Effective Date: August 25, 2020
Osmotica may collect the following information when you interact with the Services:
We may collect this information:
When you are using the Websites, third parties may collect information about your online activities over time and across third-party websites or other online services.
Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you.
The Services are not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If you are under 13 years of age, do not use or provide any information through the Services. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information.
Osmotica may use information, including Personal Information, for the following purposes:
We may use aggregated information and de-identified information without restriction.
We use information collected through cookies, pixels, or other tracking technologies, sometimes in combination with other Personal Information, to better understand, customize and improve your experience on the Websites, as well as to manage our advertising. For example, we may use web analytics services that leverage such information to help us understand how you engage with and navigate the Websites and to allow us to offer you a more customized, relevant experience on the Websites by delivering content and functionality based on your preferences and interests. We may also use information to display interest-based ads.
If your healthcare provider uses the Meet UPNEEQ app in connection with their provisioning of healthcare services to you, the app will require your healthcare provider to take before and after photographs for the purpose of measuring eyelid distance, and the app may also require your healthcare provider to input your name and birthdate into the app. Osmotica does not collect any of this information from your healthcare provider, and the app deletes this information once your healthcare provider completes his or her session in the app. Osmotica only collects from the Meet UPNEEQ app certain identifiers relating to the healthcare provider’s device on which the app is installed, such as iPad ID, device type, and operating system type, and de-identified or aggregated usage data pertaining to the provider’s use of the app.
We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:
We may obtain your consent to process your Personal Information in certain circumstances, which may include when you elect to receive information from us. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about our Services (see below).
Performance of a Contract
We rely on this lawful processing ground when we process your Personal Information to perform a contract that we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with the provision of our Services to you and the management of our relationships with third parties.
Compliance with a Legal Obligation
We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations that apply to us.
We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with marketing information or other information in relation to our Services that we believe may interest you.
If you wish to have more information regarding the legitimate interests we rely on, please contact us at email@example.com.
We may disclose information, including Personal Information:
We may disclose aggregated information and de-identified information without restriction.
Our servers are either located in the United States or, if located in other countries, may be accessed from the United States. Please note that in countries outside your own country, and in particular outside the EU and EEA, a different standard on data protection might apply than you are used to in your own country.
By sending Personal Information to us, you acknowledge and consent that your information will be transferred across national borders, including to countries outside the EU/EEA.
If you live in the EEA, we may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as an intra-company agreement that complies with the European Commission’s Standard Contractual Clauses or their equivalent under applicable law, or rely on third parties’ certification to the Swiss-U.S. Privacy Shield Framework, where applicable.
You may contact us at firstname.lastname@example.org to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.
We have implemented measures designed to secure your Personal Information from accidental loss, unauthorized access, use, alteration and disclosure. Personal Information is stored in a central database on a secured network in the United States with stringent access controls in place. Although we have made reasonable efforts to safeguard the confidentiality of your Personal Information, we cannot promise, and you should not expect, that your Personal Information will always stay private. We cannot guarantee that unauthorized third parties will never be able to circumvent our security measures and obtain access to your Personal Information and use it for improper purposes.
Osmotica only keeps Personal Information for as long as necessary. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature and sensitivity of the Personal Information, potential risk of harm from unauthorized use or disclosure, purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and our business operations and legal requirements.
Direct Marketing Opt-Out
If you no longer wish to receive promotional emails from Osmotica, you may click the “Unsubscribe” link in an email at any time.
Interest-Based Advertising Opt-Out
You may control interest-based advertising by clicking the AdChoices icon on an ad or by visiting the Digital Advertising Alliance’s (DAA) and National Advertising Initiative’s (NAI) opt-out pages at https://optout.networkadvertising.org/?c=1 or https://optout.aboutads.info/?c=2&lang=EN.
While your browser may accept cookies automatically, you can change the settings on your browser to prevent our cookies from being automatically downloaded, or to notify you that they are ready to be downloaded. The latter will give you the option of whether or not you want to accept our cookies. If you decide to decline our cookies, however, some of the Websites’ features or services may not function as well as they would have had you accepted our cookies. While you cannot decline Web Beacons, you can decline all cookies and therefore render the Web Beacons ineffective. Please note that blocking cookies may interfere with your interest-based advertising opt-out preferences. The Services do not respond to “Do Not Track” signals.
If you live in the EEA, you may have the following rights:
California Consumer Privacy Act (CCPA)
Osmotica collects Personal Information as defined by the CCPA, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include de-identified or aggregate information, publicly available information that is lawfully made available from federal, state, or local government records, information covered by certain sector-specific privacy laws, such as medical information under California’s Confidentiality of Medical Information Act and protected health information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and some clinical trial information.
In the preceding 12 months, Osmotica collected the following categories of Personal Information for the business purposes indicated above in “How We May Use Your Information”:
Osmotica collects Personal Information from the following categories of sources:
In the preceding 12 months, Osmotica has disclosed the following categories of Personal Information to the following categories of third parties for a business purpose. Osmotica does not sell Personal Information.
|Personal Information||Third Parties|
|Identifiers||marketing providers, other service providers|
|Telephone number||marketing providers, other service providers|
|Internet or other electronic network activity information||digital media agencies, other service providers|
California residents have the right to: (1) request that Osmotica disclose what Personal Information we collect, use, disclose, and sell; (2) request deletion of Personal Information; (3) opt-out of the sale of Personal Information; and (4) not receive discriminatory treatment by Osmotica for exercising these rights.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may contact us by email with proof of your written and signed permission to do so. Osmotica may also require you to verify your identity and confirm that you gave permission.
Requests to Know
You have the right to request that we disclose the following information:
To make such a request, please email us at email@example.com, or call us toll-free at 866-600-4799. We will generally ask you to provide certain information that we already maintain in our records so that we can verify your identity.
Requests to Delete
You have the right to request that we delete Personal Information about you that we collected and maintain, subject to certain exceptions. To make such a request, please call us toll-free at 866-600-4799 or email us at firstname.lastname@example.org. Once we verify your request, we will delete and direct our service providers to delete your Personal Information, unless an exception applies.
Although Osmotica does not sell your Personal Information, Nevada residents may have the right to opt-out of the any future sale of Personal Information we have collected or will collect. To make such a request, please email us at email@example.com.
You may contact Osmotica by email with questions or concerns at firstname.lastname@example.org.
If you live in the EEA, Osmotica Pharmaceuticals plc is the entity responsible for the processing of your Personal Information. Please submit questions, concerns, or requests to exercise your applicable rights by email to Osmotica and its Data Protection Officer at email@example.com or write to:
Osmotica Pharmaceuticals plc
400 Crossing Boulevard
Bridgewater, NJ 08807