Probuphine REMS Website Privacy Statement

I. SCOPE OF THIS PRIVACY STATEMENT

This Privacy Statement describes the types of personal information Braeburn Pharmaceuticals, Inc. (“us,” “we” or “our”) collects through www.probuphinerems.com, (the “Site”), and the services offered through the Site, including the Braeburn Pathways Support and Services Program (“APSS”) and the Probuphine REMS Program (collectively with the Site and the APSS, the “Services”) and how we collect, use, and share that information. This Privacy Statement does not govern our collection of personal information through any website or other means, other than through the Services.

By using the Services, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not access, browse, or use the Services.

II. PERSONAL INFORMATION WE COLLECT

A. Information You Give Us

You do not have to give us any personal information to browse the Services. However, you may be asked to provide personal information to submit or request information from us, or to use the Services. Once you provide us with personal information about you, you are no longer anonymous to us. This information may include:

  • Registration information. You may be asked to provide registration information to sign up for certain services, including without limitation your name, health care credentials if you are registering as a health care professional, email address, mailing address, telephone number, and fax number.
  • Additional Information. Additional information you provide to us, including through comments, feedback, and emails.

B. Automated Information Collection

We may collect certain information about your use of the Services through the use of tracking technologies or by other passive means. This “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Services, search engines used, the internet protocol (IP) address used, the length of time spent on the Services, the pages you looked at on the Services, other websites you visited before and after visiting the Services, the type of internet browser you have, the frequency of your visits to the Services, and other relevant statistics, including the following:

  • Log Information. When you access the Services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
  • Links. The Services may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.
  • URLs. When you visit or access the Services, we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Services. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Services.
  • Cookies. When you visit or access the Services, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Services by storing user preferences and tracking user trends. Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Services.
  • Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Services and to recognize users by accessing our cookies. We may employ web beacons to facilitate Services administration and navigation, to track the actions of users of the Services, to compile aggregate statistics about Services usage and response rates, and to provide an enhanced online experience for visitors to the Services. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
  • Aggregate Information. We may compile certain personal information and other information collected through the Services on an aggregate basis. This information may include, without limitation, the number of people who have visited the Services and other user demographics. Such aggregate information does not identify you individually.

III. HOW WE USE PERSONAL INFORMATION

Personal information collected through the Services may be used by us and our affiliates for purposes of:

  • Responding to your questions and feedback;
  • Providing the services you select through the Services;
  • Confirming your eligibility to access certain products and Services;
  • Contacting you, whether by email, postal mail, or telephone with information about the Services, our products, or our services;
  • For such purposes as you may authorize at the time you submit the information;
  • Auditing, research, and analysis to maintain, protect, and improve the Services and our services;
  • Ensuring the technical functions of our network;
  • Improving and customizing the content and layout of the Services;
  • Developing new products and services; or
  • Compiling personal information and other information collected through the Services on an aggregate basis.

IV. PERSONAL INFORMATION WE SHARE

We do not sell, rent, trade, or otherwise share personal information collected through the Services, except as described below:

  • In Connection with our Offerings. The Services involves the sharing of certain personal information collected through the Services (i) in connection providing and administering the Services, including without limitation to health care providers and insurance institutions in connection with APSS, and (ii) as you otherwise provide your consent.
  • Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
  • Service Providers. We work with third parties that provide services on our behalf. Such services may include website hosting, marketing, and website usage analytics. We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services. We do not bear any responsibility for any actions or policies of such third parties.
  • Consent. We may share personal information in accordance with any consent you provide.
  • Required by Law. We may disclose personal information or any information collected through the Services if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
  • Certain Transactions. We may disclose or transfer personal information or any information collected through the Services to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

V. AGGREGATE INFORMATION

We may compile personal information and other information collected through the Services on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Services, demographic information about users of the Services, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

VI. Your Choices

A. Information You Provide

You can always choose whether or not to provide information on the Services. However, if you choose not to disclose certain information, you may not be able to register as a user of the Services, which may limit your access to certain portions of the Services.

B. Communications From Us

If at any time you decide that you no longer wish to receive notices from us regarding the Services, you may indicate this preference by contacting us at registration@braeburnpharma.com.

C. Do Not Track

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Braeburn webservers do not currently respond to these signals.

VII. INFORMATION STORAGE AND SECURITY

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Services. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Services. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII. A SPECIAL NOTE ABOUT CHILDREN

Children are not eligible to use the Services, and we ask that minors (children under the age of 18) not submit any personal information to us. If you are a minor, you can use the Services only in conjunction with your parents or guardians.

IX. EXTERNAL LINKS

The Services may contain links to various websites that we do not control. When you click on one of these links, you will no longer be transacting business through the Services. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Services. If you visit a website that is linked to the Services, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

X. SPECIAL ADMONITIONS FOR INTERNATIONAL USE

The Services are hosted in the United States and are intended for use by residents of the United States of America only. All matters relating to the Services are governed exclusively by the laws of the New Jersey in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.

XI. UPDATES TO THIS PRIVACY STATEMENT

We may change or update the Site or any of our policies and procedures without prior notice. We will post a notice on the Services to advise you of any significant changes to this Privacy Statement and indicate via the “Last Updated” legend at the bottom of this Privacy Statement when it was most recently updated. Your continued use of the Site signifies your continued assent to the terms of this Privacy Statement, as updated or amended at that time.

XII. QUESTIONS REGARDING THIS PRIVACY STATEMENT

If you have any questions or comments regarding this Privacy Statement, please send us an email at registration@braeburnpharmac.com.

This Privacy Statement is effective as of May 27, 2016.

Last Updated: May 27, 2016