Corporate Privacy Notice for California
Last Updated: January 27, 2020
In accordance with the California Consumer Privacy Act (“CCPA”), this Corporate Privacy Notice for California (“Notice”) discloses the personal information we collect from you and the purposes for doing so. As used in this Notice, “Arena,” “we,” “us” and “our” refer to Arena Pharmaceuticals, Inc. and our subsidiaries, joint ventures, and other companies under a common control (“Affiliates”), and “personal information” means all personal information as defined in the CCPA, which includes information relating to a particular household as well as a natural person. This Notice applies to most of the personal information collected by Arena from California residents in the course of conducting our general business operations. There are four main exceptions:
- This Notice does not apply to personal information collected via the www.arenapharm.com website (the “Website”), for which we have a separate Privacy Statement that is available here
- This Notice does not apply to personal information that we obtain in connection with clinical studies sponsored by Arena, which are exempt from the CCPA and are separately regulated. Clinical trial participants (and their parents or guardians, if applicable) will have received a separate notice concerning their personal information. If you have any concerns about our processing of personal information in connection with a clinical trial, please see the information protection notice provided as part of the clinical trial intake process, as that notice will contain important information and a designated contact person for concerns – but you can always contact us using the contact information provided below.
- This Notice does not apply if you have received (directly or through our service providers or collaborators) a separate notice concerning our use of your personal information. This may occur when we need to provide a separate notice to meet the requirements of specific laws or when required by generally accepted good practices in the pharmaceutical industry.
- This Notice does not apply to the personal information of our employees or job applicants. An employee privacy notice is available to our employees on Arena’s SharePoint site. A job applicant privacy notice is provided to applicants when they submit their personal information to us in connection with their job application.
OUR BUSINESS PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION
We may use the personal information you provide us to:
- Contact you
- Respond to your comments and questions
- Consider you as a clinical investigator, advisor or other contractor
- Enter into, or take steps to enter into, a contract with you or your employer or business
- Perform our contracts with you or your employer or business
- Make payments to you
- Comply with our legal and regulatory obligations including pharmaceutical quality and safety information reporting obligations
CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS
We may process the following categories of personal information, as appropriate for the relevant processing activity:
- Contact details, including postal and e-mail addresses
- Employment-related information, information about education and professional qualifications, including professional specialties, prescribing data, and verification of credentials
- Financial information, health-related information, year of birth, and other pertinent information in connection with product quality complaints and pharmaceutical safety information reporting
SOURCES OF PERSONAL INFORMATION
You may provide personal information to us directly or via our service providers.
Information regarding investigators and clinical site personnel is provided to Arena by our CROs pursuant to contracts under which the CROs manage Arena’s clinical trials, including selection, monitoring, and payment of clinical sites and investigators.
Information regarding advisors sometimes is provided by meeting planners and other service providers who support advisory board meetings under standard services agreements.
Information regarding physicians typically is provided under a license or services agreement with a data vendor.
THE RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE PERSONAL INFORMATION
We may share your personal information with:
- Our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Notice;
- Our service providers under appropriate contractual restrictions;
- Companies or individuals who advise us or collaborate with us in connection with the development or commercialization of our pharmaceutical products;
- Third parties in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Notice;
- Relevant authorities, or other recipients as required in litigation, if Arena believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant regulatory requirements and laws, such as laws requiring the disclosure of payments made to healthcare providers, (iii) to respond to subpoenas or warrants served on Arena; (iv) to protect or defend the rights or property of Arena; or (v) to investigate or assist in preventing any violation or potential violation of the law.
THE PERIOD FOR WHICH THE PERSONAL INFORMATION WILL BE STORED, OR THE CRITERIA FOR DETERMINING THE RETENTION PERIOD
How long we retain personal information varies according to the type of information in question and the purpose for which it is used. Certain laws may require us to store personal information for specified periods. We delete personal information within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your personal information before the end of its retention period. We may archive personal information (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.
CHILDREN (UNDER 18)
We do not knowingly collect information about children (anyone under 18), except in connection with pediatric clinical studies, which, as explained above, are not subject to this Notice. If any parent or guardian of a child believes that we have personal information about that child that is not related to the child’s participation in one of our clinical studies, please contact us through one of the means below.
RIGHTS OF CALIFORNIA RESIDENTS UNDER THE CCPA
You have the right to request the following information:
- The categories of personal information Arena has collected about you.
- The categories of sources from which the personal information was collected.
- The business purpose for collecting the personal information.
- The categories of third parties with whom Arena has shared the personal information.
- The specific pieces of personal information Arena has collected about you.
RIGHT TO REQUEST DELETION
Upon a verifiable request, made through one of the methods provided within the “Contact Us” section below, we will delete personal information we have regarding you and direct our service providers to delete your personal information from their records, to the extent required by the CCPA. Please note that Arena may be required or permitted by law to not remove (or allow removal of) your personal information. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
RIGHT TO BE FREE FROM DISCRIMINATION
Arena will not discriminate against you for exercising any of your rights under the CCPA.
TIME LIMIT TO RESPOND
We will respond to all legitimate requests within forty-five (45) days, or as permitted by the CCPA.
CCPA CONTACT INFORMATION
If you are a California resident and would like to exercise the rights described above on or after January 1, 2020, please contact us using one of the
|Toll-Free Phone Number: 1-877-541-0485E-mail: email@example.com||
Mail: Arena Pharmaceuticals, Inc.
Attn: Data Protection Officer
CHANGES TO THIS NOTICE
This Notice may be amended from time to time for any reason. Generally, we will notify you of any changes to this Notice by posting a new Notice on this page as indicated by changing the “Last updated” date above. However, if we intend to process your personal information for a purpose other than the purposes for which it was initially collected, we will take appropriate steps to contact you first and notify you of the new purpose.