Privacy Notice

Effective Date: 19 June 2023

Our Commitment to Privacy

Zogenix International Limited (a company incorporated under the laws of England and Wales and member of the UCB group of companies) is committed to maintaining the highest level of confidentiality regarding the personal information that we collect, use, maintain, and disclose. This Privacy Policy explains how we handle the personal information you provide to Zogenix International Limited (“Zogenix”) within the United States, including our U.S. subsidiaries and affiliates which link to this Privacy Policy through their websites.

This Policy applies to any website (“Websites” or “Sites”) owned by Zogenix. As used in this Privacy Policy, “You” or “Your” refers to users of a Zogenix Website. “We” or “Us” includes Zogenix and its related companies. For offline interactions with Zogenix, this policy supplements (but does not replace) any other policy or notice provided to You as part of Your offline interaction(s) with Us. This Privacy Policy does not apply to third-party websites to which Zogenix Websites may link.

Zogenix is not a healthcare provider (e.g., a doctor, hospital, pharmacist, etc.) and is generally not subject to the Privacy Rule under the Health Insurance Portability and Accountability Act, commonly known as HIPAA, which imposes additional requirements on healthcare providers relating to protected health information.

Consent

Your use of Zogenix Websites is subject to this Privacy Policy, any referenced Legal Notice, and any referenced Terms of Use. By using a Website, You agree with the terms of this Privacy Policy in addition to any other posted policy found on the Site. Whenever You submit information to Zogenix via a Website, You consent to the collection, use, disclosure and storage of Your information and other information received by Us as a result of such use in accordance with these policies and as permitted or required by applicable law.

About children

Unless specifically stated, no Zogenix Website is intended for persons under the age of 13. We will not knowingly collect information from Website visitors unless You have indicated that You are age 13 or older by submitting information to Us. We encourage parents to talk to their children about their use of the Internet and the information they disclose via the Internet.

Personal information

“Personal information” means information that identifies You or could reasonably be used to identify You, and which is collected and/or maintained by Zogenix in an accessible form. Although the types of personal information We collect and share depend on the nature of Your relationship with Zogenix, as well as requirements of applicable laws, below are general categories of personal information that we may collect (either directly or indirectly).

Direct information collection

In general. We collect and store personal information You enter on our Websites or otherwise voluntarily share with Us. This may include:

Direct Identifiers such as Your first and last name, telephone number, fax number, postal address, or e-mail address;
Personal Characteristics such as Your age, ethnicity, gender, citizenship, primary language or Your relationship to a disease (e.g., as a healthcare provider, a researcher, a diagnosed patient, a friend or relative of such a patient);
Unique Identifiers such as a Zogenix or UCB product identifier/code (e.g., a lot number), Your medical insurance account number, Your clinical study identifier, or Your Social Security Number or Tax ID Number (for employment or tax reporting purposes);
If you are a diagnosed patient, Your Health Information such as the date of Your medical diagnosis or information related to medication(s) taken or other treatment(s) such as Your experience with certain therapies;
If you are seeking employment, Your Professional Background and Work Experience; and
Other Information such as the name of Your treating physician(s) or information related to Your health insurance coverage.

If you are a healthcare professional, We may also collect:

Professional Information such as Your professional credentials (e.g., pharmacist), Your medical specialty, Your hospital or other affiliation(s), or Your educational background or expertise; and
Professional Unique Identifiers such as Your National Provider Identifier (NPI) or Your DEA Registration number.

Other categories of personal information may be collected from time to time and will be described wherever the request for personal information occurs (whether on a Website or offline).

You may choose not to provide Your personal information to Zogenix, but in general, some information about You is required in order for You to interact with Zogenix. Examples include: a Website registration process; a request to subscribe to a newsletter; asking a question to Zogenix; or to initiate a transactions on our Website. If you choose not to provide certain personal information to Zogenix it may not be possible to respond to your query or transaction.

Information collected automatically. We automatically collect some information about Your computer when You visit a Website. For example, We may collect Your IP address, web browser software (such as Microsoft Edge), or Your language preference. We also may collect information about Your online activity within our Website, such as the pages You visited. One of our goals in collecting this automatic information is to help customize Your user experience.

Cookies. We may assign Your computer a “cookie” (a small, unique identifier text file). For example, whenever You sign into the Website, We record Your member ID and name on Your member account in a cookie file on Your computer. We also may record Your password in this cookie file, if You check “Remember me.” You can always choose not to receive a cookie file by enabling Your Web browser to refuse cookies or to prompt You before accepting a cookie. Please note that if You refuse to accept cookies from a Website, You may not be able to access some of the tools We offer.

Analytics information. Our Websites may use tools like Google Analytics to measure traffic to Our Site and how users interact with Our Site. Google Analytics employs cookies in order to facilitate an analysis of Your use of this site; the information generated by these cookies, such as time, place and frequency of Your visits to our Website, including Your IP address, is transmitted to Google’s location in the US and stored there.

Website users who do not want their data collected with Google Analytics can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript running on websites to prohibit sending information to Google Analytics.

To opt-out of Analytics for the web, visit https://tools.google.com/dlpage/gaoptout/ and install the add-on for Your browser. For more details, please see the relevant help resources for Your specific browser.

For more information, please review our Cookie Policy.

Indirect information collection

We also may periodically obtain information about You from other sources (for example, insurance companies) and add it to Your account information. One example of information We may receive from third parties is healthcare professional prescription histories or patterns, which We use to support Our strategic planning and operations.

Use of information

Except as otherwise stated, We may use Your personal information for the following general purposes:

to provide You with the services You request, including any follow-up activities;
to manage Your account;
to respond to Your questions and comments;
to measure interest in and improve the content of a Website;
to customize this Website to Your preferences;
to analyze and better understand Your needs, preferences, and interests;
to send You information about products in which You may be interested;
to solicit information from You, including through surveys;
to resolve disputes or troubleshoot problems;
to enforce our Terms of Use or Legal Notice; and
for other purposes specified in this Privacy Policy or described to You at the point of collection.

For information regarding Your choices about such uses, please review the “Your choices” section of this Privacy Policy below. We will not sell Your name, address, e-mail address, or any other personal information to another party for their own marketing use.

Disclosure of information

We may disclose Your personal information to other Zogenix affiliates worldwide. In addition, We may disclose Your personal information to a third party for a business purpose. For example, We may disclose Your personal information:

to third-party service providers We use to support our business (e.g., Internet service providers, hosting companies, financial institutions, and companies that provide business analytics, fulfillment services, technical support, and delivery services);
to trusted third-party businesses with which We partner to offer You products and services;
to pharmaceutical industry regulators such as the U.S. Food and Drug Administration, if required to do so by applicable laws;
in connection with a corporate transaction, such as the sale, assignment, or other transfer of the business;
in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by applicable laws or government regulations;
to protect and defend the rights of Zogenix, any Website or the users of any Website;
under circumstances We believe reasonably necessary to protect the personal safety of users of Zogenix’s products and services, this Website or the public; or
as is otherwise described in this Privacy Policy or at the point of collection.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. This information does not contain any personal information and is used to develop content and services We believe You will find of interest.

Protecting your personal information

Zogenix has adopted a number of recognized standards to protect the privacy of Your information, and We have provided a description and an example of these standards below. However, not every particular use or disclosure in every category will be listed.

We restrict and protect how Your personal information is used. We have guidelines which limit access only to those who have a reasonable need to use Your personal information. In addition, We limit how Your information is used to reasonable and legitimate business purposes. Finally, We may use Your personal information for business management and administration or to carry out Our legal responsibilities.

We restrict and protect how Your information is disclosed. As a global company with worldwide operations, We may share Your personal information with other Zogenix or UCB entities outside the United States. We limit these “affiliate disclosures” to circumstances where there is a legitimate business need, and any further use or disclosure of Your personal information is protected by Our global privacy policy and any applicable, country-specific privacy policy, law, or regulation.

For disclosures to third parties, it is Our standard practice to require those third parties keep Your personal information confidential and to use Your personal information only in a limited manner and in accordance with applicable data protection laws and regulations.

Zogenix will not sell or license Your personal information to third parties except in connection with the sale or transfer of a product line or division, or in connection with a joint marketing program.

We use strong computer security protections. Zogenix has implemented technical, administrative and procedural safeguards in an effort to secure your personal information from unauthorized access, use or disclosure. Unfortunately, no such measure is ever 100 percent effective, so we do not guarantee that your personal information will be secure from theft, loss, or unauthorized access, use or disclosure, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard your personal information.

If You have reason to believe that Your personal information is no longer secure (for example, if You feel that the security of Your account has been compromised), please immediately notify Us using the contact information below. We conduct privacy and security training and education programs. We provide appropriate training to staff who have permanent or regular access to personal information, who are involved in the collection of personal information, or in the development of tools used to collect, use or share personal information.

Your choices

You may choose:

not to provide personal information, but that may result in Your inability to obtain certain services or use certain features of our Websites;
to stop receiving commercial e-mails from Us in any such message We send or by sending an e-mail to the contact address at the bottom of this policy;
to delete or decline cookies by changing Your browser settings. (Click “Help” in the toolbar of most browsers for instructions.) If You do so, some of the features and services of our Website may not function properly; or
to review and update Your personal information by contacting Us at the link below and, if You have an online account on a Website, by logging into that account.

Access and deletion requests

If permitted by local laws, You have the right to request access to (or correction of) the personal information We have collected about You in a portable and readily usable format. In addition, You can request that We delete Your personal information in accordance with local laws. Please submit Your request(s) using the address listed in the “How to Contact Us” section below. We do not charge a fee to process or respond to Your verifiable request unless it is excessive, repetitive or manifestly unfounded. If We determine Your request warrants a fee, We will explain why We made that decision and provide You with a cost estimate before completing Your request.

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (CCPA) gives California consumers the right to know what personal information is collected about them, how it will be used and to whom it is disclosed. In addition, the CCPA provides You (as a California resident) with specific rights subject to certain exceptions.

The Right to Know. You have the right under the CCPA to request that We disclose what personal information We collect, use, disclose, and sell.
The Right to Deletion. You have the right under the CCPA to request deletion of any personal information about You that We have collected from You.
The Right to Opt-Out. You have the right under the CCPA to opt-out of the sale of Your personal information.
The Right to Non-Discrimination. You have the right under the CCPA not to be discriminated against for exercising Your rights.

Please note that some of the personal information that We collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws that apply to Us.

Nevada Privacy Law

We do not sell Covered Information as defined under Nevada law.

Links to other Websites

A Zogenix Website may contain links or references to other, non- Zogenix websites. Please be aware that We do not control other websites and that, in any case, this Privacy Policy does not apply to those websites. We encourage You to read the privacy policy of every website You visit.

International users

Unless otherwise stated, Zogenix Websites are intended for use only by U.S. residents. Any personal information You voluntarily share with Zogenix may be delivered to servers located in the United States or other countries. By using the Website, You consent to the transfer of any and all personal information that You provide to Us and to our use and disclosure of such personal information as outlined in this Privacy Policy.

How to contact us

If You have any questions, comments, or concerns about this Privacy Policy or the information practices of this Website, You can contact Us at Zogenix International Limited, Attn. Data Privacy, The Pearce Building, West Street, Maidenhead, Berkshire SL6 1RL, United Kingdom or contact Us by email or telephone.

Changes to this privacy policy

Without prejudice to Your rights under applicable law, We reserve the right to amend this Privacy Policy without prior notice to reflect technological advancements, legal and regulatory changes, and good business practices. If We change our privacy practices, an updated version of this Privacy Policy will reflect those changes and We will notify You of such changes by updating the effective date stated herein.