This Privacy Policy explains how INNOMED VIETNAM handles personal information that we collect online, through our websites and applications (apps) and through our offline interactions with you (collectively, the “INNOMED VIETNAM”). This Privacy Policy does not apply to information collected from residents of countries other than Singapore, or to third-party websites to which INNOMED VIETNAM may link. Your use of INNOMED VIETNAM which link to this Privacy Policy are subject to this Privacy Policy and the Terms of Use.

On occasion, INNOMED VIETNAM may offer apps, special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.

PERSONAL INFORMATION

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Examples of personal information include your name, your postal address and your telephone number.

INNOMED VIETNAM  collects information in a few different ways?

INNOMED VIETNAM collects information in a few different ways:

• Information you submit or choose to provide
• Information you give us permission to collect from you or another source
• From Health Care Professionals
• Through our websites and mobile apps
• Through interactions with our customer service personnel
• From contract research organizations and clinical trial investigators
• From your participation in INNOMED VIETNAM programs, surveys or clinical trials
• From third party service providers, data brokers or business partners
• From industry and patient groups and associations
• Automatically from devices you use to connect to INNOMED VIETNAM  Enterprise Services (See “Cookies and Other Tools” below)
• Information provided by INNOMED VIETNAM  partners
• From public sources including, but not limited to, social media and other websites that enable social sharing
• Information from government agencies, public or third party information sources

From time to time, we may use or augment the personal information we have about you obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

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

INFORMATION INNOMED VIETNAM COLLECTS

INNOMED VIETNAM may collect the following information, depending on what product and service you use:

• Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
• Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
• Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
• Information regarding parents or legal guardians or other family members
• Any information you provide in connection with applying to or participating in a patient assistance or support program (such as financial need information)
• Payment-related information we need to complete a transaction (such as credit card number and financial account information)
• Username and password that you may select in connection with establishing an account on our websites or mobile apps
• Your photograph, social media handle or digital or electronic signature
• Publicly available information
• Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the INNOMED VIETNAM and our advertisements
• Device information
• Geolocation data, e.g., your physical location or movements (See “Cookies and Other Tools” below)
• Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
• If you are accessing INNOMED VIETNAM websites or apps on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide INNOMED VIETNAM with any information that is not specifically requested
• Any adverse event information
• CCTV recordings when you visit our premises or photo taking or video recording at events

Failure to provide such personal information may mean that we cannot provide you with the product or service you have requested.

IF YOU ARE A HEALTH CARE PROFESSIONAL, WE MAY ALSO COLLECT:

• Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
• Information about the INNOMED VIETNAM programs, products and activities with which you have engaged
• Details about our interactions with you, your prescribing of our products and the agreements you have executed with us; including remittance or other financial information
• Any information you choose to provide about yourself or your household
• Information collected in connection with INNOMED VIETNAM hosted events or activities you attend or participate in
• Publicly-available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use public information to confirm contact or financial information, to verify licensure of Health Care Professionals or to better understand your interests by associating demographic information with the information you have provided.

HOW DOES INNOMED VIETNAM USE PERSONAL INFORMATION?

How INNOMED VIETNAM  uses your information depends on how you interact with the INNOMED VIETNAM. Generally, We may, for example, also use your information to:

• Provide our products and services to you and make them better
• Develop new products and services
• Fulfill your requests
• Provide customer service
• Send you administrative communications regarding INNOMED VIETNAM products or INNOMED VIETNAM
• Notify you about special promotions or offers that may be of interest to you
• Invite you to participate in surveys about our products or services
• Better understand the interests of our customers and visitors who use INNOMED VIETNAM
• Maintain INNOMED VIETNAM online services such as websites and apps
• Monitor, detect and prevent fraud, improper activity and ensure INNOMED VIETNAM policy compliance
• Conduct research including secondary and follow-on research
• Determine an individual’s eligibility to participate in INNOMED VIETNAM programs or clinical trials
• Process payments
• Evaluate how you and other users interact with our online services
• Protect INNOMED VIETNAM and our users
• Secure our online services including our network, websites and apps
• Conduct audits related to our current interactions with you
• Debug the site and service to identify and repair errors that impair existing intended functionality
• Defend ourselves in litigation and investigations and to prosecute litigations
• Comply with our legal and regulatory obligations

In addition, some of our applications and mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.

We may use personal information collected from any of the sources listed in the “How Does INNOMED VIETNAM Collect Personal Information?” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our INNOMED VIETNAM, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

DOES INNOMED VIETNAM SHARE PERSONAL INFORMATION?

We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

Some Service Providers may collect personal data on behalf of INNOMED VIETNAM.  These third parties may be provided with access to personal data needed to perform their functions. In addition, INNOMED VIETNAM practice is to require its Service Providers to keep your personal information confidential and to use personal information only to perform functions for INNOMED VIETNAM.

If INNOMED VIETNAM sells all or part of one of its product lines or divisions, your information may be transferred to the buyer. INNOMED VIETNAM reserves the right to disclose your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

INNOMED VIETNAM may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, INNOMED VIETNAM or others, and to exercise, establish or defend INNOMED VIETNAM legal rights. INNOMED VIETNAM may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

COOKIES AND OTHER TOOLS

INNOMED VIETNAM and its Service Providers collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make your use of our INNOMED VIETNAM easier and more meaningful by allowing INNOMED VIETNAM and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our INNOMED VIETNAM. If we have collected your personal information, we may associate this personal data with information gathered through the Tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

You can also control Flash cookies which we may use on certain INNOMED VIETNAM websites and apps from time to time by clicking here. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device-specific.

Here are some of the types of information collected when visiting GINNOMED VIETNAM Websites:

LOG DATA: When you use INNOMED VIETNAM websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit an website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had INNOMED VIETNAM features, browser type and settings, the date and time of your request, how you used websites and cookie data.

COOKIE DATA: Depending on how you are accessing INNOMED VIETNAM online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your INNOMED VIETNAM account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your INNOMED VIETNAM account (including personal information about you, such as the email address you gave us), and other cookies are not.

We may use tools such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the INNOMED VIETNAM and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

SOCIAL MEDIA PLUGINS AND DATA: In addition, our websites and apps may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online INNOMED VIETNAM, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our INNOMED VIETNAM, the social plugins allow that social media website to receive information that you have visited our Gromark Consumer Enterprise Services. The social plugins also allow the social media website to share information about your activities on Gromark Consumer Enterprise with other users of their social media website.

INNOMED VIETNAM does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

If you choose to link your social media or Google account to INNOMED VIETNAM this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access. You agree that we are not responsible for any acts or omissions by these social media service providers. If you give us permission to access this information, we will use it for the purposes described in this Privacy Policy.

DEVICE INFORMATION: In addition to log data, we may also collect information about the device you are using to access our INNOMED VIETNAM, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

INTEREST BASED ADVERTISING: INNOMED VIETNAMhopes to deliver to you advertising for products and services you need or want. INNOMED VIETNAM, its vendors and partners, use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, Gromark Consumer Enterprise may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits INNOMED VIETNAM websites and apps. This enables the network advertising company to recognize individuals who have previously visited INNOMED VIETNAM websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”).

These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

RETARGETING: One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look at Similac® products on an Gromark Consumer Enterprise website, you may later see an advertisement for Similac® products when you visit third-party sites. To do this, Gromark Consumer Enterprise or its advertising vendors may use a device ID, cookie, pixel, web beacon or similar technology placed by Gromark Consumer Enterprise or our third-party vendor when you visit Gromark Consumer Enterprise websites or apps or third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our vendors and other websites that you visit to understand how they collect and use your data.

OPTING-OUT OF IBA, OBA AND RETARGETING ACTIVITIES: As a participant of the Digital Advertising Alliance (DAA), we adhere to DAA’s Interest-Based Advertising principles by providing you enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles/. Click here to opt-out of having your online behavior collected for advertising purposes and receiving behaviorally targeted advertisements from our advertising partners. Choices you make are both browser and device-specific. Also, certain versions of the iOS operating system permit you to “Limit Ad Tracking” in the system settings, and certain versions of the Android operating system allow you to “Opt-out of Interest-Based Ads” in the system settings. Options you select are browser and device specific.

GROMARK CONSUMER ENTERPRISE DO NOT TRACK POLICY: Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. Gromark Consumer Enterprisehonors the AdChoice DNT signals. Options you select are browser and device specific. Please be aware that limiting the ability of websites to set cookies, however, may worsen your overall user experience, and in some cases the sites will not work properly without cookies, local storage and similar technologies.