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PRIVACY POLICY


MALLINCKRODT PRIVACY POLICY

Introduction

The privacy and protection of personal information is of importance to
Mallinckrodt Pharmaceuticals. This Privacy Policy (Policy) describes how
Mallinckrodt and its affiliates and brands collect, use, and share personal
information.

If you are a Healthcare Professional (“HCP”), for additional information about
how we collect, use, and share your personal information, please click here.

You can jump to particular topics by going to the links below:

Contents

 * Contact Information

 * Types of Data We Collect

 * Sharing of Personal Information

 * How We Protect Personal Information

 * Cookies and Other Web Devices

 * Your EU Privacy Rights

 * California Consumer Privacy Act Rights

 * Other Important Information

 * California Information Sharing Disclosure

Contact Information

The primary data controller is Mallinckrodt Pharmaceuticals Ireland Limited,
with registered offices at College Business & Technology Park, Cruiserath,
Blanchardstown, Dublin 15, Ireland.

If you have any questions, comments, or complaints concerning our data privacy
or data protection practices, please contact us at privacy@mnk.com or call us at
800-822-2075. 

Types of Data We Collect

Personal Information means any information relating to an identified or
identifiable natural person (“Data Subject”). An identifiable natural person is
one who can be identified, directly or indirectly, in particular by reference to
an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological,
mental, economic, cultural or social identity of that natural person.

The following provides examples of the types of data that we collect from you
and how we use the information.

Context

Types of Data

Legal Basis and Purpose for Processing, Collection and Use of Data

Account Registration

We may collect your name and contact information when you create an account or
subscribe to receive information updates.

We have a legitimate interest in providing account-related functionalities to
our users. Accounts can be used for easy checkout and to save your preferences
and transaction history.

Demographic Information

We may collect personal information from you, such as your name, postal address,
age or location.

We use this information to conduct our normal day-to-day business. We have a
legitimate interest in understanding our users and providing tailored services.
In some contexts, we are also required by law to collect this information.

Employment or Prospective Employment

If you apply for employment, or become an employee, we may collect personal
information necessary to process your application or to manage you as a member
of our workforce. This may include, among other things, your telephone number,
postal address, email address, age, location, benefits elections, employment
history, salary information, educational background, driver’s license or social
security number.

We use information about current and prospective employees to perform our
contract of employment, or the anticipation of a contract of employment, with
you. In some contexts, we are also required by law to collect information about
our employees.  We also have a legitimate interest in using your information to
have efficient staffing and work force operations. In some circumstances, our
use is based upon your consent, including, for example, your consent to
communicate with us through voice and video teleconferencing.

Feedback/Support

If you provide us feedback or contact us for support, we will collect your name
and email address and possibly other personal information, as well as any other
content that you send to us in order to reply.

We have a legitimate interest in receiving, and acting upon, your feedback or
issues.

Mailing List

When you sign up for one of our mailing lists we may collect your email address
or postal address.   

We share information about our products and services with individuals that
consent to receive such information.  

Online Forms, Submissions and Surveys

We collect information you submit to us on our websites, through online forms or
by completing a survey and registrations to process your requests, for example
to grant applications.

Our use is based upon your consent to provide us with information. We may also
use this information to perform our contract, or the anticipation of a contract,
to provide you with products or services.

Order Placement

We may collect your name, billing address, shipping address, email address, and
telephone number when you place an order.

We use your information to perform our contract to provide you with products or
services.

Seminars and Event Management

When you register for or attend a seminar or medical symposium, we may collect
your name, contact information, job title, professional specialty, and dietary
preference. 

We use your information to perform our contract to provide you with services. We
also have a legitimate interest in using your information to coordinate events.

Automatic Technologies or Interactions

As you interact with our website, we may automatically collect data about your
equipment, browsing actions and patterns. We collect this personal data by using
cookies and other similar technologies. We may also receive technical
information about you if you visit other websites employing our cookies
We may collect information from you, including your browser type, operating
system, Internet Protocol (IP) address (a number that is automatically assigned
to your computer when you use the Internet), domain name, click-activity,
referring website, and/or a date/time stamp for your visit. Web logs may be used
for things like monitoring website usage levels, diagnosing problems, and
detecting cybersecurity threats.
We may collect information about the device accessing the website such as MAC
address, device type, and device identifiers.

We have a legitimate interest in engaging in behavior-based advertising and
capturing website analytics.
You will provide consent for the use of cookies when required by law other than
strictly necessary cookies.
Web logs may be used for things like monitoring website usage levels, diagnosing
problems, and detecting cybersecurity threats.
We have a legitimate interest in making our website operate efficiently, in
identifying unique visitors, and in understanding how users interact with us on
their devices.

Clinical Trials

We may process your personal data on our behalf as part of a formal clinical
trial. Personal data collected and processed by a third party on our behalf may
include your name, postal address, email address, health-related information,
age and biometric data relating to the trial.

Our use is based upon your consent. In some contexts, we are also required by
law to collect this information.

Pharmacovigilance and Regulatory Requirements

We may process your personal data to meet our regulatory pharmacovigilance
requirements. Personal data may include your name, postal address, email address
and, in some cases, health-related data.

We use your information to comply with applicable laws.

Provision of Professional Education

We may process your personal data to assist in the provision of professional
education regarding our products. This may include your name, postal address,
email address and telephone number.

Our use is based upon your consent.

Customer Service/Call Center Interactions

We may process your personal data when providing customer service or product
support via a call center or directory, including via recorded telephone or
videoconference calls. Personal data processed may include your name, postal
address, email address, and telephone number. 

We have a legitimate interest in receiving, and acting upon, your feedback or
issues.

Safety and Physical Security

As the safety of life is of the utmost importance to us, we may process your
personal data to protect your health and safety while attending our sites.
Personal information processed may include your name, postal address, age,
location and contact details.

We use your information to protect the vital interests of yourself and others.




In addition to the information that we collect from you directly, we may also
receive information about you from other sources, including third parties,
business partners, our affiliates, or publicly available sources.

Sharing Of Personal Information

In addition to the specific situations discussed elsewhere in this Policy, we
may disclose personal information in close relation to the purposes specified
above to trusted third parties, collectively referred to as “Recipients.”

 * Affiliates and Acquisitions. We may share your personal information with our
   corporate affiliates (i.e., parent company, sister companies, subsidiaries,
   joint ventures, or other companies under common control).  If another company
   acquires our company, one of our businesses, or our assets, we will also
   share your personal information with that company as necessary, including at
   the negotiation stage.
 * Other Disclosures with Your Consent.  We may ask if you would like us to
   share your information with other unaffiliated third parties who are not
   described elsewhere in this Policy.
 * Other Disclosures without Your Consent. We will disclose personal information
   when required in response to subpoenas, warrants, or court orders, in
   connection with any legal or regulatory process, or to comply with relevant
   laws.  We will also share your personal information as necessary in order to
   establish or exercise our rights, to defend against a legal claim, to
   investigate, prevent, or take action regarding possible illegal activities,
   suspected fraud, safety of person or property, for audit purposes, or a
   violation of our policies.
 * Service Providers. We will share your personal information with service
   providers that are committed to/or under appropriate statutory obligations of
   confidentiality such as website hosting; email services; marketing; clinical
   research organizations (CROs); clinical trial administration, advertising,
   auditing; payment processing; fulfilling customer orders; data analytics;
   providing customer support; conducting customer research and satisfaction
   surveys; managing events; accepting grant applications;  cloud storage
   services; and other services that assist in providing or selling our products
   and services. These service providers may collect, store, analyze, or
   otherwise process information on our behalf.

How We Protect Personal Information

No method of transmission over the internet, or method of electronic storage, is
fully secure. While Mallinckrodt implements appropriate technical and
organizational security measures to protect your personal information from
unauthorized access, use, or disclosure, due to the public nature of the
internet, we cannot guarantee the security of your personal information. In the
event that we are required by law to inform you of any unauthorized access to
your personal information, we will notify you electronically, in writing, or by
telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do, you will be
prompted to create a password. You are responsible for maintaining the
confidentiality of your password, and you are responsible for any access to or
use of your account by someone else that has obtained your password, whether or
not such access or use has been authorized by you. You should notify us of any
unauthorized use of your password or account.

Cookies and Other Web Devices

Each website can send its own cookie to your web browser if your browser's
preferences allow it. Cookie settings can be controlled in your internet browser
to automatically reject some forms of cookies. If you do not allow cookies, some
features and functionality of our site may not operate as expected.

Mallinckrodt may use Adobe Flash technology (including Flash Local Stored
Objects "Flash LSOs") that allow Mallinckrodt to, among other things, serve you
with more tailored information, facilitate your ongoing access to and use of the
Site, and collect and store information about your use of the Site. Some of our
websites or emails also use pixel tags, web beacons, clear GIFs, or other
similar technologies to measure the success of marketing campaigns, and compile
statistics about usage and response rates, and other purposes.

Mallinckrodt may use other web devices to track website usage and views.  If you
have questions or concerns about our cookie or web device usage, please contact
us at privacy@mnk.com or call 800-822-2075.

Your EU Privacy Rights

Pursuant to EU General Data Protection Regulation (GDPR), below is additional
specific information which relates to the processing of personal information of
Data Subjects who are in the EU. Mallinckrodt has put in place a data protection
governance structure to ensure the data privacy rights and freedoms of Data
Subjects are protected.

 * Transfers to Other Countries. Some of the personal information we collect may
   be transferred to Recipients who are established in other countries, such as
   the United States. Transfers of EU personal data are based on an adequacy
   decision, standard contractual clauses, or your consent.
 * Retention. We retain personal information for as long as reasonably deemed
   required for legal or business purposes. During these periods, we take all
   appropriate steps to ensure that the privacy of your personal data is
   maintained. For further details, please contact privacy@mnk.com or call
   800-822-2075.
 * Data Subject Rights. For Data Subjects in the EU, pursuant to and to the
   extent allowed by applicable law, you have the following rights:
   * The right to be informed about our collection and use of your personal
     data.
   * The right to access the personal data we hold about you.
   * The right to have your personal data rectified if any of your personal data
     held by us is inaccurate or incomplete.
   * The right to be forgotten (erasure), i.e., the right to ask us to delete or
     otherwise dispose of any of your personal data that we hold.
   * The right to restrict (i.e., prevent) the processing of your personal data.
   * The right to data portability. This means that, if you have provided
     personal data to us directly, we are using it with your consent or for the
     performance of a contract, and that data is processed using automated
     means, you can ask us for a copy of that personal data to re-use with
     another service or business in many cases.
   * Rights relating to automated decision-making and profiling. We do not use
     your personal data in this way.
 * Compliance. You have the right to lodge a complaint with the Data Protection
   Authority in your country, including the Data Protection Commission,
   regarding the processing of your personal information in the EU.  Contact
   details are available at
   https://www.dataprotection.ie/en/contact/how-contact-us or
   https://edpb.europa.eu/about-edpb/board/members_en.

California Consumer Privacy Act Rights

Subject to legal limitations, if you are a resident of California, you may have
the right to make the following choices regarding your personal information:

 * Access to Your Personal Information. You may request access to your personal
   information by contacting us as described below. If required by law, upon
   request, we will grant you reasonable access to the personal information that
   we have about you.  You may be entitled to ask us for a notice describing
   what categories of personal information (if any) we share with third parties
   or affiliates for direct marketing. 
 * Changes to Your Personal Information. You may have a right to modify your
   personal information. You may contact us as described below in order to
   request that your information by modified. Note that we may keep historical
   information in our backup files as permitted by law. 
 * Deletion of Your Personal Information.  You may request that we delete your
   personal information by contacting us as described below.  If required by
   law, we will grant a request to delete information, but you should note that
   in many situations we must keep your personal information to comply with our
   legal obligations, resolve disputes, enforce our agreements, or for another
   one of our business purposes. 
 * Objection to Certain Processing.  You may object to our use or disclosure of
   your personal information by contacting us as described below. 
 * Promotional Emails. You may choose to provide us with your email address for
   the purpose of allowing us to send communications and promotional materials
   to you.  You can stop receiving most emails by following the unsubscribe
   instructions in emails that you receive.  If you decide not to receive these
   emails, we may still send you service related communications.
 * Revocation of Consent.  If you revoke your consent for the processing of
   personal information then we may no longer be able to provide you services.
   In some cases, we may limit or deny your request to revoke consent if the law
   permits or requires us to do so, or if we are unable to adequately verify
   your identity. You may revoke consent to processing (where such processing is
   based upon consent) by contacting us at the address described below.

Note that, as required by law, we will require you to prove your identity.  We
may verify your identity by telephone call or email. Depending on your request,
we will ask for information such as your name, your physical address, or the
name of our clinical trial in which you participated. We may also ask you to
provide a signed declaration confirming your identity. Following a request, we
will use reasonable efforts to supply, correct or delete personal information
about you in our files.

In some circumstances, you may designate an authorized agent to submit requests
to exercise certain privacy rights on your behalf.  We will require verification
that you provided the authorized agent permission to make a request on your
behalf.  You must provide us with a copy of the signed permission you have given
to the authorized agent to submit the request on your behalf and verify your own
identity directly with us.  If you are an authorized agent submitting a request
on behalf of an individual you must attach a copy of the following information
to the request:

 1. A completed Authorized Agent Designation Form indicating that you have
    authorization to act on the consumer’s behalf.
 2. If you are a business, proof that you are registered with the Secretary of
    State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

Requests to exercise your rights must be sent to privacy@mnk.com or made via
telephone by calling 800-822-2075.

Other Important Information

The following additional information relates to our privacy practices:

 * Minors. Our websites are not for individuals under age 13. Those individuals
   should not access a website or provide personal information to us.
 * Third-Party Applications/Websites.  We have no control over the privacy
   practices of websites or applications that we do not own.
 * Changes to This Policy.  We may change our Policy and practices over time. 
   To the extent that our Policy changes in a material way, the version of the
   Policy that was in place at the time that you submitted personal information
   to us will generally govern that information.  Our Privacy Policy includes an
   “effective date” and a “last updated” date. The “effective date” refers to
   the date that the current version took effect. The “last updated” date refers
   to the date that the current version was last substantively modified. 
 * Accessibility. If you are visually impaired, you may access this notice
   through your browser’s audio reader.
 * Information for California Residents.  California law indicates that
   organizations should disclose whether certain categories of information are
   collected, “sold” or transferred for an organization’s “business purpose” (as
   those terms are defined under California law).  You can find a list of the
   categories of information that we collect and share below. Please note that
   because this list is comprehensive it may refer to types of information that
   we share about people other than yourself. If you would like more information
   concerning the categories of personal information (if any) we share with
   third parties or affiliates for those parties to use for direct marketing
   please submit a written request to privacy@mnk.com or call 800-822-2075.  We
   do not discriminate against California residents who exercise any of their
   rights described in this Privacy Policy.

Last Updated: July 2020

Effective: January 2018

 

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and
1798.140 indicate that organizations should disclose whether the following
categories of personal information are collected, transferred for “valuable
consideration,” or transferred for an organization’s “business purpose” (as
those terms are defined under California law).  We do not “sell” your personal
information. The table below indicates the categories of personal information we
collect and transfer in a variety of contexts.  Please note that because this
list is comprehensive, it may refer to types of information that we collect and
share about people other than yourself.  For example, while we transfer credit
card or debit card numbers for our business purposes in order to process
payments for orders placed with us, we do not collect or transfer credit card or
debit card numbers of individuals that submit questions through our website’s
“contact us” page.

Categories of Personal Information We Collect To Whom We Disclose Personal
Information for a Business Purpose Identifiers – this may include real name,
alias, postal address, unique personal identifier, online identifier, email
address, account name, social security number, driver’s license number, passport
number or other similar identifiers.
 * Affiliates or subsidiaries
 * Third Party Service Providers
 * Business partners
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity

Additional categories of personal information described in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include
signature, physical characteristics or description, state identification card
number, insurance policy number, education, bank account number, credit card
number, debit card number, and other financial information, medical information,
and health insurance information.
 * Affiliates or subsidiaries
 * Third Party Service Providers
 * Business partners
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity

Characteristics of protected classifications – this may include age, sex, race,
ethnicity, physical or mental handicap, etc.  
 * Third Party Service Providers
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity
 * Business partners
 * Affiliates or subsidiaries

Commercial information – this may include information about products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendencies.
 * Third Party Service Providers
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity
 * Business partners
 * Affiliates or subsidiaries

Biometric information
 * Service Providers
 * Affiliates or subsidiaries

Internet or other electronic network activity information – this may include
browsing history, search history, and information regarding an individual’s
interaction with an internet website, application, or advertisement.
 * Affiliates or subsidiaries
 * Third Party Service Providers
 * Business partners
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity

Audio, electronic, visual, thermal, olfactory, or similar information
 * Affiliates or subsidiaries
 * Third Party Service Providers
 * Business partners
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity

Professional or employment-related information
 * Affiliates or subsidiaries
 * Third Party Service Providers
 * Business partners
 * Government entities, as may be needed to comply with law or to prevent
   illegal activity






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Mallinckrodt, the 'M' brand mark, the Mallinckrodt Pharmaceuticals logo and
other brands are trademarks of a Mallinckrodt company.© 2021 Mallinckrodt.
Mallinckrodt Pharmaceuticals is a registered business name of Mallinckrodt plc,
which is registered in Ireland as a public limited company with registration
number 522227 and has its registered office at College Business & Technology
Park, Cruiserath, Blanchardstown, Dublin 15, Ireland.

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