or “us”) is committed to protecting and respecting your privacy, and we value your trust that we will protect your information. This Privacy Policy describes how we use, disclose, share, protect or otherwise process your Personal Information (as defined below). This Privacy Policy is incorporated into and made a part of our Terms of Use.
This Privacy Policy applies to the Personal Information we obtain through your use of our websites, mobile applications and any other website that links to this Privacy Policy (collectively, the “Site”); your interaction with us offline (e.g. at a convention or event); or other interactions you have with us.
This Privacy Policy contains information about your privacy rights and how you can exercise them. We encourage you to review this Privacy Policy and click on the available links below if you want additional information on a particular topic. Please read this Privacy Policy carefully to understand how we may process your Personal Information. If you do not agree with the terms of this Privacy Policy, please do not use the Site or otherwise provide any Personal Information to us.
- What type of Personal Information do we collect?
- How do we obtain your Personal Information?
- What are the legal bases for collecting and processing your Personal Information?
- How do we use your Personal Information?
- How will we share your Personal Information?
- How can you request access, amendment, or deletion of your Personal Information?
- Your Marketing Choices
- Additional Technical Information
- Security
- Retention of Personal Information
- Children’s Privacy
- International Transfer of Personal Information
- Third Party Website and Services
- Additional Information for Individuals in the European Economic Area, Switzerland, and the United Kingdom
- Additional Information for California Residents
- Changes to Privacy Policy
- Contact Us
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:
- Contact information, such as your name, email address, phone number, address, company affiliation, or job title;
- Access information, such as your log-in username and password details;
- Online and technical identifiers, such as your IP (Internet Protocol) address and cookies;
- Professional credentials, such as curriculum vitae/resume, work history, qualifications or any other type of information that may be included on a resume or curriculum vitae;
- Demographic and medical information;
- Communication and correspondence information, such as the content of communications you send us to report a problem or to submit a query, or your response to a survey for market research purposes;
- Financial and government identifying numbers, such as social security numbers; and
- Any other information that you provide to us that can be used to identify you.
2.How do we obtain your Personal Information?
We collect Personal Information from a number of sources, including:
- Directly from you, such as when you enquire about our products and services, contact us via the Site, apply for employment, ask to be a research study participant or a principal investigator in one of our trials, or in any way engage with us or our personnel;
- Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links in our emails;
- Through the use of social media platforms, such that if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
- Third party vendors, which may include those vendors, suppliers, contractors or business partners that provide services for us (e.g. market research vendors);
- Adverse event reporting reporters or subjects;
- Consumers and customers;
- Government officials; and
- Publicly available sources.
3. What are the legal bases for collecting and processing your Personal Information?
In certain jurisdictions, we are required to have a legal basis in order to process your Personal Information. The legal basis that applies will depend on your relationship to us and the nature of our processing activity:
- We may collect and use your Personal Information with your consent for the specific purpose identified in a notice given to you at the point of data collection.
- We may process your Personal Information 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.
- 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:
- to perform or enter into a contract;
- to comply with applicable laws, regulations, codes, court order or other legal obligations (e.g., pharmacovigilance obligations, financial disclosure requirements);
- to send communications (including documents and electronic messages or alerts) regarding our products and services and related materials;
- to respond to and fulfill inquiries and requests;
- to provide our products or services offered through the Site;
- to perform website analytics and understand usage trends to personalize your access to the Site;
- to recruit study participants;
- to conduct research and development activities for our products and services;
- to conduct market research relating to our products and services;
- to provide patients assistance;
- fraud and security monitoring;
- to enforce these privacy principles and to protect our rights or property; or
- for any other administration of legal and/or business processes that are in Acadia’s legitimate interest unless such use is prejudicial to your rights or your liberties.
We may also aggregate or de-identify your Personal Information so that it can no longer be used to identify you. This aggregated or de-identified information may be used for any purpose permitted by law and is no longer subject to this Privacy Policy.
5.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:
- Services by Third Party Providers: We may provide your Personal Information to our service providers that help us run and manage our organization and process Personal Information solely on our behalf. The categories of service providers may include delivery services, financial institutions, clinical research organizations, central laboratories, clinical database companies, payroll and benefit companies, and specialty pharmacies, among others.
- Corporate Transaction: In the event Acadia is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Information as part of that transaction.
- Third Party Collaborators: We may share your Personal Information with other companies with which we collaborate regarding particular products or services. These may include our co-promote partners for products that we jointly develop and/or market.
- As Required By Law: We may disclose your Personal Information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests or safety of Acadia, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use ; or (v) to respond to an emergency.
6. How can you request access, amendment, or deletion of your Personal Information?
If you wish to request access to the Personal Information we maintain about you, or that we amend or delete such information, you may do so by clicking here or following the instructions in the “Contact Us” section below. We will address your request in accordance with applicable laws. Please understand that we may not be permitted to comply with requests to amend or remove Personal Information that relate to consumer product complaints; adverse events or reactions involving medicine, medical products or medical devices; or other information that we are required to maintain in accordance with a court order or other legal or regulatory process.
7. Your Marketing Choices
If you are a recipient of marketing-related communications from us, you can unsubscribe at any time by following the opt-out instructions in the communication or by contacting us using the information in the “Contact Us” section below. Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
8. Additional Technical Information
Our Site automatically collects certain information when you use our Site, such as your IP address, browsing history (including without limitation search terms and clickstream data), device type, operating system information and other usage information about your use of the Site. We collect this information to analyze trends and statistics as well as for site administration purposes. We use cookies and other similar technologies to manage and customize your experience through our Site. If any of this information can be used to identify you because, for example, we link it to your Personal Information, we will treat such information as Personal Information. You may choose to decline cookies. You have the ability to delete cookie files from your hard drive at any time.
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.
Please read our Cookie Policy. for more information about our collection of your data through cookies and other technical processes.
9. Security
We implement technical and organizational measures designed to safeguard your Personal Information from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure.
10. 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.
11. Children’s Privacy
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.
12. International Transfer of Personal Information
Acadia is committed to complying with this Privacy Policy and data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. Acadia is located in the United States, and we recognize that the laws in the United States may be different and, in some cases, not as protective as the laws in other countries. By providing us with your Personal Information and using our Site, you acknowledge that your Personal Information may be transferred and processed outside of your home country. In this case, be assured that Acadia will take all the necessary measures to ensure that any international transfers of your personal information comply with applicable data protection and privacy laws. If you would like to know more about how we protect your Personal Information, you can contact us using the information in the “Contact Us” section below.
13. Third Party Websites and Services
When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.
14. Additional Information for Individuals in the European Economic Area, Switzerland, and the United Kingdom
Acadia is the data controller of the Personal Information collected under this Privacy Policy.
If you are located in the EEA, Switzerland, or United Kingdom and we maintain your Personal Information, you have the following additional rights with regard to your Personal Information:
- Right to be informed: You have the right to obtain from our European Data Protection Officer confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, all necessary information to make the process transparent.
- Right to access and receive: You may request a copy of or access to the Personal Information we hold about you. Under the European Union’s General Data Protection Regulation (“GDPR”) (and similar laws in Switzerland and the United Kingdom), 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.
- Right to portability: You may request that we transfer your Personal Information to a third party in a machine-readable format.
- Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.
- Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it.
- Right to erase: You may have the right to request that we delete all or some of your Personal Information. This right may be limited if we have collected your Personal Information for research purposes.
- Right to withdraw consent: You have the right to withdraw any consent you have previously given to Acadia at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.
- Right to complain: You have the right to lodge a complaint with your Supervisory Authority or with the Supervisory Authority where the alleged violation took place.
For those individuals located in the EEA or Switzerland, Acadia and its U.S. controlled 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.
15. Additional Information for California Residents
If you are a California resident, you can learn more about the Personal Information we collect from or about you through both your online and offline interactions with our products or services in the Supplemental Notice for California Consumers below:
| Acadia Pharmaceuticals Privacy Policy Supplemental Notice for California Consumers |
||
|---|---|---|
| Why? | The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information Acadia Pharmaceuticals collects about them, including whether it is being sold or disclosed to third parties. The CCPA also grants certain rights to California residents, including the right to delete their personal information (subject to certain exceptions) and the right to prevent Acadia Pharmaceuticals from selling their personal information. Companies are prohibited from retaliating or discriminating against consumers for exercising their rights under the CCPA.
All companies need to collect and share consumers’ personal information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons. This Supplemental Notice provides the information required under the CCPA and applies to both Acadia Pharmaceuticals’ online and offline activities. For more information about how we collect, use, and share information through our websites and online services, please review our Privacy Policy. |
|
| What? | The types of personal information we collect and disclose depends on your relationship and interaction with Acadia Pharmaceuticals. Please review the Consumer Type below that applies to your relationship or interaction with Acadia Pharmaceuticals to learn about the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting the personal information, and the categories of third parties with whom we share the personal information. If you interact with Acadia Pharmaceuticals in more than one way, please review each Consumer Type below that applies to you in order to learn about the personal information we collect and how we use and share it in connection with each particular relationship.
In addition to the purposes for collecting and sharing personal information described under each Consumer Type below, Acadia Pharmaceuticals collects and discloses any and all personal information (regardless of your relationship or interaction with us) as necessary or appropriate to: comply with laws and regulations; monitor, investigate potential breaches of, and enforce compliance with Acadia Pharmaceuticals policies and procedures and legal and regulatory requirements; comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and exercise or defend the legal rights of Acadia Pharmaceuticals and its employees, affiliates, customers, contractors, and agents. |
|
| Disclosure About Direct Marketing | California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to other entities for their own direct marketing purposes in the preceding calendar year. Acadia Pharmaceuticals does not distribute your personal information to other entities for their own direct marketing purposes, except as provided for in our Privacy Policy. | |
| Personal Information | Personal Information In this Supplemental Notice, “personal information” (or “PI”) means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly. In the charts below, we use the following categories of personal information to describe the personal information we collect, use, and share about consumers: | |
| Identifiers | Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, phone number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | |
| Biometric Information | Biometric information, including an individual’s physiological, biological, or behavioral characteristics (including DNA) to the extent it can be used to establish individual identity. Biometric information consists of, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template (such as a faceprint, a minutiae template, or a voiceprint) can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | |
| Commercial Information | Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | |
| Education Information | An individual’s education information, including academic information and records. | |
| Electronic and Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call or profile photograph). | |
| Geolocation Data | An individual’s precise geolocation data. | |
| Inferences | Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies). | |
| Network Activity Data | Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. | |
| Professional Information | An individual’s professional or employment-related information. | |
| Protected Characteristics | Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion. | |
| Other Identifiable Information | An individual’s written signature; health insurance information, including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history; medical information, including any information in possession of or derived from a health care provider, health care service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment; and financial information, including bank account number, credit or debit card number, or other financial information. | |
| Sources of Personal Information | Received From . . . | Example Collection Methods and Circumstances |
| You (directly) |
|
|
| Your devices |
|
|
| Health care providers |
|
|
| Health insurance providers or other payors |
|
|
| Caregivers |
|
|
| Event organizers |
|
|
| Lead generators |
|
|
| Third parties who verify the information that you provide (e.g., consumer reporting agencies) |
|
|
| Third parties who help us maintain the accuracy and completeness of our records (e.g., data brokers) |
|
|
| Third Parties to Whom We Disclose PI | Disclosure to . . . | Example Circumstances for Disclosure |
| Service Providers |
|
|
| Authorized/legal representatives, family members, and caregivers |
|
|
| Health care providers |
|
|
| Health insurance providers or other payors |
|
|
| Public authorities |
|
|
| Your Rights | If you are a California resident, you have the following rights under the CCPA with respect to your personal information:
You can exercise your rights by calling (844) 422-2342 or by clicking here to submit your request through our web portal. VERIFICATION: We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully.
You may also authorize someone else to submit these requests on your behalf. To do so, you may execute a power of attorney pursuant to California Probate Code sections 4121 to 4130. You may also authorize a third party to submit these requests on your behalf by providing that third party with your signed permission to do so. If you authorize a third party to submit requests on your behalf, we may need to contact you directly to verify your identity. |
|
| Questions? | Call (844) 422-2342 or email us at privacy@acadia-pharma.com to contact us with questions regarding this Supplemental Notice. California residents who are unable to review or access this Supplemental Notice due to a disability may contact us to request access this Supplemental Notice an alternative format. | |
Website Visitors
| Categories of PI Collected |
Sources of PI | Purposes for Collecting or Sharing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
|
|
|
|
Patients
| Categories of PI Collected |
Sources of PI | Purposes for Collecting or Sharing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
|
|
|
|
Health Care Professionals (HCPs) and Caregivers
| Categories of PI Collected |
Sources of PI | Purposes for Collecting or Sharing PI | Third Parties to Whom We Disclose PI |
|---|---|---|---|
|
|
|
|
16.Changes to this Privacy Policy
Acadia reserves the right to modify this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.
17.Contact Us
Acadia is the data controller of the Personal Information collected under this Privacy Policy. We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below and we will respond to you as soon as reasonably possible.
Acadia Pharmaceuticals Inc.
12830 El Camino Real, Suite 400
San Diego, CA 92130
Email: privacy@acadia-pharm.com
For Individuals Located in the European Economic Area, Switzerland, or the United Kingdom:
If you have a question about your Personal Information or would like to exercise your data protection rights, please click here to submit your request through our web portal or contact our European Data Protection Officer:
Name: Data Compliant Limited, Attention: Michelle Evans
Address: 25-26 Nethergate Street, Clare, Suffolk, CO10 8NP, United Kingdom
Phone: 01787 277742
Email: acadiadpo@datacompliant.co.uk