Kadmon Investors and Media

Privacy Policy

Privacy Policy

Kadmon Privacy Policy –

Your Privacy Rights

Kadmon Holdings, Inc., and its subsidiaries (collectively “Kadmon”, “We” and “Our”) recognizes the importance of protecting the privacy of information we may receive from visitors to our websites (collectively, the “Site”). You may visit our Site without telling us anything about yourself, and our Site collects only such technical information as disclosed in this Privacy Policy. If you contact us and choose to provide Personal Information (as defined herein), we will utilize it to respond to your inquiry and as otherwise outlined below. In addition, we will not send unsolicited messages to users of our Site who indicate that they do not wish to receive such messages. If at any time you do not wish to receive unsolicited email messages from us, please contact us at customer.service@kadmon.com.

Please carefully read this Privacy Policy to learn more about how we collect, use, disclose and store information provided, and the steps we take to help protect the often sensitive information provided from unauthorized use or disclosure. When you submit information to, or through, the Site, you consent to the collection, processing and retention of your information as described in this Privacy Policy.  Notwithstanding anything herein, if any applicable law differs from this Privacy Policy, Kadmon will comply with such applicable law.

 

SECTION 1:

PERSONAL INFORMATION COLLECTED

Personal Information

“Personal Information” is information associated with or used to identify or contact a specific person.

  • Contact data – your name, address, telephone number, email address, or company name
  • Demographic data – age, gender, geographic location or the products that you are interested in
  • In certain circumstances, Usage Data (defined in following section)

We collect and store the Personal Information that you have provided to us. Here are some examples of manners in which we may collect your Personal Information on the Site:

  • We may collect your email address, first and last name and zip code if you sign up for an online newsletter; and
  • We may collect your email address if you contact us with a question.

From time to time, we may collect Personal Information from you in other ways that are not described above. If you do not want us to collect your Personal Information, please do not provide it to us. If you choose to provide Personal Information, you may have the right to request to delete the Personal Information we have collected from you or to opt-out of the sale of your Personal Information. To make requests, please use the contact information at the end of this Privacy Policy.

Sensitive Personal Information (such as health, medical or financial information) may be subject to stricter regulation and consent requirements than other information. Before providing it to us, we urge you to carefully consider whether to disclose your Sensitive Personal Information. If you do provide Sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Statement.

Usage Data

Usage Data, a type of Personal Information, is information about an individual’s activity on or through the Site. By itself, this data does not identify an individual. If Usage Data and other types of Personal Information are linked, and identify an individual, then this Usage Data may be considered to be Personal Information.

Here are some examples of the Usage Data that is collected via the Site and a description of how this information is used:

  • Internet Protocol (IP) address – Your IP address is a number that lets computers attached to the Internet know where to send you data (such as the web pages you view).
  • Cookie – A “cookie” is a small text file that may be used to collect information about your activity on the Site. For example, when someone visits a page within the Site, a cookie is placed on the user’s machine (if the user accepts cookies) or is read if the user has visited the Site previously. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Site.

 

SECTION 2:

USE OF PERSONAL INFORMATION COLLECTED

 

Personal Information – Without your explicit consent, we may use your Personal Information that is voluntarily provided on the Site primarily to:

  • deliver services, such as information, newsletters or other information that you request;
  • alert you to special offers, updated information and other new services from us, or other third parties, or to forward promotional materials;
  • complete a transaction or service requested by you;
  • ensure the Site is relevant to your needs;
  • help us create and publish content most relevant to you;
  • fulfill the terms of a promotion;
  • notify you about a material change to this privacy policy or the Terms of Use, if necessary;
  • allow you access to limited-entry areas of the Site (if applicable); and/or
  • contact you in response to sign up forms, such as Contact Us.

If you are a healthcare provider (“Provider”), you are responsible for obtaining any legally required authorization, consent or other permission from your patients prior to providing their Personal Information to Kadmon through the Site. By submitting any Personal Information about a patient, you represent and warrant to Kadmon that you have obtained all required permissions to do so.

Non-Personal Information – Non-Personal Information is used as described above and in other ways as permitted by applicable laws, including combining non-Personal Information with Personal Information.

 

SECTION 3:

CONTROL THE USE OF YOUR PERSONAL INFORMATION

Direct Marketing Opt-Out

If you no longer wish to receive promotional emails from Kadmon, you may click the “Unsubscribe” link in an email at any time.

Online Advertising Opt-Out

You may opt out of third parties collecting your Personal Information for online advertising purposes by visiting the National Advertising Initiative’s opt-out page or the Digital Advertising Alliance’s opt-out page.

Tracking Preferences

You may disable or delete browser cookies through your browser settings. Cookies are generally easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of the Services may not work properly.

The Services do not respond to “Do Not Track” signals.

Update Your Personal Information

You may have the right to review and correct certain of the information that you have provided to us by contacting us using the contact information below or by accessing your account(s) on the Site.

 

SECTION 4:

DISCLOSURE OF PERSONAL INFORMATION

 

Under the following circumstances, we may disclosure your Personal Information to third parties:

(i)       To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your Personal Information for research, administrative and/or internal business purposes. These parties may use your Personal Information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your Personal Information in this manner, please do not provide us with this information. If you choose to provide Personal Information you may have the right to request to delete the personal information we have collected from you or opt-out of the sale of your personal information. To make requests please use the contact information at the end of this Privacy Policy.

(ii)      To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Site and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection). We seek to ensure that these unaffiliated third parties will not use the Personal Information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Site will have access to users’ Personal Information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any Personal Information to us. If you choose to provide Personal Information you may have the right to request to delete the personal information we have collected from you or to opt-out of the sale of your personal information. To make requests please use the contact information at the end of this Privacy Policy.

(iii)      In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

(iv)       To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

(v)      To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.

(vi)     When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Site terms and conditions or other agreements or policies. Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your Personal Information to any third parties.

Non-Personal Information – We use non-Personal Information collected on the Site in the manner disclosed above. We may share this non-personal information with third parties.

 

SECTION 5:

OTHER IMPORTANT INFORMATION

Notification of Changes to This Policy

Kadmon is continually improving and adding new functionality and features to this website. Because of these ongoing changes, changes in the law and the changing nature of technology, Kadmon’s data practices will change from time to time. We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. If and when our data practices change, Kadmon will post the changes on this page of our website to notify you of the changes. Such changes to the Privacy Policy will become effective when posted. Unless stated otherwise, our current Privacy Notice applies to all Personal Information that we have about you. We stand behind the promises we make, however, and will not materially change our policies and practices to make them less protective of Personal Information collected in the past without the consent of affected individuals. We encourage you to check this page frequently by clicking on the Privacy Policy link on any page of our Site.

Visiting Our Websites From Outside the United States

This Privacy Policy is intended to cover collection of information on our Site from residents of the United States. If you are visiting our Web site from outside the United States, please be aware that your information may be transferred, stored and/or processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Site, you understand that your Personal Information may be transferred to our facilities and those third parties with whom we may share it, as described in this Privacy Policy.

Links to Other Sites

This Privacy Policy applies only to Kadmon and its Site. The website may contain links to other sites that are not owned or controlled by Kadmon. Please be aware that we are not responsible for the privacy policies of such other sites. These third-party Web sites may independently solicit and collect information, including personal information, from you. We recommend that you consult the privacy statements of all third-party Web sites you visit by clicking on the “privacy” link typically located at the bottom of the Web page you are visiting.

Information Retention

We retain information as long as it is necessary and relevant for our operations. In addition, we retain Personal Information to, among other things, comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. When your Personal Information is no longer needed for Kadmon’s business purposes, we dispose of it subject to applicable law and Kadmon policy.

Information Security

In accordance with applicable laws, we employ reasonable security measures intended to help protect the security of all information submitted through the Site from unauthorized access, use, alteration and disclosure. The security of information transmitted through the internet cannot, however, be guaranteed. Please note that any information you send to Kadmon via email is sent via an unsecured email link. Due to the nature of the Internet, there is a possibility that unsecured (unencrypted) email could be intercepted and read by third parties. Kadmon assumes no responsibility for interception of confidential information (including in a resume or CV) that you send in an unsecured (unencrypted) email message. We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. Users of the Site are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Site. Any access to the Site through your user ID and password will be treated as authorized by you. To help protect your Personal Information, we may suspend your use of all or part of the Site, without notice, if Kadmon suspects or detects any breach of security. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Our Children’s Policy

The Site is not intended for use by children. If you are under the age of majority in your place of residence, you may use the Site only with the consent, or under the supervision, of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that a child under age 13 has provided Personal Information to or through the Site without first receiving their applicable verified consent, we will use that information only to respond directly to that child (or their parent or legal guardian) to inform the child that they cannot use the Site, and subsequently we will dispose of such Personal Information in accordance with this Privacy Statement.

If you believe Kadmon may have any information from or about a child under age 13, please contact us using the contact information below.

Digital Advertising

We may use third-party advertising companies to place ads on other websites and digital services. These companies may use information obtained from data collection tools in order to measure advertising effectiveness and to provide advertisements of interest to you.

You can opt out using the contact information at the end of this Privacy Policy, so as not to receive targeted ads from use of the tools, but this will not affect any general advertisements you may receive.

 

SECTION 6:

California Privacy Rights

 

California Civil Code Section 1798.83 may permit California residents to request certain information regarding the disclosure of personal information by certain businesses to third parties for direct marketing purposes. To make such a request, please contact us at the address listed below.  Kadmon will review your request and determine whether California Civil Code Section 1798.83 applies.

Kadmon Holdings, Inc.
Attn: Customer Service
450 East 29th Street
New York, NY 10016
customer.service@kadmon.com

1-800-405-8506

Please refer to this page from time to time to review these and other new features.

California Consumer Privacy Act Notice for California Residents (CCPA)

If you reside in the State of California, this Privacy Notice supplements the information above regarding the collection, use, disclosure and sale of your personal information.

 

The California Consumer Privacy Act of 2018 (CCPA) gives California consumers the right to know what personal information is collected about them by certain businesses and how it will be used, disclosed and sold by these businesses.  The CCPA gives California consumers the right to request access to and deletion of their personal information from those businesses, and the right to request that their personal information not be sold. Upon receipt of such request, Kadmon will determine whether the collection, use, disclosure or sale of personal information in question is subject to the CCPA at that time. 

 

We collect personal information from you when you interact with us online (through our Site) or offline (such as through your healthcare providers, if you are a patient.)  The information we collect from you will depend on the nature of our interaction with you, but may include the following categories that we have collected in the 12 months preceding the date this Privacy Notice was last updated:

 

Categories of Personal Information CollectedCategories of SourcesPurpose of Collecting/SharingCategories of Third Parties to Whom We Disclose Personal Information
Identifiers – such as a full name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number (partial and full), driver’s license number, passport number, or other similar identifiers.
  • You (directly from participant).
  • Healthcare providers.
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Consumer reporting agencies and other third parties who verify the information you provide.
  • Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records.
  • Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID.
  • Determine program, product, and service eligibility.
  • Enroll you in our programs and provide our products and services to you.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Communicate with you regarding our programs, products, and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Conduct internal business analysis and market research.
  • Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
  • Engage in joint marketing initiatives.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Provide access to, monitor, and secure our facilities, equipment, and other property.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes or to help ensure the integrity of our programs and the preservation of your privacy.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third-parties that help administer, manage and analyze our programs and services
  • Third parties with whom we have joint marketing and similar arrangements.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
  • Third parties who deliver our communications, such as the postal service and couriers.
  • Other third parties as necessary to complete transactions and provide our products/services, including delivery companies, agents, and manufacturers.
  • Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Third party network advertising partners.
  • Third parties who assist with our information technology and security programs.
  • Third parties who assist with fraud prevention, detection, and mitigation.
  • Consumer reporting agencies.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Health Insurance Information – including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Determine program, product, and service eligibility.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
  • Third-parties that help administer, manage and analyze our programs and services
Financial information – including bank account number, credit or debit card number, or other financial information.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Payment processors and other financial institutions.
  • Third parties who assist with fraud prevention, detection, and mitigation.
  • Determine program, product, and service eligibility and coverage.
  • Enroll you in our programs and provide our products and services to you.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Consumer reporting agencies.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Medical Information – including any information in possession of or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Determine program, product, and service eligibility and coverage.
  • Enroll you in our programs and provide our products and services to you.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Protected Characteristics – such as race, gender, physical or mental disability.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Third parties that provide access to information you make publicly available, such as social media platforms.
  • Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators.
  • Determine program, product, and service eligibility and coverage.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Conduct internal business analysis and market research.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties with whom we have joint marketing and similar arrangements.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Commercial Information – including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Consumer reporting agencies.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Other third parties who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners.
  • Enroll you in our programs and provide our products and services to you.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Communicate with you regarding our programs, products, and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Conduct internal business analysis and market research.
  • Engage in joint marketing initiatives.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties with whom we have joint marketing and similar arrangements.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Third party network advertising partners.
  • Consumer reporting agencies.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Network Activity Data – Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms.
  • Cookies, web beacons, and similar technologies (automatically) when you visit our websites or third-party websites.
  • Third party advertising partners and other third parties who provide digital marketing services.
  • Third parties who provide website and online security services.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Conduct internal business analysis and market research.
  • Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
  • Engage in joint marketing initiatives.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes.
  • Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Third party network advertising partners.
  • Third parties who assist with our information technology and security programs.
  • Third parties who assist with fraud prevention, detection, and mitigation.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Geolocation Data – an individual’s precise geolocation data.
  • Your mobile devices with your permission upon downloading and when you visit or interact with our websites, applications, and online platforms.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Conduct internal business analysis and market research.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Third parties who assist with our information technology and security programs.
  • Third parties who assist with fraud prevention, detection, and mitigation.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Electronic and Sensory Data – audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call).
  • You (directly from participant).
  • When you contact or visit us (automatically), such as when we record calls to our call centers.
  • Your mobile devices and other internet-connected devices with your permission when you use these devices and relevant applications,
  • Third parties that provide access to information you make publicly available, such as social media platforms.
  • Administer, manage, analyze, and improve our programs, products, and services.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
  • Third party network advertising partners.
  • Third parties who assist with our information technology and security programs.
  • Third parties who assist with fraud prevention, detection, and mitigation.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Written Signature – an individual’s written signature.
  • You (directly from participant).
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Enroll you in our programs and provide our products and services to you.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Engage in joint marketing initiatives.
  • Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
  • Comply with legal and regulatory obligations.
  • Healthcare providers (including specialty pharmacies).
  • Health insurance companies (health plans) and other payors.
  • Authorized/legal representatives, family members, and caregivers.
  • Third parties with whom we have joint marketing and similar arrangements.
  • Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our products and services.
  • Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
  • Other third parties as necessary to complete transactions and provide our products/services.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.
Inferences – drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predictions about an individual’s preferences or tendencies).
  • We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.
  • Analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
  • Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
  • Engage in joint marketing initiatives.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Comply with legal and regulatory obligations.
  • Third parties with whom we have joint marketing and similar arrangements.
  • Our lawyers, auditors, and consultants.
  • Legal and regulatory bodies and other third parties as required by law.

 

Your Rights

The CCPA may provide you (as a California resident) with specific rights, applicable to covered businesses and subject to certain exceptions.

  • The Right to Know.  You have the right under the CCPA to request that certain businesses disclose what personal information they collect, use, disclose, and sell.  The process for exercising this right (if applicable) is describe below under How to Submit a Data Privacy Request
  • The Right to Deletion.  You have the right under the CCPA to request deletion of any personal information about you that certain businesses have collected from you.  The process for exercising this right (if applicable) is describe below under How to Submit a Data Privacy Request  
  • The Right to Opt-Out.  You have the right under the CCPA to opt-out of the sale of your personal information by certain businesses.
  • The Right to Non-Discrimination.   You have the right under the CCPA not to be discriminated against for exercising your rights.

 

How to Submit a Data Privacy Request

You may exercise your Right to Know and Right to Deletion by emailing customer.service@kadmon.com. Upon receipt of such request, Kadmon will determine whether the collection, use, disclosure or sale of personal information in question is subject to the CCPA at that time. 

To process your request for access or deletion, we must be able to verify your identity to a reasonable degree of certainty.  In order to do so, you must provide the required information when completing the online request form or making a request through one of our customer service agents.  We will ask you to provide your contact information and an additional identifier based on your relationship with us.  Before we process your request, we will match these data point with data points we currently maintain to verify your identity and your relationship with us.

You can designate an authorized agent to make a request to access, delete, or opt-out of the sale of your information on your behalf.  When you use an authorized agent to submit a request for access or deletion, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us.  We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Right to Know

You may have the right to request that we disclose the following information:

  • Specific pieces of Personal Information Kadmon has collected about you;
  • Categories of Personal Information Kadmon has collected about you, disclosed about you for a business purpose, or sold;
  • Categories of sources from which the Personal Information is collected;
  • Categories of third parties with whom Kadmon shares or to whom Kadmon sells Personal Information; and
  • The business or commercial purpose for collecting and selling Personal Information.

To make such a request, please refer to the “Contact Us” information below.

Please note that we may not be required to provide you access to the specific pieces of information we have collected about you or delete information if we have not been able to verify your identity.

Right to Delete

We may not be required to delete information under certain circumstances.  Specifically, the CCPA includes exemptions that provide that we do not have to delete data that, for example, is necessary to complete a transaction, detect security incidents or for certain other internal purposes.

Sale or Disclosure of Personal Information

The CCPA defines “sale” very broadly to include sharing or disclosing of personal information with a third party for monetary or other valuable consideration.  Kadmon does not resell personal information as part of its business model, but occasionally shares data with third parties secondarily to a services arrangement, such as when the third party processes the data on behalf of Kadmon, but then may also keep the data to further use on its own behalf.

Personal Information Collected from Employees, Contractors, Applicants and Healthcare Providers

  • Employees – If you are a Kadmon employee and would like more information about the categories of personal information we collect from you and the purposes for which the personal information will be used, please contact us at customer.service@kadmon.com.
  • Contractors – If you are a contractor performing services for Kadmon and would like information about the categories of personal information we collect from you as a contractor and the purpose for which the personal information will be used, please contact us at customer.service@kadmon.com.
  • Job Applicants – If you are applying for a position with Kadmon and would like information about the categories of personal information Kadmon collects from you as a job applicant and the purposes for which the personal information, please contact us at customer.service@kadmon.com.
  • Healthcare Providers – If you are a healthcare provider with whom we have a contractual arrangement and would like information about the categories of personal information we collect from you and the purposes for which the personal information will be used, please contact us at customer.service@kadmon.com.

California residents who are unable to review or access this CCPA Notice due to a disability may contact us to request access this CCPA Notice in an alternative format. Please contact us at customer.service@kadmon.com.

 

Section 7:

Your Nevada Privacy Rights

 

Although Kadmon does not sell yourersonal Information, Nevada residents may have the right to opt-out of the any future sale of Personal Information we have collected or will collect. To make such a request, please email us at customer.service@kadmon.com.

 

SECTION 8:

CONTACT INFORMATION

 

Please submit questions, concerns, or requests to exercise your applicable rights to Kadmon by email or postal mail as follows:

Kadmon Holdings, Inc.
Attn: Customer Service
450 East 29th Street,16th Floor
New York, NY 10016
customer.service@kadmon.com
Effective Date: July 1, 2020

1-800-405-8506