Insmed Privacy Policy (Insmed AU CLINICAL Services)

Insmed ("Insmed" or "we" or "us") takes your privacy very seriously. This privacy policy (“Privacy Policy”) is intended to inform you about the personal data that is collected from you when you use the website located at www.willowstudyportal.com (“Website”), use our products and services, or otherwise provide us with your personal data; how this personal data may be collected, stored, used and disclosed; how you can control the use and disclosure of your personal data; how you can complain about our use of, request access to, or correction of, your personal data; and how your personal data is protected. If you have any questions about this Privacy Policy, please contact our privacy team at privacyAPAC@insmed.com.

By accessing the Website, using our products and services, or otherwise providing us with your personal data, you acknowledge that you have read and accept the terms of this Privacy Policy and expressly consent to the collection, storage, use and disclosure of your personal information in accordance with the terms of this Privacy Policy.

This Privacy Policy is in addition to any other terms and conditions applicable to the Services, including those set out in our Terms of Use. In order to fully understand your rights, we encourage you to also consult our Terms of Service.

If you do not feel comfortable with any aspect of this Privacy Policy, you must immediately leave the Website and discontinue your use of our products and services.

  1. Personal data we collect

    So that we can provide you with our Website, products and services, and respond to your direct contact (collectively, the “Services”), we may need to collect data from you or about your use of our Services as described below.

    When you use our Services we may collect your personal data from you, including:

    • contact information, such as name, specialty, email address, postal address, phone number, and mobile number;
    • your age range and information about your health where you consent to such collection;
    • your browser type and operating system;
    • web pages that you view, and links that you click on, while using our Services;
    • standard server log personal data including your IP address, data, time and duration of your access or use of our Services, page views, the referring URLs, and any other information about your activities on our Services;
    • correspondence you send to us; and
    • personal data collected through cookies, web beacons, and similar technologies (please see below for details).
  1. How we process and use the personal data that we collect

    We collect personal data so that we can carry out our business activities in a professional and efficient manner, and to improve our Services. We also collect your personal data for the purposes stated below:

    • To identify our customers, potential customers, and people acting on their behalf

    We use your personal information to set-up and configure customer accounts, record and maintain user details and profile information, respond to your enquiries and concerns, and to resolve disputes.

    • Email communications

    With your consent, we may use the personal data that we collect to send you e-mail communications, such as editorial updates, information about your account or changes to our Services. We also may send you relevant newsletters, announcements, promotional material, or requests to participate in market research. Consent can be withdrawn at all times by opting out from future communications.

    • Request fulfillment

    We may use the personal data that we collect to fulfill your requests for information and Services, which may include assessing your eligibility for clinical trials in which you have applied to take part. We will inform you about any additional use of your personal data and obtain your consent if required by applicable law.

    The collection of your health data is based on your explicit consent, and will be used only for the purpose of assessing your eligibility for clinical trials in which you have applied to take part.

    • Operation of our business

    We use technical information for our legitimate interest, namely to render our Website, create statistics on the use of our Website and to ensure the security of our Website. As explained more fully below, our Website uses cookies, some of which may require your consent. We also use this information to improve our Service offerings to our customers.

    • Customer support

    We use personal data we collect about you to provide customer support to you, respond to your enquiries, resolve disputes, and contact you regarding your use of our Services.

  1. Personal data sharing

    We value your privacy, and share personal data about our users only under certain circumstances. We will make personal data about you available to other companies, applications, or people in the circumstances listed below:

    • We may share aggregated personal data or personal data that does not directly identify you with third parties to help us develop content, websites, and advertising that we hope you will find of interest. We do not use your health data for this purpose. Please note that we do not share personal contact information with third parties that advertise on the Website.
    • We may employ third parties to perform services for us, including database management, maintenance services, analytics, marketing, data processing, and email and text message distribution. We may also share your personal information with third party business advisors, including auditors and lawyers. These third parties have access to your personal data only to perform these tasks on our behalf and subject to the required contracts on data processing.
    • We may share personal data about you with third parties involved in a business transaction with us, as permitted by applicable law. For example in the event that a merger, acquisition, or sale of all or part of our assets occurs. However, we will notify you by placing a prominent notice on our Website or sending a notice to the primary email address specified in your account before your personal data is transferred and becomes subject to a different privacy policy. Such sharing of your health data will be based on your prior consent.
    • We may share personal data about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, or if required by law, and in other circumstances in which we have a good faith belief that sharing is necessary. We want the Website to be a safe and friendly community.
    • We may share your personal data with our related entities.
    • We may share personal data about you to respond to law enforcement authorities.
    • In addition to the scenarios identified above, we may share personal data about you for any other purposes disclosed to you at the time we collect your personal data or pursuant to your consent.
    • If you are applying to participate in a clinical study, and the information you provide indicates that you are eligible to participate, then we will forward your information to your chosen Study Centre (as specified on the Website). If you are not eligible, then we will delete from our databases any information you have provided. We will not share or disclose your health information to any other third party.
  1. Cookies and similar technologies

    We collect limited data about our users so that we can track the use of our Services, maintain and improve our Services, and understand how our users navigate through and use our Services. This data is collected about you automatically through cookies and other technologies.

    Data we collect may include:

    • server and/or internet protocol (IP) addresses;
    • top level domain names;
    • the date, time and duration of your visit;
    • pages accessed and documents downloaded;
    • referring and exit pages;
    • whether you are a returning visitor;
    • the type of browser used; and
    • the hardware type and operating system of the computer or device used.

    Cookies

    Cookies are small amounts of information stored in files within your computer's browser. Websites can access only the cookies that they have stored on your computer.

    We use cookies for the following purposes:

    • To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was using the Website;
    • To help us customize the content you see when you use the Website; and
    • To help measure and research the effectiveness of our interactive online content, features, advertisements, and other communications.

    Statistical Analysis

    In order to learn more about how our Services are used, we aggregate and analyze the data that we collect. We may use this aggregated data, for example, to monitor and analyze use of the Services, to increase the functionality of our Services, and to better tailor our content and design to suit our visitors' needs.

    Google Analytics

    Our Website uses Google Analytics, a web analytics Website provided by Google, Inc. (“Google”). Google will use this data for the purpose of evaluating your use of the Website, compiling reports on the Website activity for Website operators and providing other Websites relating to Website activity and internet usage. The IP address/UDID transmitted by your browser in the context of Google Analytics will not be associated with other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser/device, or you can avoid the collection of data generated by the Google Analytics cookie and relating to your use of the Website (including your IP address/UDID) and the processing of such data by Google by downloading and installing the browser plugin available at http://tools.google.com/dlpage/gaoptout?hl=de. You can find more information on terms of use and privacy at http://www.google.com/analytics/terms/de.html.

    Your choice

    You can change your browser settings to reject all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that you may need to renew these settings, if you delete your cookies after these preferences are made. These settings also may not apply, if you are using a different computer or internet browser. Some of the services may not work properly if you opt-out of cookies.

    Please remember that we do not have access to, or control over, the cookies used by third party website providers, and the personal data practices of third parties are not covered by this Privacy Policy.

  1. Your rights and choices

    In accordance with the law, you may at any time request to access, rectify, complete, update, block, move, or delete your personal data, by contacting us at privacyAPAC@insmed.com.

    Where our processing of your personal information is based on your consent, you can withdraw your consent to the processing of your health data at any time, in which case we will delete your information.

  1. Confidentiality and security

    We limit access to personal data about you to employees or contracted third party service providers who we believe reasonably need to come into contact with that personal data to provide products or Websites to you or in order to do their jobs. All our employees and contracted third party service providers engaged in processing personal data have been obligated to maintain confidentiality. We also have adopted technical, physical, and administrative procedures that are adequate to help protect personal data about you from loss, misuse, and alteration.

    Please note that no electronic data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using our Services, but we cannot warrant the security of any personal data you transmit to us. We take all reasonable steps to keep the personal data we hold about you secure and free from loss, misuse and alteration, however even the largest enterprises of the world experience data vulnerabilities. You acknowledge that you are responsible for the security of your personal data by taking precautionary measures, such as keeping your account password confidential and using secure wireless connections.

    Your personal data will be retained for as long as necessary to provide the requested service or until you withdraw your consent, unless we are obliged by law to retain the data.

  1. Overseas transfer of personal data outside of Australia

    As a global organisation, we may store, use, transfer, and otherwise process your personal information in countries outside of the country of your residence, including jurisdictions outside Australia where Australian information will be transferred or stored, e.g. the U.S., E.U. These transfers will be based on contractual guarantees aimed at providing a level of protection which is at least equivalent to the protection enjoyed in your home jurisdiction. For more information and a copy of these terms, please contact us at: privacyAPAC@insmed.com.

  1. Changes to the Privacy Policy

    We may update this Privacy Policy at any time to reflect changes in our practices and Services offerings. If we modify this Privacy Policy, we will update the "Effective Date." We will notify you of any material changes in the way we treat your personal data by placing a prominent notice on our Website or sending a notice to the primary email address specified in your account.

  1. Questions, suggestions and complaints

    If you have questions, suggestions or complaints about this Privacy Policy, or the manner in which we have collected, stored, used or disclosed your personal information, please contact our privacy team at privacyAPAC@insmed.com. We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation. We will ensure that we respond to your complaint within a reasonable time (and in any event within the time required by privacy and data protection legislation in your jurisdiction).

    If you still have concerns about the collection and use of your personal data, you have the right to lodge a complaint with the Australian Office of the Information Commissioner (see https://www.oaic.gov.au).

    This website is not intended for and should not be used by individuals under the age of 18.

Effective Date: 01 October, 2018

MED-00104