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.
Individuals located in California should read the important information available here.
Individuals located in the European Union, European Economic Area, or United Kingdom (collectively, “Europe” or “European”) should read the important
information available here.
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. This includes 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.
- Contact information. Personal and business contact information and preferences such as name, job title,
employer name, email address, mailing address, phone number, and emergency contact information.
- Demographic information. Such information includes date of birth, age, gender, marital status, and information regarding any parents or legal guardians.
- Professional credentials. Educational and professional history, certifications, and institutional affiliations
- Payment-related information. This includes information we need to pay for professional services that
individuals may provide to us (such as tax identification number and financial account information).
- Professional activity 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.
- Digital information. This may include your photograph, social media handle, or digital or
- Publicly available information. This may include comments you make online describing support for and experience with our products.
- Correspondence. This refers to other information you provide to us 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 you, your computer or mobile devices, and your activity over time on the Sites, such as:
- Device data including your IP address (a number assigned to your computer when you use the Internet) your device’s operating system, your Internet service provider and location, browser type and language, your unique device ID (persistent/non-persistent), hardware type, and the website you visited before browsing to our Sites; and
- Online activity data that is collected automatically (such as information about the Site content you access) and information about the date, time and duration of your visit to our Sites.
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
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.
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
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
Healthcare professionals and organizations
Analytics and advertising partners
When we use third-party cookies and other tracking tools, we may disclose your personal information to those third-party companies to help us analyze use of our Sites and advertise our Services.
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
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
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.”
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
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.
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
Neurocrine Biosciences, Inc.
Attention: Legal Department
12780 El Camino Real
San Diego, CA 92130
Notice to California residents
The information provided in this section applies only to California residents.
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal
information and of the rights and choices we offer California residents regarding our handling of the personal information.
This notice does not apply to the information we collect in connection with clinical trials or to any health or medical information we collect that is otherwise governed by California’s Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act of 1996. This notice also does not apply to information related to our business contacts (including healthcare providers).
PERSONAL INFORMATION THAT WE COLLECT, USE AND SHARE
Here is a summary of how we currently collect, use and share personal information, and how we have collected, used and shared the information in the preceding 12 months:
of personal information (definitions are available here)
which we may collect and use personal information
|Categories of third parties to which we disclose
Personal information we collect
CCPA categories of personal information (definitions are available here)
- Internet or network information
- Geolocation data
- Online identifiers
Sources of personal information
- Automatic collection
Purposes for which we may collect and use personal information
Categories of third parties to which we disclose personal information
- Analytics and advertising partners
CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
The CCPA grants California residents the following rights.
- You can request information about how we have collected, used and shared your personal
information during the past 12 months.
- Access. You can request a copy of the personal information that we maintain about
- Deletion. You can ask us to delete the personal information that we collected or maintain
You are entitled to exercise the rights described above free from discrimination. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
HOW TO SUBMIT A REQUEST
- To request access to or deletion of personal information:
- Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your
information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will
require the authorized agent to have a written authorization confirming that authority.
Notice to European users
Controller Representative and Data Protection Officer
Neurocrine Biosciences’ representative in the European Union and United Kingdom is DataRep, which you can contact at firstname.lastname@example.org (noting “Neurocrine Biosciences, Inc.” in the subject line).
Neurocrine Biosciences has appointed a Data Protection Officer who 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.
link for details)
|To provide the Services||
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
In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact
|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).|
|Processing is necessary to comply with our legal
|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.|
Processing purpose (click link for details)
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.
Processing purpose (click link for details)
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.
Processing purpose (click link for details)
Processing purpose (click link for details)
Processing purpose (click link for details)
Use for new purposes
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.
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
- 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 Europe 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
On July 16, 2020, the Court (Grand Chamber) of Justice of the European Union ruled that the EU-U.S. Privacy Shield Framework is invalid as a justification for the transfer of personal information to the U.S., and on September 8, 2020, Switzerland’s Federal Data Protection and Information Commissioner indicated that the Swiss-U.S. Privacy Shield Framework does not provide adequate protection for the transfer of personal information from Switzerland to the U.S. Notwithstanding these rulings, the U.S. Department of Commerce continues to administer the Privacy Shield program to maintain the Privacy Shield Frameworks, and Neurocrine Biosciences continues to be bound by the Privacy Shield obligations.
Neurocrine Biosciences does not use or share the personal information we collect for purposes other than the purposes we disclose to the relevant individuals. We do not use clinical trial participants’ personal information for purposes other than those described in the informed consent form and the study protocol for the relevant clinical trial. The informed consent form sets out choices trial participants may have under laws and regulations that govern clinical trials, such as the choice to withdraw consent for further participation in a clinical trial.
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. Our commitments under the Privacy Shield Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.