Privacy Policy

Overall Policy

Neurocrine Biosciences, Inc. (“Neurocrine Biosciences”, “we”, “us” or “our”) is a neuroscience-focused, biopharmaceutical company with more than 25 years of experience discovering and developing life-changing treatments for people with serious, challenging and under-addressed neurological, endocrine and psychiatric disorders.

This Privacy Policy sets forth the practices of Neurocrine Biosciences, and our subsidiaries and affiliates, regarding the collection, use and disclosure of your personal information in connection with our websites, including www.neurocrine.com, www.neurocrinemedical.com, www.ingrezza.com, www.ingrezzahcp.com, www.takeontd.com, www.talkabouttd.com, www.inbracesupportprogram.com, https://sservices.trialcard.com/Coupon/ingrezza, and www.comtenzyme.com (the “Sites”), and our clinical trials, products and services (together with the Sites, the “Services”).  This Privacy Policy also describes the rights and choices you have with respect to your personal information.

This Privacy Policy does not apply to any information that may be collected by third parties that may link to our Sites. Please read this entire Privacy Policy before using our Services or submitting information to Neurocrine Biosciences. Neurocrine Biosciences may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describes our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time. For example, our privacy practices in connection with clinical trials are governed by applicable clinical trial protocols. 

By using our Services, you agree to the terms of this Privacy Policy.

Individuals located in the European Union, European Economic Area, or United Kingdom (collectively, “Europe” or “European”) should read the important information available here

Privacy Policy……. 1
Personal information we collect……. 2
How this information is used……. 4
How we share your personal information……. 5
Storage and transfer of personal information……. 6
Information choices……. 7
Links to other sites……. 7
Children’s policy……. 7
International data transfers……. 7
Acceptance of terms……. 8
Privacy policy updates……. 8
Contact us……. 8
Notice to European Users……. 9

Personal information we collect

Whose personal information we collect

We collect personal information about the following types of individuals: clinical trial participants, patients, patients’ family members, caregivers, or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, users of our Sites, and other individuals who interact directly with Neurocrine Biosciences or our service providers or business partners.

How we collect personal information

We collect personal information:

  • Directly from you, such as when you contact us
  • Through the Sites
  • From healthcare professionals
  • From hospitals, clinics and other healthcare providers
  • From contract research organizations and clinical trial investigators
  • From government agencies or public records
  • From third-party service providers, data brokers, or business partners
  • From industry and patient groups and associations
  • From social media and other public forums (including adverse event information or product quality complaints)

Types of personal information we collect

The types of personal information we collect and share depend on the nature of the relationship you have with us and the requirements of applicable laws. We may collect:

  • Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications you may take, including the dosage, timing, and frequency) that we collect in connection with managing clinical trials, conducting research, providing patient support programs, managing compassionate use and expanded access programs, and tracking adverse event reports
  • Personal and business contact information and preferences (such as name, job title, employer name, email address, mailing address, phone number, and emergency contact information)
  • Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians)
  • Professional credentials, educational and professional history, and institutional affiliations
  • Payment-related information we need to pay for professional services that individuals may provide to us (such as tax identification number and financial account information)
  • If you are a health care professional, we collect information about the programs and activities in which you have participated, your prescribing of our products, and the agreements you have executed with us
  • Your photograph, social media handle, or digital or electronic signature
  • Publicly available information (such as comments describing support for and experience with our products)
  • Other information you provide to us (such as in emails, on phone calls, in market research surveys, or in other correspondence with us or our service providers or business partners)

We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide us.

Cookies and other information automatically collected 

While you are using the Sites, we automatically log information provided to us by your browser such as your IP address (a number assigned to your computer when you use the Internet) and your activity while using this website. We also collect information about your use of our site through cookies and similar technology. Cookies contain certain information that a website can then use to make communication between your browser and this site more efficient, such as by tracking site navigation and personal preferences involving dynamic site content. To enable Neurocrine Biosciences to provide customized and personalized services, we may use cookies to store and sometimes track information about you. Please refer to our Cookie Policy for more details.

Do Not Track signals 

Some web browsers offer a “Do Not Track” function that can send a signal to websites regarding the user’s privacy preferences. Our Sites do not respond to such signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

How this information is used

We may use your personal information in a variety of ways, including the following:

To operate the Sites:

  • To operate, maintain, enhance and provide all features of the Sites and our business, to provide services and information that you request, and to respond to comments and questions.
  • To personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the site, and provide customized content and information.
  • To monitor and analyze the effectiveness of content on the Sites, monitor aggregate site usage metrics such as total number of visitors and pages viewed, and track other usage of this site.

To communicate with you:

  • To contact you for administrative or other business purposes, and to send information that you have requested.
  • To send marketing communications, including updates on promotions and events, relating to our Services and products and services offered by third parties we work with. You can opt out of these marketing communications as described in the Opt out of marketing

To provide the Services:

  • To manage access to our products, including where access is limited by law to licensed physicians.
  • To pay for services that physicians, researchers, and other individuals may provide to us.
  • To develop new products, services, features, and functionality.

To perform and administer clinical trials, research, and product-improvement activities:

We may use your personal information when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including:

  • To staff and manage clinical trials, including by recruiting investigators and participants.
  • To track and respond to safety and product quality concerns (including product recalls).
  • To support public health initiatives, symposia, conferences, and scientific, educational, and volunteer events.
  • To facilitate medication adherence programs.
  • To define and manage appropriate patient engagement activities and patient support programs (including to provide co-pay and other financial assistance where available).
  • To identify and engage thought leaders and external experts.
  • To award scholarships and research grants.
  • To attribute authorship to academic and promotional materials.

To comply with law:

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

To comply with regulatory monitoring and reporting obligations:

We use your personal information as we believe necessary or appropriate to comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, patient safety, and financial disclosures.

To create anonymous data for analytics:

We may conduct research on users’ demographics, interests, and behavior based upon information you provide during use of our website. We may combine your information with information collected from other individuals to produce anonymous, aggregated statistical information that will not include personally identifiable information. We may use this aggregated information for our business purposes. We may also share this anonymous, aggregated information with third parties, or allow third parties to collect anonymous, aggregated information through our website. We do not have total control over these third parties or which methods they may use to collect information.

For compliance, fraud prevention, and safety

We use your personal information as we believe necessary or appropriate to:

  • Enforce the terms and conditions that govern the Services;
  • Protect our rights, privacy, safety or property, and/or that of you or others; and
  • Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Other uses:

We also may use your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent

How we share your personal information

Affiliates

We may disclose your information to our affiliates or subsidiaries for purposes consistent with this Privacy Policy.

Service providers

We may employ third-party companies and individuals to perform services on our behalf, including:

  • Contract research organizations that conduct clinical trials
  • Data storage and analytics providers
  • Customer service (including our medical information line) and patient support providers (including for product quality and adverse event reporting, patient co-pay assistance, medicine intake adherence programs, etc.)
  • Product recall administration
  • Technology services and support (including email and web hosting providers, marketing and advertising technology providers, email and text communications providers, and mobile app developers)
  • Event planning and travel organizations that help facilitate Neurocrine Biosciences programs
  • Payment, shipping, and fulfillment service providers

These third parties may use your information only as directed by Neurocrine Biosciences and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. 

Healthcare professionals and organizations

We may share your personal information with health care professionals, researchers, institutions, academics, public health organizations, and publishers for purposes consistent with this Privacy Policy.

Business partners

We may disclose your personal information to partners with whom we jointly develop products or services, in connection with the development and promotion of such products or services. We will ask for your consent before disclosing your information to our business partners where required by applicable law.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Compliance with laws and law enforcement, protection, and safety

We may disclose your personal information to comply with any court order, law, or legal process; to enforce this Privacy Policy, our Terms & Conditions, or other agreements; if we believe disclosure is necessary or appropriate to protect the integrity, security, safety, or rights of Neurocrine Biosciences or any other person; or if you consent to such disclosure.

Business transfer

Neurocrine Biosciences may, in the future, sell or otherwise transfer some or all of its assets, including your personal information, to an affiliate or to a third party in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, sale of assets, or in the event of bankruptcy.  We will make reasonable efforts to require the recipient to honor this Privacy Policy.

Additional program terms

In some situations, Neurocrine Biosciences may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a special program, activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information. We will honor these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating in any programs.

Storage and transfer of personal information

Neurocrine Biosciences, or in some cases our agents or service providers, may store your personal information in an electronic database. We and our agents may also exchange such information with each other or with you over the internet or over intranet systems for the purposes of processing the data, mailing information to you in response to your request, or otherwise carrying out the Services.

We use reasonable efforts to protect the confidentiality of your personal information. However, there is always some risk involved when submitting information over the internet, and we cannot guarantee that our website is 100% safe from illegal tampering or “hacking.”

Information choices

Changes to your personal information

If you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you may contact us.

Opt out of marketing

You may opt out of marketing-related emails by clicking the “Unsubscribe” link at the bottom of each such email. You may continue to receive service-related and other non-marketing emails.

Testimonials

If you gave us consent to post a testimonial on our Sites, but wish to update or delete the testimonial, please contact us.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with our Services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means.

Links to other sites

Neurocrine Biosciences Services may contain links to third-party websites that we believe may offer useful information. We are not responsible for the privacy practices or content of these other websites. We encourage you to review the privacy policies of these third-party websites.

Children’s policy

The Sites are not intended or designed to attract children under 13 years of age, and we do not knowingly collect information about children under age 13 in the United States through the Sites. If we learn that a child under age 13 has provided personal information without a parent or guardian’s consent, we will delete such information from our active databases.

International data transfers

Neurocrine Biosciences is headquartered in the United States and may have affiliates and service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

Individuals in the European Union should read the important information provided here about the transfer of personal information outside of the European Economic Area.

Acceptance of terms

By using this website and voluntarily providing your personally identifiable information to us, you consent to the collection and use of such personally identifiable information as set forth in this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use this site.

Privacy policy updates

We reserve the right, at any time, to modify, alter, or update this policy, and any such modifications, alterations, or updates will be effective upon posting.  In the event we modify this Privacy Policy, your continued use of the Services will signify your acceptance of the modified Privacy Policy.

Contact us

Please contact us regarding this Privacy Policy or our privacy practices at: 

Neurocrine Biosciences, Inc.
Attention: Legal Department
12780 El Camino Real
San Diego, CA 92130
Email: DPO@neurocrine.com

 

This Privacy Policy was last updated November 4, 2019. 

Notice to European Users

Controller, Representative, and Data Protection Officer

Neurocrine Biosciences, Inc. is the controller of your personal information covered by this Privacy Policy. Neurocrine Biosciences’ representative in Europe is Data Protection Representative Limited (“DPR Group”), which you can contact at datainquiry@dpr.eu.com. Neurocrine Biosciences has appointed a Data Protection Officer whom you can contact at DPO@neurocrine.com.

Legal bases for processing

The legal bases for our processing of your personal information are described in the table below.

Processing purpose (click link for details) Legal basis
To provide the Services Where we have a contract governing this processing purpose, the processing is necessary to perform that contract or to take steps that you have requested prior to entering into the contract.In other cases, these processing activities are necessary to protect your, or another person’s, vital interests.
To perform and administer clinical trials, research, and product-improvement activities Where we process sensitive personal information in connection with this processing purpose, the processing is authorized by Member State law or is necessary for scientific research, historical research, or statistical purposes.In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To operate the Sites

To communicate with you

To create anonymous data for analytics

For compliance, fraud prevention, and safety

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

To comply with regulatory monitoring and reporting obligations

To comply with law

Processing is necessary to comply with our legal obligations.
Other uses Where we rely on your consent, you have the right to withdraw it at any time in the manner indicated when we requested the consent or by contacting us.

 

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information. 

You can submit these requests by email or postal mail as described above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions, including legal requirements that govern clinical trials. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here

Cross-border data transfer

If we transfer your personal information from the European Economic Area (the “EEA”) to a country outside of it and are required to apply additional safeguards to that personal information under European data protection laws, we will do so:

  • Pursuant to standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules;
  • Pursuant to the consent of the relevant individual; or
  • As otherwise permitted by applicable European requirements.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Neurocrine Biosciences complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  We have applied to the Department of Commerce for certification that we adhere to the Privacy Shield Principles.  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 www.privacyshield.gov.

We may transfer your personal information to third parties as described in this Privacy Policy. We maintain contracts with our third-party service providers restricting their access, use and disclosure of personal information in compliance with our Privacy Shield obligations. Neurocrine Biosciences may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information.  European Union and Swiss individuals with inquiries or complaints regarding our Privacy Policy should first contact us. Neurocrine Biosciences has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The JAMS services are provided at no cost to you. If neither Neurocrine Biosciences nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.

We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over Neurocrine Biosciences’ compliance with the Privacy Shield. Our commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.