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PRIVACY POLICY


EFFECTIVE SEPTEMBER 25, 2019

Thank you for your trust in Novartis Pharmaceuticals Corporation ("Novartis
Pharmaceuticals" "we", "our", or "us"). We are a United States-based affiliate
of the Novartis global group(link is external), a world leader in healthcare.
This Privacy Policy describes how we use and disclose the information we collect
from you through our U.S. Healthcare Professionals websites, mobile
applications, social media forums, and other services, both offline and online,
that link to, incorporate, or for which you are provided a copy of this Privacy
Policy (collectively, the "Services"), and the choices you have about how we use
that information.


WHAT INFORMATION DO WE COLLECT?

 * Information You Provide: We collect information that you voluntarily provide
   when you use the Services, such as when you register for or use a Novartis
   Pharmaceuticals program or service, participate in a survey, provide a
   testimonial, order a product, participate in an interactive feature or forum
   (such as chat features), or contact us with a question, comment, or request.
   The types of information that you provide are based on the specific function
   of the Services that you use or the Novartis Pharmaceuticals program or
   service for which you register, and might include, for instance, your name,
   address, age, birth date, gender, email address, phone number, photo, social
   media account number, medical license number, zip code, education,
   professional experience, demographic information, information about health
   and/or medical conditions and specialties, and information required to
   process payments for speaking events or expense reimbursement, including your
   social security number and/or tax identification number. If you submit
   personal information relating to other people to us or to our service
   providers in connection with the Services, you represent that you have the
   authority to do so and to permit us to use the information in accordance with
   this Privacy Policy.
 * Information We Receive From Third Parties:We may combine the information we
   collect from you with information that we receive about you from other
   sources, such as public databases, providers of demographic information,
   joint marketing partners, publications, professional organizations, social
   media platforms, people with whom you are connected on social media
   platforms, and other third parties.


WHAT INFORMATION DO WE COLLECT AUTOMATICALLY FROM YOUR DEVICE AND HOW DO WE USE
IT?

We and our third party service providers may collect information automatically
from your device in a variety of ways, including:

 * Through your browser or device: Certain information is collected by most
   browsers or automatically through your device, such as your Media Access
   Control (MAC) address, computer type (Windows or Macintosh), screen
   resolution, operating system name and version, device manufacturer and model,
   language, Internet browser type and version and the name and version of the
   Services you are using. We use this information to ensure that the Services
   function properly.
 * Through your use of an app: When you download and use one of our apps, we may
   track and collect app usage data, such as the date and time the app on your
   device accesses our servers and the information and files that have been
   downloaded to the app.
 * Using cookies: Cookies are small text files stored directly on your device.
   We use cookies to collect information such as time spent on the Services,
   pages visited, the pages you view immediately before and after you access the
   Services, the search terms you enter, and other anonymous traffic data.
   Cookies allow us to recognize you and personalize your experience, to
   facilitate navigation, and to display information more effectively. We also
   use cookies to gather statistical information about the use of the Services
   in order to understand how they are used, improve them, and resolve questions
   about them. If you do not want information collected through the use of
   cookies, most browsers allow you to automatically decline cookies or to be
   given the choice of declining or accepting cookies from a particular site.
   You may wish to refer to
   http://www.allaboutcookies.org/manage-cookies/index.html(link is external) If
   you do not accept our cookies, you may experience some inconvenience in your
   use of the Services.
 * Using pixel tags and other similar technologies: We may use pixel tags (also
   known as web beacons and clear GIFs) to, among other things, track the
   actions of users of the Services and our email recipients, measure the
   success of our marketing campaigns and compile statistics about usage of the
   Services and response rates.
 * To deliver interest-based advertising: We may use third-party advertising
   companies to serve advertisements regarding products and services that may be
   of interest to you when you access and use the Services and other online
   properties, based on information about your use of the Services and/or other
   online properties. To do so, these companies may place or recognize a unique
   cookie on your browser, including through the use of pixel tags, or use other
   tracking technologies. To learn more about these practices, including your
   choices in connection with them, please visit
   http://www.adobe.com/privacy/opt-out.html(link is external),
   http://www.networkadvertising.org/managing.opt-out.asp(link is external) and
   http://www.aboutads.info/choices(link is external).
 * Using Adobe Flash technology (including Flash Local Shared Objects ("Flash
   LSOs")) and other similar technologies: We may use Flash LSOs and other
   technologies to, among other things, collect and store information about your
   use of the Services. If you do not want Flash LSOs stored on your computer,
   you can adjust the settings of your Flash player to block Flash LSO storage
   using the tools contained in the Website Storage Settings Panel(link is
   external). You can also control Flash LSOs by going to the Global Storage
   Settings Panel(link is external) and following the instructions (which may
   include instructions that explain, for example, how to delete existing Flash
   LSOs (referred to "information" on the Macromedia site), how to prevent Flash
   LSOs from being placed on your computer without your being asked, and how to
   block Flash LSOs that are not being delivered by the operator of the page you
   are on at the time). Please note that setting the Flash Player to restrict or
   limit acceptance of Flash LSOs may reduce or impede the functionality of some
   Flash applications.
 * IP Address: Your IP Address is a number that is automatically assigned to the
   computer that you are using by your Internet Service Provider. An IP Address
   may be identified and logged automatically in our server log files whenever a
   user accesses the Services, along with the time of the visit and the page(s)
   visited. Collecting IP Addresses is standard practice and is done
   automatically by many websites, applications and other services. We use IP
   Addresses for purposes such as calculating usage levels of the Services,
   helping diagnose server problems, and administering the Services.
 * Precise Real-Time Location Information: We may collect precise, real-time
   information about the location of your mobile device. We may use your
   device's location to provide you with personalized location-based services
   and content, including marketing communications. You may be permitted to
   allow or deny the use of your device's location by managing your location
   services preferences through your device settings.


HOW DO WE USE YOUR INFORMATION?

In addition to using your information to deliver the programs, services,
products, or information you request, and for the purposes described above, we
may also use it:

 * to provide customer support;
 * to provide you with information about the Services, our other products,
   programs, or services, your accounts, and notices;
 * to administer Speaker Programs, such as verifying speaker credentials,
   training and scheduling speakers, coordinating events and travel, advertising
   speaker events, and processing honoraria and expense reimbursement;
 * to deliver marketing communications that may be of interest to you;
 * to permit you to participate in polls, surveys, promotions, or other
   interactive features, such as chat features;
 * to personalize your experience and better tailor content to you;
 * to facilitate social sharing functionality;
 * to allow you to send messages to another person through the Services;
 * to help us, our subsidiaries, affiliates, and business partners better
   understand our audiences, evaluate user interest in the Services, improve the
   Services, and perform other market research activities;
 * for our business purposes, such as data analysis; audits; monitoring and
   prevention of fraud, infringement, and other potential misuse of the
   Services; modifying the Services; determining the effectiveness of our
   promotional campaigns; and operating and expanding our business activities;
   and
 * as we believe to be necessary or appropriate: (a) under applicable law,
   including laws outside your country of residence; (b) to comply with legal
   process; (c) to respond to requests from public and government authorities,
   including public and government authorities outside your country of
   residence; (d) to enforce our terms and conditions; (e) to protect our
   operations or those of any of our affiliates; (f) to protect our rights,
   privacy, safety or property, and/or that of our affiliates, you or others;
   and (g) to allow us to pursue available remedies or limit the damages that we
   may sustain.

We may use information that does not personally identify you for any purpose,
except where we are required to do otherwise under applicable law. We may
combine, aggregate, or anonymize any of the information we collect from you with
information we may collect from or about you from any other online or offline
source.


WHEN AND TO WHOM DO WE DISCLOSE YOUR INFORMATION?

The information we collect from and about you may be disclosed:

 * to our subsidiaries and affiliates within the Novartis global group(link is
   external), for the purposes described in this Privacy Policy;
 * to third parties that provide services to us, such as fulfilling requests for
   information, answering calls, administering programs or projects, processing
   speaker honoraria and expense reimbursement, arranging travel, assisting in
   research and development, or delivering advertisements or other
   communications;
 * to business partners who offer products or services jointly with us or with
   our subsidiaries or affiliates;
 * to permit a third-party business partner to deliver marketing communications
   or products that may be of interest to you, subject to any choices you have
   expressed;
 * to identify you to any person to whom you send messages;
 * to any person you direct us to contact, such as your designated caregiver(s);
 * by you, on message boards, chat, profile pages, blogs, and other services to
   which you post information and materials. Because any information you post
   may become public, we urge you to be very careful when deciding to disclose
   any information on or through the Services;
 * to your friends associated with your social media account, to other Services
   users, and to your social media account provider, in connection with your
   social sharing activity, such as if you connect your social media account to
   your Services account or log into your Services account from your social
   media account. By connecting your accounts, you authorize us to share
   information with your social media account provider, and you understand that
   the use of the information we share will be governed by the social media
   site's own privacy policy;
 * as required by law, such as to law enforcement, to health authorities to
   report possible adverse events, during government inspections or audits, as
   ordered or directed by courts or other governmental agencies, or in order to
   comply with a subpoena or other legal process;
 * when we believe in good faith that disclosure is necessary to protect legal
   rights or the security or integrity of the Services; protect your safety or
   the safety of others; investigate fraud, a breach of contract, or a violation
   of law; or respond to a government request; and
 * to third parties, advisors, and other entities to the extent reasonably
   necessary for development of or to proceed with the negotiation or completion
   of a corporate or commercial transaction, including a reorganization, merger,
   acquisition, joint venture, sale or other disposition of all or a portion of
   our business, assets, or stock (including in connection with any bankruptcy
   or similar proceedings).

We may disclose information that does not personally identify you for any
purpose, except where we are required to do otherwise under applicable law.


YOUR CHOICES

Where you have elected to participate in one of our programs or services or to
receive marketing communications from us, we may offer you the ability to
discontinue your participation or to opt out of receiving those communications
in the communication itself, or you can visit our Contact Us page, write to us
at Novartis Pharmaceuticals Corporation, 1 Health Plaza, East Hanover, New
Jersey, 07936 attention Privacy Office, or call us at 1-888-NOW-NOVA
(1-888-669-6682).

We do not currently respond to web browser "do not track" signals or other
mechanisms that provide a method to opt out of the collection of information
across websites or other online services.

If you are a resident of California, under 18 and a registered user of the
Services, you may ask us to remove content or information that you have posted
to the Services by writing to novartis.email@novartis.com. Please note that your
request does not ensure complete or comprehensive removal of the content or
information, as, for example, some of your content may have been reposted by
another user.


INFORMATION SECURITY

We use appropriate technical, administrative, and physical safeguards to protect
the information collected through the Services. Unfortunately, no organization
can guarantee the absolute security of information, especially information
transmitted over the Internet.


CHILDREN'S INFORMATION

We do not knowingly collect personal information online from a child under the
age of 13 without obtaining prior parental consent, other than to inform the
child that we must have parental consent before collecting personal information.


ACCESSING AND UPDATING YOUR INFORMATION

We encourage you to update the personal information you provide to us to help us
continue to provide information that best meets your needs. You may be able to
update this information through Services, or visit our Contact Us page, write to
us at Novartis Pharmaceuticals Corporation, 1 Health Plaza, East Hanover, New
Jersey, 07936 attention Privacy Office, or call us at 1-888-NOW-NOVA
(1-888-669-6682). For your protection, we may only implement requests with
respect to the personal information associated with the particular email address
that you use to send us your request, and we may need to verify your identity
before implementing your request.


LINKS TO THIRD PARTY WEBSITES

The Services may contain links to third-party services that are not under our
control. We are not responsible for the collection and use of your information
by such services, and we encourage you to review their privacy policies. In
addition, we are not responsible for the information collection, use,
disclosure, or security practices of other organizations, such as Facebook,
Apple, Google, Microsoft, RIM, or any other app developer, app provider, social
media platform provider, operating system provider, wireless service provider,
or device manufacturer, including in connection with any information you
disclose to such other organizations through or in connection with the Services.


NEVADA RESIDENTS AS COVERED BY NEVADA PRIVACY LAW

Novartis does not sell Covered Information as defined under Nevada law.  If you
would like to make a further inquiry regarding the selling of your Covered
Information, as defined under Nevada law, please contact
Nevada-Privacy.Request@novartis.com.


TEXAS RESIDENTS

Pursuant to the Texas Health and Safety Code, Sec. 181.154, please be advised
that if Novartis Pharmaceuticals receives any information that identifies you
and relates to your past, present or future physical or mental health,
healthcare or payment for your healthcare, such information may be subject to
electronic disclosure by such means as file transfers or email.


CHANGES TO THIS PRIVACY POLICY

This Privacy Policy became effective on September 25, 2019. We may update it
from time to time by posting a new Privacy Policy on our website. You are
advised to consult our website regularly for any changes, and your continued use
of the Services after such changes have been made constitutes acceptance of
those changes.


HOW TO CONTACT US

If you have any questions about our Privacy Policy, please visit our Contact Us
page, write to us at Novartis Pharmaceuticals Corporation, 1 Health Plaza, East
Hanover, New Jersey, 07936 attention Privacy Office, or call us at
1-888-NOW-NOVA (1-888-669-6682).

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