PRIVACY POLICY AND COOKIES

Effective Date: February 1, 2020

Policy Scope

Policy Scope

This Privacy Policy (Policy) sets forth the BTG Specialty Pharmaceutical (BTG) privacy practices regarding the collection and use of personal data relating to BTG websites (Sites) addressing Europe and Switzerland, including mobile sites and our applications. BTG is dedicated to treating people with respect, transparency, and integrity; therefore, we don’t sell or lease your personal data to a third party. This Policy also describes your choices regarding our use of your personal data and how you can access and update your information. When we refer to BTG, we mean BTG International Inc, including our affiliates and subsidiaries. BTG adheres to privacy best practices, including the Generally Accepted Privacy Principles (GAPP), and complies with international personal data transfer framework requirements.

International users who access our international, EU and Swiss Sites and applications or provide information to BTG, understand and agree with BTG’s legitimate interest to collect, use, disclose, retain and transfer your personal data to the United States and other countries and territories for the purposes stated in this Policy. This includes, but is not limited to, the transfer of personal data between BTG's third parties, affiliates and subsidiaries located in the United States and globally.

BTG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework(s) (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland, to the United States in reliance on Privacy Shield. BTG has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

BTG remains accountable for onward transfers of EU and Swiss personal data to third party agents acting on BTG’s behalf, where those parties have processed personal data in a manner inconsistent with the Principles, unless BTG proves it is not responsible for the event. The U.S. Federal Trade Commission has jurisdiction over BTG’s compliance with Privacy Shield. If you have an unresolved privacy or data use concern that BTG has not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, JAMS Privacy Shield Program, (free of charge). Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

BTG protects any EU and Swiss information transferred to other third countries by introducing privacy provisions to our contracts with online providers or by ensuring the providers adopt the EU standard model clause of the European Commission to ensure information are protected in an adequate manner.

Table of Contents

  • Information Collection & Use
  • Data Sharing & Onward Transfers
  • Cookies & Similar Technologies
  • Access & Choice
  • Security
  • Links to Other Sites
  • Minors
  • California Privacy Rights & Do Not Track Disclosures
  • Updates to Privacy Policy
  • Contact, Questions, Comments, Complaints

Information Collection & Use

Personal data is data that can be used to identify or contact you, such as your name, email address, telephone number or similar information. BTG collects personal data you voluntarily give us, such as but not limited to, requesting information via our Sites, resume submission, online event registration, or Site registration. We provide interactive digital health tools through which information is collected from users. We also collect information about your interactions with our Sites and applications (e.g., browsing behavior). Our Sites automatically track certain behavior (Usage Data) during visits, such as, referring/exit URLs and we also collect other basic information about you which does not directly identify you but which may correspond with you or a particular device. We use this information to learn more about how our websites and online resources are used and to otherwise improve and administer the site. We also use this information to enable us to deliver information tailored to your interests and preferences, based on your use of the site. For example, we may collect the Internet Protocol Address assigned to your computer by your internet service provider. This address may change each time you connect to the internet (a “dynamic” IP address), or it may remain the same (a “static” IP address). In most cases, this information is collected automatically, for our legitimate business interests. In some jurisdictions, we are required to ask for your consent before collecting this information, in which case you will be presented with a choice as to whether you wish to allow the collection and use of this type of information, generally this will present itself in the form of a consent banner (providing you with a choice to accept or reject such collection). If you are a registered user, we may use your Usage Data with or without your personal data, in order to measure the Site's performance and improve the Site's design and functionality.

We may also collect the following voluntarily from you:

Information about your business such as company name, company size, business type or your position in the company
  • Medical condition
  • Demographic information such as age, education, gender, interests and location
  • Contact information such as email address and phone number
  • Testimonials
  • Site survey responses
  • Site blog and community forum posts
  • Transaction history.
  • We use this information to:
  • Send you product updates, newsletters, marketing communications, requested product or service information, fulfil services you have requested, and to understand your interests and preferences.
  • Respond to your questions
  • Administer your account
  • Conduct surveys or other research and analysis
  • Improve our Site and marketing efforts
  • Optimize user experience
  • Display personalized content
  • Deliver promotional material where allowed by law
  • Enable you to post your resume, search job postings, and contact or be contacted by prospective BTG representatives or agents
  • Notify you of Policy updates

We may also collect from you the following personal data about your contacts:

  • Email Address, in order to share information or messages

When you provide us with personal data about your contacts we will only use it for the specific reason for which it is provided. If you believe one of your contacts has provided us with your personal data and you want to submit a removal request, please contact us at Globalprivacy@bsci.com or at EuropePrivacy@bsci.com or through our Data Subject Request Form if you are located in the EU, Swiss, or EEA zone.

Licensed medical professionals must provide additional personal data to register (e.g., profession, title, Medical ID and clinical affiliation) in case of websites with restricted access. In addition to the uses mentioned above, we use this data to review and verify your registration. We may obtain additional information about you from other sources through your Unique Physician Identification Number (UPIN). We use small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit BTG to collect information about you.

Job applicant personal data is used solely for the purpose of the employment process. It is retained only for the purpose of considering your application for current BTG positions or as necessary to comply with the law.

We may use your personal data to support the activities of unaffiliated third parties that are under contract to perform services for or on behalf of BTG (including to maintain computer database, perform marketing activities when allowed by law, or conduct surveys). For example, personal data collected through interactive digital health tools we provide may be used to improve these tools and determine payment amounts for vendors who assist us in making these tools available.

Data Sharing & Onward Transfers

BTG won’t sell or lease your personal data to a third party; however, there are certain circumstances where we may share your personal data without additional notice to you. In addition to the disclosures described throughout this Policy, and subject to applicable law, we and our third parties may disclose your personal data:

  • To affiliates and subsidiaries for purposes consistent with this Policy;
  • To unaffiliated third parties that are under contract to perform services for or on behalf of BTG (e.g., to maintain computer database, perform marketing activities, or conduct surveys);
  • In the event of a corporate sale, merger, reorganization, dissolution or similar event;
  • To other persons as permitted by applicable law or regulation; and
  • To law enforcement personnel and agencies, including to meet national security requirements, or as part of a legal process, in order to protect our property or in furtherance of an investigation regarding a breach of the Site rules and policies, unauthorized access to or use of the Site or any other illegal activities.

We may share aggregate data with selected third parties. For example, BTG may disclose aggregate Usage Data to third parties to understand how the Site is used or for marketing purposes. See also "Cookies", below. Aggregate data does not identify individuals.

The access granted to our affiliates, subsidiaries, and third parties is limited solely to the purpose for which such information was provided. Furthermore, we require our affiliates, subsidiaries and third parties to uphold and maintain BTG’s policies with respect to privacy and the treatment of your personal data. Regardless of their locations or the laws of the countries they are based in, they are contractually required to provide at least the same level of protection as required by the Privacy Shield Principles.

Cookies & Similar Technologies

BTG and our partners use a variety of technologies to facilitate the delivery of services to you via our Sites and applications and to understand and preserve your personal preferences. Use of these is governed by our Policy or the privacy policy of the third party providing the service.

Please check our Cookie Policy 

Access & Choice

Registered users and those who have provided BTG with personal data may request to review, change or delete information by logging in and modifying their profile, by e-mailing info@btgsp.com. Deletion or change requests should be made by you directly. We will respond to all access requests within 30 days.

To "opt-out" of (1) having your Site provided personal data disclosed to third parties for promotional purposes, or (2) any other consent previously granted for a specific purpose concerning your personal data on this Site, send an e-mail to BTG at info@btgsp.com. To "opt-out" of receiving a particular marketing or promotional communication, follow the unsubscribe instructions included in the specific communication.

If you wish to update or delete a testimonial you submitted, please contact us at info@btgsp.com.

The information you post in publicly-accessible Site blogs or community forums may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@btgsp.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Data Retention

We retain your information while your account is active or as needed to provide you services. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

BTG takes security seriously. We use reasonable and appropriate data protection measures, such as robust technologies, security policies, and procedures, to reduce the risk of misuse, alteration, accidental destruction or loss, and unauthorized disclosure or access to our systems and data. For example, we encrypt the transmission of sensitive information using secure socket layer technology (SSL). We follow industry standards and best practices to protect your personal data during transmission and once we receive it. Unfortunately, no security method is 100% secure; therefore, we cannot guarantee absolute security. Please email any Site or application security questions to info@btgsp.com.

Links to Other Sites

This Policy applies only to BTG Sites and applications that link to this Policy. Our Sites include links to both our affiliated sites and to non-BTG web sites, including access to content, products and services of such affiliated and non-affiliated sites (Other Sites). BTG is not responsible for the privacy practices of Other Sites. You should directly contact these Other Sites to read their privacy policies and for more information about their practices.

Minors

Our Sites and applications are not intended for use by individuals under the age of 18, and BTG does not knowingly collect personal data from those in this age group. If you are under 18, please discontinue the use of our Sites and applications. If we become aware that someone under the age of 18 has registered, we will expunge any related personal data from our records.

California Privacy Rights & Do Not Track Disclosures

The BTG Specialty Pharmaceuticals Privacy Notice for California Residents  provides additional information for California residents under the California Consumer Privacy Act of 2018 (CCPA).

Please be aware BTG does not respond to your browser’s Do Not Track signals

Updates to Privacy Policy

BTG may, in its sole discretion, update this Policy by posting the amended Policy on this Site. We will notify you prior to the changes, where required, of material Policy changes via your account email address or by a Site notice.

This Policy was last updated on February 1, 2020.

Contact, Questions, Comments, Complaints

Please direct privacy-related issues, questions, comments or complaints to one of the following:

Email: info@btgsp.com

Postal Mail:

BTG International Inc.

300 Four Falls Corporate Center, Suite 300, 300 Conshohocken State Road

West Conshohocken, Pennsylvania

19428

United States of America

This Policy was last updated on February 1, 2020.


EU/EEA/Switzerland countries:

Postal Mail:

BTG Specialty Pharmaceuticals

Blaenwaun, Ffostrasol, Llandysul

Ceredigion

SA44 5JT

United Kingdom


Finally, in the EU/EEA and Switzerland you have the right to lodge a complaint with the data protection authority of your country where you believe that your rights have been violated [see EU list, Switzerland].

Rest of the world at Email: info@btgsp.com

Postal Mail:

BTG Specialty Pharmaceuticals

Blaenwaun, Ffostrasol, Llandysul

Ceredigion

SA44 5JT

United Kingdom