This Privacy Notice outlines
a) the information provided to us by you as a User of Indivior, or that Indivior will collect;
b) how we will use, and in some circumstances, share that information; and
c) the choices available to you regarding our use of your personal data, and how you can access and update this information.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. There will be no adverse consequences to you, and you should be aware that we may not be able to provide you with information, goods or services that you may need or want to hear about. If you do decide to proceed, but then change your mind, you may do so at any time by ceasing to use the Site. You can also write to us at the contact details below asking us to delete the information you have provided.
We may change this Privacy Notice from time to time. Therefore, we ask you to check this Privacy Notice occasionally to ensure that you are aware of the most recent version.
We will notify you of any changes where we are required to do so.
BY ACCESSING BROWSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE RECEIVED, READ, UNDERSTOOD AND AGREE TO BE BOUND BY THE FOLLOWING PRIVACY NOTICE AND ANY UPDATES TO IT. YOU ACKNOWLEDGE THAT INDIVIOR IS NOT A MEDICAL PRACTICE AND DOES NOT PROVIDE MEDICAL ADVICE.
YOU FURTHERMORE ACKNOWLEDGE AND AGREE THAT INDIVIOR IS NOT A MEDICAL PRACTICE AND DOES NOT PROVIDE MEDICAL ADVICE.
When we use these capitalised terms, they have the following definitions:
“Disclose” and variations such as “Disclosure” means any and all of the following:
Using, accessing or barring access, processing, fulfilling, disclosing, receiving, displaying, sharing, making available, transferring, storing, selling, leasing, licensing, retaining, deleting or destroying, combining, investigating, verifying, proving, enforcing or otherwise dealing with personal information.
“Personal information” “Personal data” or “PI” means any information relating to an identified or identifiable natural person. That means, effectively, if a person can be reasonably be identified personally or by their computing device, the information identifying them is PI.
Legal bases for processing
The PI we use will largely be information supplied by yourself, although in certain circumstances it could be from publicly accessible sources. It largely depends on who you are and what you choose to tell us. So, one legal ground for our using your PI could be consent. However, that may not be the (only) ground.
There may be occasions where we use other grounds; for example, if you want to be an Indivior Employee we may need to process your PI to take steps at your request before joining us.
If you are an Indivior Employee, then we may need to process your PI to perform a contract; for example, to ensure we pay you.
If you are a HCP we may use it to ensure we know your clinical experience and expertise, allowing us in certain circumstances to reach out to you to tell you about events and seminars you might want to attend.
If you are a Patient, we may use your details to get in touch with you.
In relation to the specific legal grounds set out in the new EU legislation on data protection which comes into force in May 2018 (GDPR) we may need to use Consent (Article 6.1 a), performance of a contract (Article 6.1 b), compliance with a legal obligation (Article 6.1 c), protection of the vital interest of a person (Article 6.1 d) and/or legitimate interests (Article 6.1.f). The legitimate interest may be the dissemination of medical or pharmacological information, but it may vary according to the specific circumstances in which we need to process your PI.
What Information Do We Collect and How Do We Use It?
Indivior will collect certain personal information that you provide to us voluntarily. For example, we may collect personal information when you fill out a questionnaire, sign up for a survey or otherwise interact with us. Such information may include your name, address and email address. Depending on the circumstances it could be wider; for example, if you are a patient you may want to tell us more about yourself.
In addition to providing you with the service or information you request on our Site, your PI may also be used to help us track the way you use our Site.
There may be times when we may obtain Sensitive Personal Data (this will be called Special categories of personal data in the EU after May 2018) about you; for example, if you voluntarily provide information about your physical or mental health.
By providing us with your Sensitive Personal Data, you explicitly consent to us processing this data for the purposes set out in this Privacy Notice or any collection notice provided to you.
However, as with non-sensitive personal data, consent may not be the (only)legal ground for processing your PI. If you are an Employee then we may use Article 9.1. b. GDPR (complying with employment or social security law). We may need to use Article 9.1 c. (protecting vital interests), Article 9.1 f. (defence of legal claims), Article 9.1 h. (preventative or occupational medicine), Article 9.1 i. (public health) and/or Article 9.1.j. (scientific research) .
Who we may share your PI with
Information may be shared with service providers who provide services for or administer activities on behalf of Indivior. For example, if you are an Employee we may need to pass your information on to our benefits provider. We may provide information about you to service providers that perform certain functions or services on our behalf (for example, hosting our services, storing our data, managing databases, performing analyses, or sending communications for us). These companies are contractually limited in the ways in which they may use this information.
Information you submit to one or more of the Indivior bodies may be shared with part of the Indivior Group.
In the event Indivior, or its assets, is bought or sold, PI may be included among the transferred business assets. In this case, a prominent notice on our Site of any change in ownership or uses of your PI, as well as any choices you may have regarding your PI will be provided.
Indivior may disclose specific PI if it determines that such disclosure is necessary to comply with the law, such as to comply with a subpoena or to protect the safety of the public. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or respond to a government request, we may feel we must disclose to the relevant Authority. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
The Indivior Site(s) may contain links to other websites. The Privacy Policies at these other websites may be different from this one. You should refer to relating to that website.
We use aggregate information, which does not identify individuals, to monitor customer traffic patterns to the website and particular pages, as well as site usage, in order to help us improve the design and layout of the content.
How We Protect Your Information
Indivior uses reasonable security techniques to help protect against the loss, misuse or alteration of information collected from you at an Indivior Site. When you transmit PI, it is stored on servers that Indivior has attempted to secure from unauthorized access or intrusion. Of course, no Internet site or service can be made 100 percent secure, and Indivior cannot be and are not responsible for unauthorized access to information by hackers who have obtained access through illegal measures.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of the PI you transmit to our Site; any transmission is at your own risk.
While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will make reasonable efforts to prevent such occurrences.
How long we will keep your PI
We keep PI for as long as your account is active or as needed to provide you services and reserve the right to retain it to the full extent not prohibited by law (e.g., for the length of a statute of limitations). We may discard PI in our discretion, so you should retain your own records. Often it is not feasible or advisable actually to discard PI (such as commingled PI), so we reserve the right to retain and treat it as inactive or discarded (such as removing traditional “pointers” to it).
Access and Correction
If we process Personal Data about you, then broadly, within the EU you have the right under data privacy law to know that your PI is being processed, to object to your PI being processed, to request access to your Personal Data, to correct any inaccuracies or to ask to have it deleted.
If we agree that the information is incorrect, or that the processing should be stopped, we will delete or correct the information. If we do not agree that the information is incorrect, we will nevertheless, record the fact that you consider the information to be incorrect.
Right of complaint
If you do not accept our conclusions, then in the EU you may lodge a complaint with the relevant Supervisory Authority.
In the UK this is the Information Commissioner’s Office.
In France it is CNIL.
In Italy it is the Garante.
In Germany in the first instance it is the regional Data Protection Authority (Regierungspräsidium).
Other countries within the EU will have their own Supervisory Authority.
Opting Out Of Further Communications From Us
If you have elected to receive information about our products or services, and wish to opt-out of receiving such information, then you can do so by sending an email to Privacy@indivior.com. If in Germany to datenschutzbeauftragter_DE@indivior.com You should clearly state on all communications: your name, username (if any), registration details (if any) and the name of this website.
10710 Midlothian Turnpike
North Chesterfield, VA 23235
Attn: Legal Department
For Germany, contact datenschutzbeauftragter_DE@indivior.com
Special Note to International Users
The Site is hosted in the United States of America. If you are a User that is a resident of another country, or are accessing the Site from outside of the United States of America, please note that you are transferring your data outside of the European Economic Area (EEA) which may not have the same data protection laws as the European Union and other regions, and by providing your data you are aware of the possible issues (such as the data principles set out in Article 5 GDPR not applying in whole or in part), and explicitly consent to
(ii) the transfer of your data, including Personal Information, to outside of the EEA as indicated above