Mallinckrodt Privacy Policy

Introduction

The privacy and protection of personal information is of importance to Mallinckrodt Pharmaceuticals. This Privacy Policy (Policy) describes how Mallinckrodt and its affiliates and brands collect, use, and share personal information.

If you are a Healthcare Professional (“HCP”), for additional information about how we collect, use, and share your personal information, please click here.

You can jump to particular topics by going to the links below:

Contents

• Contact Information

• Types of Data We Collect

• Sharing of Personal Information

• How We Protect Personal Information

• Cookies and Other Web Devices

• Your EU Privacy Rights

• California Consumer Privacy Act Rights

• Other Important Information

• California Information Sharing Disclosure

Contact Information

The primary data controller is Mallinckrodt Pharmaceuticals Ireland Limited, with registered offices at College Business & Technology Park, Cruiserath, Blanchardstown, Dublin 15, Ireland.

If you have any questions, comments, or complaints concerning our data privacy or data protection practices, please contact us at privacy@mnk.com or call us at 800-822-2075. 

Types of Data We Collect

Personal Information means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person.

The following provides examples of the types of data that we collect from you and how we use the information.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

Sharing Of Personal Information

In addition to the specific situations discussed elsewhere in this Policy, we may disclose personal information in close relation to the purposes specified above to trusted third parties, collectively referred to as “Recipients.”

• Affiliates and Acquisitions. We may share your personal information with our corporate affiliates (i.e., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  If another company acquires our company, one of our businesses, or our assets, we will also share your personal information with that company as necessary, including at the negotiation stage.
• Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.
• Other Disclosures without Your Consent. We will disclose personal information when required in response to subpoenas, warrants, or court orders, in connection with any legal or regulatory process, or to comply with relevant laws.  We will also share your personal information as necessary in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, for audit purposes, or a violation of our policies.
• Service Providers. We will share your personal information with service providers that are committed to/or under appropriate statutory obligations of confidentiality such as website hosting; email services; marketing; clinical research organizations (CROs); clinical trial administration, advertising, auditing; payment processing; fulfilling customer orders; data analytics; providing customer support; conducting customer research and satisfaction surveys; managing events; accepting grant applications;  cloud storage services; and other services that assist in providing or selling our products and services. These service providers may collect, store, analyze, or otherwise process information on our behalf.

How We Protect Personal Information

No method of transmission over the internet, or method of electronic storage, is fully secure. While Mallinckrodt implements appropriate technical and organizational security measures to protect your personal information from unauthorized access, use, or disclosure, due to the public nature of the internet, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we will notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Cookies and Other Web Devices

Each website can send its own cookie to your web browser if your browser's preferences allow it. Cookie settings can be controlled in your internet browser to automatically reject some forms of cookies. If you do not allow cookies, some features and functionality of our site may not operate as expected.

Mallinckrodt may use Adobe Flash technology (including Flash Local Stored Objects "Flash LSOs") that allow Mallinckrodt to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Site, and collect and store information about your use of the Site. Some of our websites or emails also use pixel tags, web beacons, clear GIFs, or other similar technologies to measure the success of marketing campaigns, and compile statistics about usage and response rates, and other purposes.

Mallinckrodt may use other web devices to track website usage and views.  If you have questions or concerns about our cookie or web device usage, please contact us at privacy@mnk.com or call 800-822-2075.

Your EU Privacy Rights

Pursuant to EU General Data Protection Regulation (GDPR), below is additional specific information which relates to the processing of personal information of Data Subjects who are in the EU. Mallinckrodt has put in place a data protection governance structure to ensure the data privacy rights and freedoms of Data Subjects are protected.

• Transfers to Other Countries. Some of the personal information we collect may be transferred to Recipients who are established in other countries, such as the United States. Transfers of EU personal data are based on an adequacy decision, standard contractual clauses, or your consent.
• Retention. We retain personal information for as long as reasonably deemed required for legal or business purposes. During these periods, we take all appropriate steps to ensure that the privacy of your personal data is maintained. For further details, please contact privacy@mnk.com or call 800-822-2075.
• Data Subject Rights. For Data Subjects in the EU, pursuant to and to the extent allowed by applicable law, you have the following rights:
  • The right to be informed about our collection and use of your personal data.
  • The right to access the personal data we hold about you.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  • The right to be forgotten (erasure), i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
  • The right to restrict (i.e., prevent) the processing of your personal data.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
• Compliance. You have the right to lodge a complaint with the Data Protection Authority in your country, including the Data Protection Commission, regarding the processing of your personal information in the EU.  Contact details are available at https://www.dataprotection.ie/en/contact/how-contact-us or https://edpb.europa.eu/about-edpb/board/members_en.

California Consumer Privacy Act Rights

Subject to legal limitations, if you are a resident of California, you may have the right to make the following choices regarding your personal information:

• Access to Your Personal Information. You may request access to your personal information by contacting us as described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.  You may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. 
• Changes to Your Personal Information. You may have a right to modify your personal information. You may contact us as described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law. 
• Deletion of Your Personal Information.  You may request that we delete your personal information by contacting us as described below.  If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. 
• Objection to Certain Processing.  You may object to our use or disclosure of your personal information by contacting us as described below. 
• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send communications and promotional materials to you.  You can stop receiving most emails by following the unsubscribe instructions in emails that you receive.  If you decide not to receive these emails, we may still send you service related communications.
• Revocation of Consent.  If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by telephone call or email. Depending on your request, we will ask for information such as your name, your physical address, or the name of our clinical trial in which you participated. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

Requests to exercise your rights must be sent to privacy@mnk.com or made via telephone by calling 800-822-2075.

Other Important Information

The following additional information relates to our privacy practices:

• Minors. Our websites are not for individuals under age 13. Those individuals should not access a website or provide personal information to us.
• Third-Party Applications/Websites.  We have no control over the privacy practices of websites or applications that we do not own.
• Changes to This Policy.  We may change our Policy and practices over time.  To the extent that our Policy changes in a material way, the version of the Policy that was in place at the time that you submitted personal information to us will generally govern that information.  Our Privacy Policy includes an “effective date” and a “last updated” date. The “effective date” refers to the date that the current version took effect. The “last updated” date refers to the date that the current version was last substantively modified. 
• Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
• Information for California Residents.  California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  You can find a list of the categories of information that we collect and share below. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to privacy@mnk.com or call 800-822-2075.  We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Last Updated: July 2020

Effective: January 2018

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts.  Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.  For example, while we transfer credit card or debit card numbers for our business purposes in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.