Privacy Policy

[FULL LEGAL NAME OF ENTITY] cares about your privacy and wants you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we or our service providers collect through the website or application (hereinafter the “Service”) operated and controlled by us from which you are accessing this Privacy Policy.  By providing personal information to us or by using the Service, you acknowledge that you have read and understand this Privacy Policy.

USE BY MINORS

The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under Contacting Us.

INFORMATION COLLECTION

We may ask you to submit personal information in order for you to benefit from certain features or to participate in a particular activity. You will be informed what information is required and what information is optional.

We may combine the information you submit with other information we have collected from you, whether on‑ or offline.

If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SENSITIVE INFORMATION

Applicable to patients using the Service: Concerning sensitive personal data (e.g. health condition, symptoms) we will ask you for your explicit consent at the time you decide to join the Program. We will ask you as well for your consent for us to be able to share your health information with your treating physician/nurse. If you do not want us to collect that information from you or do not want us to share that information with your  treating physician/nurse, you will not be able to participate in the Program. The process of collecting sensitive data of patients using the Service has been regulated in detail in the declaration of consent and the privacy notice attached to it.

With the exception of the above stated we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health or medical conditions, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data) on or through the Service or otherwise to us.

AUTOMATIC INFORMATION COLLECTION AND USE

We and our service providers may collect certain information automatically as you navigate around the Service.  Please read the Cookie Policy [insert link to the website’s cookie policy] for detailed information about the cookies and other tracking technologies used on the Service.  Except where allowed by applicable law, we place cookies after having received your consent through the cookie banner or preference center. The Cookie Policy includes information on how you may disable these technologies.

We and our service providers may also automatically collect and use information in the following ways:

  • Through your browser:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device.  We use this information to ensure that the Service functions properly.
  • IP address:  Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider.  An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited.  Collecting IP addresses is standard practice and is done automatically by many online services.  We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service.  We may also derive your approximate location from your IP address.
  • Device Information:  We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

HOW WE USE AND DISCLOSE INFORMATION

We use and disclose information you provide to us as described to you at the point of collection.  Please see the section entitled “Choices and Access,” below, to learn how you may opt out of certain of our uses and disclosures.

Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection.  We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, due to our pharmacovigilance obligations), or for our legitimate business interests.  We may also rely on other legal bases, specifically for:

  • Providing the functionality of the Service and fulfilling your requests.
    • to provide the functionality of the Service to you and providing you with related customer service;
    • to respond to your inquiries and fulfill your requests, such as to send you documents you request or e‑mail alerts;
    • to send you important information regarding our relationship with you or regarding the Service, changes to our terms, conditions, and policies and/or other administrative information.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.


  • Accomplishing our business purposes.
    • for data analysis, for example, to improve the efficiency of the Service;
    • for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
    • for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
    • for developing new products and services;
    • for enhancing, improving or modifying our website or products and services;
    • for identifying Service usage trends, for example, understanding which parts of our Service are of most interest to users; and
    • for determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.


We also disclose information collected through the Service:

  • to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e‑mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
  • as permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
  • Applicable to patients using the Service: to your treating physician/nurse, which we do on the basis of your consent given at the point of data collection;

In addition, we may use and disclose your information as we believe to be necessary or appropriate: (a) to comply with legal process or applicable law, which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.  We may also use and disclose your information in other ways after obtaining your consent to do so.

We may use and disclose information we collect automatically as described above, under “Automatic Information Collection and Use.”

In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose.  If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

CHOICES AND ACCESS

If you no longer want to receive reminders from us on a going‑forward basis with regards to medical reminders or optimal solution functioning messages, you may opt out of receiving them by changing the profile settings of the Service.

We will seek to comply with your request(s) as soon as reasonably practicable. Please also note that if you opt out of receiving medical reminders or optimal solution functioning messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.

How you can access, change, or delete your personal information

If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us via [include your mechanism here, e.g., send an e‑mail with your request to [insert e‑mail address]. We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. You may also visit the Service to update your online profile.

CROSS‑BORDER TRANSFER

Personal Information will not be transferred to countries outside of the EU/European Economic Area.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. 

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

RETENTION PERIOD

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained.  The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

THIRD PARTY SITES AND SERVICES

This Service may contain links to sites of third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Service or to which this Service contains a link.  The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates.

CONTACTING US

[Full legal name of entity], located at [Full address], is the company responsible for collection, use, and disclosure of personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us via [include your mechanism here, e.g., e‑mail at [e-mail address], or please write to the following address:
[Address]

You may also contact our data protection officer responsible for your country or region, if applicable, at emeaprivacy@its.jnj.com.

Additionally you may contact …… who is responsible for the maintaining of the Service:
……………..

……….. will be considered as the single point of contact for the users of the Service concerning any relevant request in respect of operational functioning of the Service, privacy rights, or in respect to any issue arising from this Privacy Policy.

LODGING A COMPLAINT WITH A REGULATOR

You may lodge a complaint with a supervisory authority competent for your country or region. Please click here for contact information for such authorities.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Service.  Your use of the Service following these changes means that you accept the revised Privacy Policy.  We recommend that you regularly review the Privacy Policy when you visit the Service. This policy was last updated on [date on which the privacy policy page is updated on production].