Consumer Health Data Privacy Notice
Avadel CNS Pharmaceuticals, LLC and its affiliates (“we,” “our,” or “us”) respects the privacy of your “consumer health data” as defined by applicable law. This Consumer Health Data Privacy Policy (“Policy”) is designed to assist you in understanding how we collect, use, share, and safeguard your consumer health data. Depending on the state in which you reside, this Policy applies to individuals who access our websites (collectively, “Sites”) and any of our services (“Services”). This Policy applies in addition to our U.S. Online Privacy Policy.
Categories of Consumer Health Data We Collect
Depending on how you interact with our Sites and Services, we will collect the following categories of consumer health data for the following purposes and uses:
- Diagnostic Information: When you sign up for updates regarding our products or attempt to enroll in our RYZUP™ Support Services, you may provide us with information regarding your health including concerns of excessive daytime sleepiness, cataplexy or narcolepsy.
- Demographic Information: When you attempt to enroll in our RYZUP™ Support Services, you may provide us with your date of birth and gender so that we can properly enroll you in the program.
- Health Care Seeking Behavior: When you visit our Sites, signup for updates regarding our products or attempt to enroll in our RYZUP™ Support Services, you may share with us information related to your need or desire for certain healthcare services.
In addition, several of the categories of personal data we collect may be considered consumer health data depending on the context and extent of information you provide to us. To view the full list of categories of personal data we may collect, please see the “Personal Data We Collect” section of our U.S. Online Privacy Policy.
Depending on the state in which you reside, we may use cookies and other tracking technologies; however, we do not use them to identify your past, present, or future health status. For more information, please see our U.S. Online Privacy Policy. We do not use non-strictly necessary cookies for Washington residents.
In addition to the purposes stated above, we may process consumer health data for purposes allowed under applicable law, such as to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable law; preserve the integrity or security of our systems; or investigate, report, or prosecute those responsible for any such action that is illegal under applicable law.
Categories of Sources from Which We Collect Consumer Health Data
We receive consumer health data directly from you. In some cases, we may receive personal data about you from other sources. This includes government entities, advertising networks, data brokers, operating systems and platforms, mailing list providers, social networks and advertising and marketing partners. We do not receive information from advertising networks or data analytics providers regarding Washington residents.
Sharing of Consumer Health Data
We share all of the categories of consumer health data listed above with the following categories of third parties and specific affiliates:
- Service Providers
- Operating Systems and Platforms
- Data Analytics Providers
- Advertising Networks
- Social Media Networks
Your Privacy Rights
Under applicable law, you may have certain privacy rights regarding your consumer health data, including the right to:
- Confirm whether we are collecting, sharing, or selling your consumer health data;
- Access your consumer health data, including a list of all third parties and affiliates with whom we shared or sold your consumer health data and an active email address or other online mechanism that you may use to contact any third parties;
- Withdraw your consent from our collection and sharing of your consumer health data; and
- Delete your consumer health data.
To exercise your rights, please submit a request by emailing us at privacy@avadel.com. If legally required, we will comply with your request upon verification of your identity. To do so, we will ask you to verify data points based on information we have in our records. If we refuse to take action regarding your request, you may appeal our decision by replying to the email you received from us in response to your request.
Effective as of April 15, 2024
