PRIVACY POLICY

Website Privacy Statement

We at Innocoll Holdings Public Limited Company (“Innocoll”) respect your right to privacy and comply with the applicable privacy law obligations including the General Data Protection Regulation (“GDPR”). Innocoll is a “controller”, as described in GDPR, in relation to the personal data we collect about you. References to “we”, “us” and “our” mean Innocoll.

We have created this privacy statement (“Website Privacy Statement”) in order to demonstrate our firm commitment to privacy. The purpose of this Website Privacy Statement is to outline how we deal with any personal data which you provide to us while visiting the Innocoll website (“Website”). Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.

By using this Website, you agree that you have read and understood this Website Privacy Statement.

Information we collect

We may collect and process information that identifies you (“Personal Data”). If you submit Personal Data to us, it will only be used for the purposes stated in this Website Privacy Statement. For general web-browsing, the following Personal Data is revealed to us: your IP address (in circumstances where they have not been deleted/clipped/made anonymous), details of your browser and your interaction with our Website. If you further interact with our Website, including by corresponding with us, providing information via the Website, providing feedback through the “contact us” pages, requesting additional services or interacting with our “careers” page, we will collect additional Personal Data relating to that activity. Such information may include your name, address, email address, telephone number, other contact details, birth date, billing and credit card information and other information that you may voluntarily provide us.

Like most websites, we use tracking information to determine which areas of our Website users like and don’t like based on traffic to those areas. We gather statistical and other analytical information (collected on an aggregate basis) of all visitors to our Website. This information may include the IP and logical address of the server you are using, the top level domain name from which you access the Internet, the type of browser you are using, the date and time you access our Website and the Internet address linking to our Website. This information helps us to continue to build a better service for our customers. We use this kind of data gathered from visitors to our Website in an aggregate and anonymised form to get a better understanding of where our visitors come from and to help us better design and organize our Website. Once anonymised, this data is no longer considered your Personal Data.

Personal Data will only be used by us for the following purposes (and corresponding lawful bases):

• the purposes for which it was provided by you, including as necessary to fulfil our contractual or any other obligations to you or to respond to your correspondence (which is in our legitimate interest);
• verification purposes and statistical analysis based on our legitimate interest in carrying out such activities; and
• marketing and administration purposes insofar as that we will provide you information about goods and services we offer that are similar to those that you have already ordered or inquired about (which is in our legitimate interest).
  
  

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will retain and securely destroy your Personal Data in accordance with applicable laws and regulations. To request more information around data retention please contact us at inquiries@innocoll.com

For further information on the length of time in which we may retain your personal information, please contact us using the details contained below in the ‘Contact us’ section.

Cookies

This website uses “cookie” technology to improve your experience. A cookie is a little piece of text stored by the browser on your computer, at the request of our server. When you visit the website again, the cookie allows that site to recognize your browser. We may use cookies to deliver content specific to your interests and to save your personal preferences so you do not have to re-enter them each time you connect to our website – our cookies are not available to other websites. You are always free to decline our cookies, if your browser permits, or to ask your browser to indicate when a cookie is being sent. You can also delete cookie files from your computer at your discretion. However, some website features or services may not function properly without cookies.

Links

Our Website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy statements and that we do not accept any responsibility or liability for these privacy statements. Please be aware:

• If you access another website through a link we provide, you are subject to the privacy policy of that website. Links to other websites do not constitute an endorsement of that website by Innocoll. Innocoll (or affiliates) is not responsible for the contents of any pages referred from its Website.

We encourage visitors to review each website’s privacy policy before disclosing any personally identifiable information.

If you fail to provide Personal Data

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing goods or services), or we may be prevented from complying with our legal obligations (such as to ensure your health and safety).

Automated decision-making

We do not envisage that any decisions will be taken about you using automated means, however we will update our Website Privacy Statement if this position changes.

Disclosure of Information to Third Parties

We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our website, but we do not sell or distribute without your explicit consent your Personal Data to third parties for purposes of allowing them to market products and services to you.

We will not disclose your Personal Data to any third party unless you have consented to this disclosure or unless such disclosure is necessary to create, carry out or terminate a legal obligation or quasi-legal obligation with you. In these cases, the third party will act as our third party data processor and will be required to enter into an appropriate data processing contract with us which protects your rights.

Personal Data which has been submitted to Innocoll may be disclosed to other member companies in the Innocoll network of companies, where this is necessary to meet the purpose for which the visitor has submitted the information. This will be done in accordance with applicable data protection laws.

International Data Transfers

We will, from time to time, send some of your personal data to recipients based in countries located outside of the European Economic Area (“EEA”). As certain countries are not within the EEA, this may mean that such countries are not deemed to provide an adequate level of protection for your personal information. To ensure that your personal data receives an adequate level of protection we will put in place for any international transfers appropriate measures, as provided for under data protection laws, in order to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects EU data protection laws.

Sale of Business

We reserve the right to transfer information (including your Personal Data) to a third party if it should become contractually or legally necessary in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Website Privacy Statement and provided that the third party only uses your Personal Data for the purposes that you provided it to us.

Security

This Website has security measures in place to protect the loss, misuse and alteration of the information under our control. In particular, we use reasonable endeavours to ensure that all appropriate confidentiality obligations and technical and organizational security measures are in place to prevent any unauthorized or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organizational measures) to protect your Personal Data.

Withdrawal of Consent

If you choose to unsubscribe from any mailing lists or any registrations, please contact us by emailing to inquiries@innocoll.com

Your Rights

You have certain rights under data protection legislation as summarised below:

1. Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data, as well as certain information on how we are processing such data.
2. Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Considering the purpose of the processing, you may also, in some cases, be entitled to supplemental information regarding incomplete Personal Data.
3. Right to erasure (right to be forgotten): You may, in certain circumstances, have your Personal Data deleted, for example if your personal information is no longer necessary in relation to the purpose for which it was collected, if you have objected to the processing of Personal Data and we do not have a legitimate interest which outweighs your interest, if the Personal Data has been processed unlawfully, or if the Personal Data must be deleted to comply with a legal obligation.
4. Right to restriction of processing: You may require that we restrict the processing of your Personal Data in certain cases, for example where we no longer need your Personal Data but you need it to determine, enforce or defend legal claims or you have objected to processing based on our legitimate interest in order to enable us to check if our interest overrides your interest.
5. Right to data portability: In some circumstances, you may be entitled to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another controller.
6. Right to object: You have the right to object to the processing of your Personal Data in certain circumstances, for example where the processing is based on our legitimate interest. If so, in order to continue processing, we must be able to show compelling legitimate grounds that override your interests, rights and freedoms.

Your rights will in each case be subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data, can be obtained by contacting us using the details in the ‘Contact us’ section below. If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us using the details in the ‘Contact us’ section below.

Right to Make a Complaint

If you have any grievance, issue or problem in respect of our handling or processing of your Personal Data in any way, you have the right to lodge a complaint to the Data Protection Commission, whose contact details are as follows:

Telephone:	1890 252 231
Email:	info@dataprotection.ie
Address:	Data Protection Commission Canal House Station Road Portarlington Co. Laois R32 AP23 Ireland

Changes to the Website Privacy Statement

We may update or amend this Website Privacy Statement from time to time to comply with law or to meet our changing business requirements. Any changes to this Website Privacy Statement will be posted on this Website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If at any time we decide to use Personal Data in a manner significantly different from that stated in this Website Privacy Statement, or otherwise disclosed to you at the time it was collected, we will notify you by email.

Contact Us

If you have any questions about this Website Privacy Statement or practices relating to the website, or you would like to raise a complaint, please contact us at:

Email:	inquiries@innocoll.com
Telephone:	1-855-851-9222

Last Updated October 2018