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PRIVACY POLICY

Effective Date: March 2, 2020

Welcome to the SECUADO® brand website.

The owner of the SECUADO® brand website (the “Site”), Noven Therapeutics, LLC (“Noven”, “we”, “us” or “our”), is hosting the Site on behalf of Hisamitsu Pharmaceutical Co., Inc.

Your access to and use of our Site is subject to the following privacy policy (the “Privacy Policy”), and all applicable laws.

The Privacy Policy is designed to tell you about our practices regarding collection, management, use, and disclosure of information that you may voluntarily provide to us, including through the Site or through an electronic or mobile device such as a cellphone or tablet (collectively, “mobile device”). Please be sure to read this entire Privacy Policy before using or submitting information to the Site or through a mobile device. Although the information on the Site may be accessible to users outside of the U.S., the products and product information are intended only for residents of the U.S. and its territories, and who are over the age of 18. Personal information provided through mail, email, phone call, text message, social media, or otherwise (other than through a Noven website) is also protected under this Privacy Policy.

Your Consent
By using the Site, you agree to the terms of this Privacy Policy and the Terms of Use. Whenever you submit information to us, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Site and please do not submit any personal information to us through a mobile device or otherwise.

Information You Provide
Some areas of the Site may ask you to submit personally identifiable information, treatment information, or demographic information so you can benefit from the specified features (such as newsletter subscriptions or other informative resources, including about Noven products) or to participate in a specific marketing activity (such as promotions, including coupons). For example, you may need to provide your full name, mailing address, email address, phone number, and/or information about your organization to request product samples. You may also need to provide your name, mailing address, email address, phone number, and insurance information to participate in one of our patient support programs. In such an instance, you will be informed about what information is required and what information is optional at the point of collection.

Passive Information Collection
As you navigate through the Site, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the Site some of this information, such as the URL of the website you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using. If using a mobile device, we may collect information about your mobile device, such as the unique device identifier. The Site may use and combine such passively collected anonymous information to provide better service to Site visitors, customize the Site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the Site for your use.

A “cookie” is a bit of information that a website sends to your web browser that helps the Site remember information about you and your preferences. If you desire, you can use your browser settings to set your preferences regarding cookies. If you set your browser to refuse cookies altogether, certain features of this Site might not work without cookies. To learn more about cookies and how to specify your preferences, please search for “cookie” in the “Help” portion of your browser and see the “Your Choices” section below. So that we may better customize our service to you, from time to time, we may contract with third parties to place cookies on your computer. Additionally, some third party companies, such as owners of the website links we may provide for your convenience, may use cookies to track your activities once you leave Noven’s website. Noven is not responsible for the policies of any third party sites.

An Internet Protocol (IP) address is a number assigned to your computer by your Internet service provider so you can access the Internet. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the Site and on different pages of the Site. Such tags indicate how many times a page is opened and which information is consulted.

“Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the Site, market research purposes, and to communicate information to visitors.

Use of Information
Except as otherwise stated, we may use information collected to provide products and services to you, to respond to your requests or questions, to improve the content of our Site, to customize the Site to your preferences, to communicate information to you, for our marketing and research purposes, and for any other purpose specified in this Privacy Policy. We use information for security purposes, including to protect our company and our Site. In addition, we may make full use of all aggregated or deidentified information acquired through the Site. If you provide information to the Site, we may combine such information with other actively collected information unless we specify otherwise at the point of collection.

We also use information as otherwise permitted by law or as we may notify you.

Disclosure of Information
We may disclose information you provide via the Site, through a mobile device, or otherwise to other Noven affiliates worldwide that agree to treat it in accordance with this Privacy Policy and use it for the same purposes. We also may disclose personally identifiable information you provide via the Site to third parties that are not Noven affiliates, but only:

  1. to contractors and service providers that Noven uses to support our business (such as fulfillment services, technical support, and delivery services), in which case we will require such third parties to agree to treat it consistent with this Privacy Policy and use it only for the same purposes;
  2. in connection with the sale, assignment, or other transfer of the business of the Site to which the information relates;
  3. to respond to law enforcement, government, or investigatory body requests or where required by applicable laws, court orders, or government regulations;
  4. to comply with legal requirements, to protect ourselves, or to establish or exercise our legal rights to defend against legal claims; or
  5. when we believe it is necessary to share information to assist in an investigation regarding, or to prevent, illegal activities, suspected fraud, or potential threats to the safety of any person.

We may also share information for other reasons we may describe to you.

Your Choices

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.

You can control cookies and tracking tools. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

Options you select are browser and device specific.

Access and Correction
To keep your personally identifiable information that you provide to the Site accurate, current, and complete, please contact us as explained below and we will take reasonable steps to update or correct such information in our possession, or to delete your information from our contact list. In some cases, however, where we are required to retain information by law or regulation, or to continue to manage a service you have requested, or to ensure that we honor your preferences, or for other necessary business purposes, we may not be able to delete certain personal information about you.

This Site and Children
This Site is meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can contact us using the contact information below. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

Security
Noven takes reasonable steps to protect personally identifiable information as you transmit it to our Site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Noven does not guarantee that your personal and other information will be secure from theft, loss or unauthorized access or use, and Noven makes no representation as to the reasonableness, efficacy or appropriateness of measures we use to safeguard such information. You should know and consider that no internet or mobile device transmission, including text messages, is ever completely secure or error-free. In particular, email sent to or from this site may not be secure. You are also responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you have with us has been compromised), please immediately notify us by contacting us at privacypolicy@noven.com.

Links to Other Websites
The Site may contain links or references to other websites to which this Privacy Policy does not apply, including links to third-party websites, content and/or services that are not owned or controlled by Noven. We encourage you to read the Privacy Policy of every website you visit.

Transfer of Data to Other Countries
This site is subject to U.S. laws. Any information you provide to Noven through use of the Site may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. Noven will, however, handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

How Long We Retain Personal Information
We generally retain personal information for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.

How to Contact Us or Opt Out
If you decide you no longer wish to receive communications from us, you may opt out at any time by emailing privacypolicy@noven.com or using the contact information below. If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, please contact us as follows:

privacypolicy@noven.com or

Noven Therapeutics, LLC. Attn: Privacy Policy
11960 SW 144th Street Miami, FL 33186

Changes to This Privacy Policy
Noven reserves the right to modify, add or remove portions of this Privacy Policy at its discretion and without prior notification, and may from time to time do so. We will notify you of any material changes to our Policy as required by law, and any changes to this Privacy Policy will be posted on the Site. Minor changes to this Privacy Policy may occur that will not significantly affect our use of personal information without notice or consent. Please check back periodically, and especially before you provide any personally identifiable information.

Revised as of 02/2020

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