EU Privacy Addendum

This EU Privacy Addendum applies in circumstances where Alkermes’ privacy practices are subject to the EU General Data Protection Regulation (“GDPR”). This will be the case where you are accessing a website controlled by Alkermes plc or Alkermes Pharma Ireland Limited, both of which are registered in Dublin, Ireland. When you are dealing with these companies, they will control and be responsible for the collection and processing of your personal data as data controller.

This Addendum should be read in conjunction with the Alkermes Privacy Policy. In this Addendum, we set out further information on our processing activities and we also set out details of the rights which you have under the EU GDPR.

If you have any queries about this Privacy Notice please contact us at dataprotection@alkermes.com.

Legal Bases for Processing Personal Data

The legal bases under the EU GDPR which justifies our collection, use and disclosure of your personal data in the manner described in the Privacy Policy are, depending on the particular processing:

Our legitimate interests in conducting our business in a responsible and commercially prudent manner. We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
The performance of a contract with you;
To take steps at your request prior to entering into a contract with you;
To comply with our legal and regulatory obligations; and
Your consent.

Legal Bases for Processing Special Categories of Data

Where we process special categories of data, such as data relating to your health, this will be done on the basis of either:

Your explicit consent; or
Compliance with our legal and regulatory obligations.

Retention Timelines

The information that you provide to us is stored on servers that are operated and maintained by Alkermes and third parties under contract with Alkermes. Alkermes will only retain your data for such period of time as may be reasonably necessary to fulfil the purposes set out in the Privacy Policy and, if relevant, to deal with any claim or dispute that might arise in connection with any Services which you avail of via our websites.

Transfers Abroad

In connection with the Services provided on our websites, we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognized by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers from the EU to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at dataprotection@alkermes.com.

Cookies

The Services provided on our websites may use cookies, web beacons and similar technologies including, but not limited to, pixels and tags, and may place such technologies on your personal computer or any other device you may use to access the Services. A cookie is a small file of letters and numbers downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device. Web beacons are small strings of code that the Services may use to deliver small graphic images on a web page or in an email. Web beacons may recognize certain types of information on your computer, such as cookies and the time and date a page is viewed.

You can block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our site.

Your Rights

Under the EU GDPR, you have the following rights, which apply in certain circumstances and subject to certain restrictions, in relation to your personal data:

The right to access your personal data;
The right to request the rectification and/or erasure of your personal data;
The right to restrict the use of your personal data;
The right to object to the processing of your personal data;
Where our processing of personal data is based on you having provided your consent or the processing is necessary for the performance of a contract with you, you have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and
Where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@alkermes.com.

Changes to our Privacy Policy and this Addendum

We will only use personal data in the manner described in the Privacy Policy and this Addendum in effect when the information was collected from you. However, we reserve the right to amend the terms of the Privacy Policy and this Addendum at any time by posting revisions to these documents. If at any point, we decide to use personal data in a manner which is materially different from that stated at the time it was collected, we will seek to notify users by email to the extent that we have email addresses. Where required by the GDPR, you will be given the choice at that time to “opt-in” for any additional uses or disclosures of your personal data that you made available to us prior to the change in the Privacy Policy or this Addendum. In such circumstances, if you do not grant us your informed consent for the processing of your personal data for such additional purposes your personal data will not be used for any purposes other than those to which you have agreed. For the avoidance of doubt, in the event of any conflict between the provisions of this section in the Addendum and section 6 of the Privacy Policy, this section in the Addendum shall prevail.

Complaints

If you are not happy with the way we have used your information or addressed your rights, please contact us at dataprotection@alkermes.com.

In addition, you have the right to make a complaint to the Irish Data Protection Commission by emailing info@dataprotection.ie.

Effective Date: January 08, 2019