Privacy Statement

When we say “Gilead” “we” or “us” we refer to Gilead Sciences, Inc. and its subsidiaries and successors, including Kite Pharma Inc. ("Gilead", "we", or "us"). When we process your personal information, Gilead Sciences Limited is the data controller of your personal information. The contact details for Gilead Sciences Limited can be found here: Contact us.

We will review this HCP Privacy Notice from time to time and may change or update it at any time.

The categories of personal information that we collect, and use may include:

• Identification information, including your full name, date of birth, tax number and other government identification numbers.
• Contact information, including your e-mail addresses, telephone numbers, mailing addresses and social media profile.
• Profile information, including your title, education, languages spoken, country of residence, department, company, or organization that you work for or that you collaborate with, age and gender, communication preferences, use of both Gilead and non-Gilead products and related information and the customer segment that you have been attributed to.
• Professional information and experience, including professional role, professional credentials and history, medical specialty, license information, work experience, membership of associations and boards, medical and scientific opinions given, and publications drafted.
• Financial information, including details related to your compensation and transfers of value from us (or those acting on our behalf) to you or the organization that you work for.
• Due diligence related information, including disciplinary history, prior litigation, regulatory proceedings, and circumstances which may create a conflict of interest.
• Interaction and communication information, including information in and about e-mails, messages, telephone calls, responses to surveys that you participate in, meetings and other activities, your use of our digital channels and services, and any comments you may make about us, our business and therapeutic areas we specialize in on public domains (such as social media sites).
• Project and Event information, including information on type of projects and events you participate in, such as date(s), location(s) and topics.
• Picture, video, and audio material, which includes video footage of you, your picture or voice, photographs and video and audio recordings in connection with webinars or virtual meetings in which you participate, whether or not sponsored by Gilead.
• Travel-related information, including your national ID number, passport number, driver’s license number, tax identification number and travel preferences.
• Technical information derived from tracking technologies, including information about the device you use to access our websites, apps and systems, information about how you use our websites and digital content (such as downloads, pages visited, access time), device location, IP address and other online type of identifiers, as well as pixels used to track your engagement with emails. For more information about our use of cookies and other tracking technologies please read our Cookie Statement.

We collect personal information from:

• You, when you interact with our staff, enter into a collaboration agreement with Gilead, register to receive marketing material and/or other information from us, attend our online and in-person meetings and events, use our websites, apps and systems, share adverse events and medical information, participate in our surveys, share or use your social media profile to contact us, or request support and information. It is your choice whether you provide personal information when we ask you for it. If you decide not to give us your personal information, it may restrict our relationship with you, as we may not be able to completely deliver the services that you require or perform our contractual obligations.
• The organization that you work for, for example from your organization’s website or other communications material.
• Event and travel management agencies, for example in the context of your participation at conferences and symposia that we arrange or sponsor.
• Publicly available sources, for example websites, official registers, directories of HCPs, and professional and other social media platforms (including by social media listening tools, used to monitor what HCPs publish about us, our business, products, and therapeutic areas we specialize in).
• Your patients, where they have told us you are their HCP.
• Third Parties, such as data companies who provide information services in the healthcare sector to companies like ours and/or which maintain databases with HCPs’ personal information, including relating to clinical trials you participated in, publications you made, or congresses you attended.
• Our Affiliates that have previously collected your personal information and share your personal information with us.

We may combine and use your personal information, collected from different sources, in different ways depending on your interactions with us. Examples of how we use your personal information include:

Learning more about you

Like all pharmaceutical companies, it is important that we have an understanding of the professional profile of HCPs operating in our areas of research interest. In this respect, we may process your personal information in order to learn more about you and in particular to:

• Maintain a database to identify and engage with you based on your professional expertise and opinions, and our interactions.
• Assess your suitability for our projects based on your areas of expertise and by carrying out background checks to ensure we are not precluded from working with you.
• Review your usage of our websites and/or apps and analyze the previous website you visited, the links you clicked, pages you visited and other usage and browsing activity to understand your interests and preferences to improve our relationship with you by personalizing your experience and to inform our communications with you
• Review your attendance at events we organize or sponsor, to understand your interest in particular areas of research or clinical practice and to use this information to inform our communications with you.
• Analyze how you engage with communications we send to you (e.g., through the use of email pixels or other similar technology to determine if communications are opened) so that we can measure and improve the effectiveness of our marketing and other campaigns and to inform our future communications with you.
• Understand public perception of our products by analyzing statements, including information published by you about us, our products, business and therapeutic areas we specialize in on external sources such as social media platforms.

Providing you with financial support

If we provide financial support to you to attend meetings or if we look to engage you to provide services to us, we may use your personal information to:

• Determine your suitability to receive our support or to provide services, including your expertise and other background checks to ensure we are not precluded from working with you.
• Pay you for services you have provided and reimburse you for expenses related to those services or, where agreed in advance, in relation to attending Gilead or third-party meetings.
• Manage and assess applications by your organization or by you for grants, fellowship or travel support, including eligibility to receive support and considering potential conflicts of interest.

Engaging with you

We pro-actively communicate with HCPs to talk about research opportunities, for product marketing, and to promote events. You may also choose to get in touch with us for various reasons. Specific purposes for which we may use your personal information to:

• Send you product information, tell you about related services, and provide you with administrative information (e.g., sending email with event details where you have registered to attend).
• Arrange meetings, seminars, medical education events and similar activities.
• Interact with you through online digital advisory forums.
• Ask you to complete a survey to give feedback, which we use to make improvements to our products and services.
• Respond to and handling your questions or requests.

Carrying out research

We work with HCPs as investigators and research partners in the context of our clinical and scientific research activities. We may use your personal information to:

• Recruit you as an investigator for a research study.
• Conduct clinical trials and other research studies.
• Undertake market research to obtain insight about a disease area in which Gilead is interested, in order to improve our understanding of the pharmaceutical industry, and to develop and tailor our business and services. Your responses to market research questions may be analyzed on an aggregated or individual level.

Other general business purposes

In addition to the activities above, we may need to use your personal information for general business purposes, including to:

• Plan for and implement business restructuring.
• Complete management reporting, analytics and metrics.
• Conducting training and ensuring quality control.
• Analyzing or predicting your preferences to identify general trends to develop, improve or modify our products, services and business activities
• Process orders for cell therapy products.

Legal compliance and claims

• Monitoring the safety of our products including those related to adverse events, product complaints and safety.
• Defending and exercising legal claims and rights.
• Detecting, preventing, and investigating misconduct.
• Responding to requests from competent public authorities such as data protection authorities and other regulators.
• Fulfilling other legal obligations and regulatory requirements.

Transparency reporting

• For transparency reporting regarding the amount of direct and indirect payments, whether in cash, in kind or otherwise, made to HCPs or for their benefit, we use your personal information: (i) to comply with national laws; ii) for our legitimate interests; or (iii) with your consent

Where required by applicable law, we rely on one or more of the following legal grounds to process your personal information:

Performance of a contract

We may collect and use your personal information to:

• take steps to enter into a contract with you (such as collecting your name, contact details and area of specialism, providing you with financial support, and carrying out research activities under a contract with you), and
• perform our obligations under a contract with you (such as making payments to you).

In accordance with the scope of the contract, we may also use images, audio material and video recordings of you, for example in connection with webinars or digital meetings that we arrange.

Legitimate interest

We may use your personal information where necessary for our legitimate interests, including:

• Sending direct marketing materials to you, where we are not required to rely on your consent (we provide a way to opt out of marketing communications).
• Planning and improving our business activities (e.g., conducting mergers and acquisitions and planning company strategy).
• Conducting training and gathering feedback for ensuring quality control.
• Verifying your eligibility to access certain products, services and data that may be provided only to licensed HCPs or otherwise conducting background checks to ensure we are not precluded from working with you.
• Analyzing your interactions with Gilead (e.g., your participation in Gilead events, your interaction with Gilead websites, emails and telephone marketing and your professional activities) in order to tailor our communications with you according to your perceived preferences and interests. For more information see ‘Profiling’ below.
• Analyzing your contributions to HCP market research in order to develop, improve or modify our products, services and business activities.
• Interacting with you through online digital advisory forums.
• Responding to and handling your queries or requests.
• Maintaining a database to identify and engage with you based on your professional expertise and opinions, and where applicable, our interactions.
• Contacting you to request input on surveys relating to our products or services.
• Supplying cell therapy products for your patients. 

Consent

Depending on the jurisdiction, we may need your consent to use your personal information, and we will obtain your consent where required by law, for example where you share sensitive information about yourself (such as dietary requirements or health information) and when we send you direct e-marketing communications and promotional material. We may also need to rely on consent to collect information through tracking technologies, such as cookies, on our websites.

Compliance with law or regulations 

We may use your personal information as necessary to comply with applicable law/regulations (such as responding to adverse events, anti-corruption, transparency reporting, money laundering, accounting, financial and data retention obligations).

To protect the vital interests of you or another person

This covers the use of your personal information in emergency situations.

If you wish to know more about our use of your personal information, its purposes and the legal grounds on which they are based, please contact us by e-mailing [email protected]

We collect information from our own interactions with HCPs, as well as from third parties (such as publicly available and commercial HCP databases, publications in scientific media and / or on social media accounts and from third party organizers of Gilead sponsored events), and combine such information in order to understand areas of professional interest (including interest in Gilead products, our business and therapeutic areas we specialize in ) and the communication preferences of the HCPs we work with (or are interested in working with). We use this information in order to make automated recommendations to our sales teams regarding the most effective and relevant ways to engage with HCPs.

We share your personal information with different recipients:

• Affiliates, within the Gilead group of companies, for example to manage the customer relationship and to arrange meetings, seminars, events and similar activities.
• The organization that you work for, for example to manage our customer relationship with you and with your employer.
• Service providers, to assist and support us to provide services and assistance to you (such as meeting and events coordinators marketing agencies, web hosting and storage service providers)
• Individuals that participate in the same activity as you, for example in connection with events that you participate in.
• The public, when we report value transfers in connection with transparency reporting.
• Other recipients, including public authorities, government bodies and regulators, professional advisors, such as auditors and accountants, lawyers, and insurance companies for legal purposes, for example to manage, defend or exercise legal claims and rights in connection with a court dispute.
• In the event of any reorganization, merger, sale, or transfer of any portion of our business, your personal information may be transferred to the parties involved in accordance with applicable law.

We retain your personal information for no longer than is necessary for the purposes for which it has been collected and in accordance with any specific retention periods required by law. Our retention periods are based on the nature of our relationship with you, legal or regulatory requirements and business needs.

We take appropriate measures to protect personal information that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use safeguards to protect the confidentiality and security of personal information.

Due to the global nature of Gilead’s operations, your personal information may be disclosed throughout the Gilead affiliates, and/or to Gilead service providers, to fulfil the purposes described in this HCP Privacy Notice.

This may include transfer to and storage of personal information in countries other than where you are based, for the purposes and in the manner described in this HCP Privacy Notice, including to servers and other storage facilities in the United States, where Gilead is headquartered. To the extent that personal information is sent outside of your country, it is subject to the laws of the country in which it is, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country, which may not provide an equivalent level of protection to the laws of your home country.

Gilead implements safeguards to protect personal information, such as entering into standard data protection clauses, to protect and maintain the security and confidentiality of your personal information. To find out more about these safeguards please contact us by e-mailing [email protected].

We will take steps in accordance with applicable laws to keep your personal information accurate, complete and up to date. Below we describe some of the rights that you may have, depending on your location or where you are a resident. These rights are subject to certain exceptions depending on local law. If you wish to exercise your rights or would like more information about these or other rights, please contact us by e-mailing [email protected]

You may have the right to:

• Request information about how we use your personal information and to be provided with copies of your personal information that is held by Gilead.
• Withdraw your consent, if you have given consent for the processing of your personal information, including for purposes of direct marketing.
• Ask us to correct your personal information that you believe is inaccurate or incomplete.
• Request that we restrict how we use your personal information.
• Object to our use of your personal information, including profiling.
• Request that we delete your personal information in certain circumstances.
• Ask us to move your personal information to you or another organization.
• Lodge a complaint with a local data protection authority.

If you have any questions in relation to our use of your personal information, please contact us by emailing [email protected].

Gilead also has an appointed European Data Protection Officer, whom you can contact by emailing [email protected].

You can also find information about how Gilead processes personal information here: General Privacy Statement. The Gilead General Privacy Statement also includes a number of supplements where you can find additional information relating to your region, country or state, when applicable.

Except as otherwise noted below, this Privacy Statement applies to the personal information that Gilead processes related to:

• our Services, including our clinical research and patient support programs, and other healthcare and patient programs we administer, sponsor, or operate
• healthcare professionals
• individuals who register for or participate in our webinars and other events
• individuals who are subscribed to receive news, information, and marketing communications from us
• individuals who participate in contests, sweepstakes, surveys, and research conducted by us
• individuals that otherwise communicate, engage, or interact with us related to our business or our Services

This Privacy Statement does not apply to the personal information that we collect and process about employees and personnel or job applicants and candidates, which is subject to separate privacy notices.

Additional notices. In some cases, additional or supplemental privacy notices may apply to certain personal information that we collect and process. Such notices are generally intended to supplement this Privacy Statement by providing additional information for certain personal information and business activities. For example, we may provide notices to individuals who participate in patient support and assistance programs sponsored by Gilead in order to provide additional or more specific information to participants about the processing of their personal information related to such programs. We may also provide specific notices and obtain specific consents from clinical trial participants. To the extent there is a conflict with this Privacy Statement, the additional or supplemental notice will control, where applicable, with respect to the personal information subject to such notice.

We collect personal information from various sources including:

• Directly from individuals who access or use our Services or communicate with us about our business or our Services, including, for example:
• Participants in clinical trials and patient assistance programs that we sponsor
• Others acting on behalf of patients and other individuals, such as authorized representatives and legal guardians
• Users of our websites and mobile applications
• Individuals that communicate with Gilead
• Individuals that report or otherwise communicate quality, safety, or adverse event-related information about our clinical products and treatments
• Through our Services
• From healthcare professionals
• From contract research organizations and clinical trial investigators
• From government agencies and/or public records
• From service providers, data brokers, or business partners
• From industry and patient groups and associations
• From publicly available sources, including information provided on websites, social media channels, public forums or platforms, and other third-party sources

The personal information that we collect and process varies depending upon our relationship and interactions with you. As further described below, we may collect personal information directly from individuals, as well as from third parties and via automated means, such as cookies, web beacons, pixels, and web server logs related to the use of our Services or an individual’s interactions with Gilead.

You may choose not to give us personal information when we ask for it. However, if you decide not to provide certain personal information, it may restrict our relationship with you. For example, we may not be able to provide you with the Services you have requested.

Personal information provided to Gilead. We may collect and process personal information that you provide to us, as well as personal information about you that is provided on your behalf (such as by your authorized representative, legal guardian, healthcare provider, and others with whom you interact related to our Services). This information generally includes:

• Contact information and contact preferences for individuals and (as applicable) their authorized representatives (such as name, email address, mailing address, phone number, and emergency contact information)
• Information regarding your parents or legal guardians if you are a minor
• Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
• Health and medical information (such as information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, medications an individual may take, including the dosage, timing, and frequency, and information about an individual’s healthcare providers) 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
• Product safety, product quality, and the safety related information related to our clinical products and treatments (such as adverse incident reports). Gilead will record any personal information provided to or received by it related to product safety, quality, and other adverse events, including the name and contact details of the individual reporting the event (e.g., email and/or postal address, phone number), as well as the reporting individual’s profession/specialty (if a healthcare professional) and the health and other information provided in relation to such report or event. (For more information about safety and adverse incident reporting, go to https://www.gilead.co.uk/utility/contact.)
• Financial information and transaction data, including purchase history (such as billing, payment and other transactional information, income, eligibility information to determine eligibility for patient assistance programs, and information collected as part of our clinical trial investigator onboarding) and other financial and payment-related data (such as information that we are required to collect and maintain related to payments and financial interactions that we engage in with both businesses and individuals)
• Username and password that you may select in connection with establishing an account on our websites or mobile apps
• Records of your communications and other requests. For example, if you email, call, or otherwise communicate with us or with members of our team, we collect and maintain a record of your contact details, communications and our responses. When you fill out a form on one of our websites or sign up for news and updates from us, or otherwise request information from us, we collect and maintain records of your requests
• Registration information when you register for certain Services (such as if you participate in promotions or register for events or programs that we sponsor or administer)
• Photograph and social media handle
• Digital or electronic signature

Additional information about healthcare professionals. If you are a healthcare professional, we may also collect:

• Your professional credentials, educational and professional history, institutional and government affiliations, membership in associations and boards, and information included on a resume or curriculum vitae (such as work experience, education, and languages spoken)
• Information about the Gilead 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
• Information related to your practice, such as license information, disciplinary history, prior litigation, and regulatory proceedings, and other due diligence related information
• Information regarding circumstances which may create a conflict of interest
• Information provided to participate in our sponsored or supported initiatives, such as our sponsored clinical research and development activities, online or in-person seminars, educational events, and clinical information updates

Information collected from third parties. We may also collect personal information about individuals from other third-party sources, such as social media platforms and channels, forums and other third-party sites, and public databases, as well as from other third parties who support our business activities.

For example:

• If you post information about us or our Services or engage with us on third party platforms or social media, we may collect personal information about you from that third party platform or account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
• In some cases, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases and other third parties. For example, we may use such third-party information to confirm or verify licensure of healthcare professionals or to better understand your interests by associating demographic information with the information you have provided.
• If we become aware of information about us or our Services that relates to product or treatment quality or safety, or is otherwise reportable pursuant to our regulatory obligations, we will maintain records of such information in accordance with our regulatory and reporting obligations, including information that has been communicated on third party social media sites or otherwise shared by or with a third party.

Gilead may combine or aggregate the information we collect from third party sources with the information we may collect about you directly or otherwise.

Information we may collect via automated means or derive about you. We may also collect personal information related to your use of our Services and your interactions with us and others related to our Services, including information we derive about you and your use of our Services. Such information may include your device and browser information, activities and usage data about your use of our Services, and location information derived from your IP address or (with you permission) your mobile device.

For information about our collection of personal information via cookies and similar tracking technologies, and the choices you have regarding our use of cookies and related information collection, please see our Cookie Statement.

In general, Gilead collects and processes personal information for the following purposes:

• Providing Services and support. To provide and make available our Services, to communicate with you about your use of and interactions with our Services, to respond to your inquiries, to fulfill your orders and requests, to process your payments, and for other customer and patient support purposes. For example:
  • Where you have requested information regarding participation in a clinical trial with Gilead or one of Gilead’s partners
  • To support disease management, education, or decision support systems related to the use of our Services
  • Where you have requested a Service from Gilead, assisting you in the completion of your application, the assessment of your eligibility for any such requested Services, the processing and maintenance of the Services, as well as any applicable renewal of such Services
  • Making proposals for future Service needs
• Quality, safety and regulatory reporting. We may record and report on the health and other information that we collect associated with product safety or quality, and other adverse incident reports in compliance with our legal regulatory obligations. We may also contact you to seek additional information from individuals who report or communicate such product safety, quality, and other adverse incident information, in order to fulfill our legal and regulatory obligations. The information you provide Gilead is very important and will be used in the safety monitoring of our products for reporting and public health purposes. Please visit the Adverse Event Reporting page to learn more about our practices related to such information.
• Research and analytics. For purposes of conducting research and analytics to understand, improve, evaluate, and develop our Services and business processes and to develop other insights. For example, we may conduct primary and secondary research related to our clinical products and treatments and related Services, including by conducting clinical trials and to research and develop new products and treatments and other Services. We may administer surveys and questionnaires for market research or quality and satisfaction purposes. We also use personal information that we collect about your use of our Services to better understand how users access and use these Services and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop new Services and features, and for internal quality control and training purposes. We may also analyze public sources, such as websites and social media channels, for information related to or reported about us and our Services.
• Customization and personalization. To tailor content we may send or display on our Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
• Marketing and advertising. We use certain personal information for marketing and advertising purposes, in accordance with applicable law. For example, to send you information about our Services, such as offers, promotions, newsletters and other information we think may interest you, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
• Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, event feedback, and contacting you about relevant events and Services.
• Security and protection of rights. To protect our business and our Services; to prevent and detect fraud, unauthorized activities and access, and/or other misuse; and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our terms of services and other agreements with you.
• Compliance with law and legal process. To respond to legal process and related to legal proceedings, as well as for regulatory reporting and recordkeeping purposes (such as adverse event reporting and tracking or to ensure that we are not precluded from doing business with you).
• General business and operational support. To operate our business, consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and otherwise related to the administration and/or planning of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

Additional information about healthcare professionals. In addition to the purposes listed above, we use information of healthcare professionals for the following purposes:

• For the performance of our contract(s) with you if you or your institution entered into a consulting, professional services, or other type of agreement with us.
• Developing and improving our Services, including:
• managing and improving our relationship with you, including planning, organizing and reviewing any collaborations with you
• helping to ensure that we provide you with information that is relevant based on your expertise, interests, and preferences
• recruiting and evaluating your suitability for participation in our programs, including clinical trials, market research, and other research activities
• communicating with you regarding products and programs, engaging with you about scientific or educational programs, administering patient support programs, and providing access to you where applicable, responding to orders, and providing samples
• creating and maintaining our database of healthcare professionals, which may include publicly available information in connection with healthcare professionals
• Assessing grant requests and fellowship applications
• Complying with transparency reporting requirements and demonstrating adherence to industry codes of practice

We may also use personal information for other purposes which will be described at the time of collection.

Gilead processes personal information where it has a legal ground for doing so. Certain laws, such as the GDPR, UK data protection law, and similar laws, set forth specific legal grounds for our processing of personal information. Legal grounds for the processing of personal information under such laws include:

• The processing is in Gilead’s legitimate interest in providing you with access to our Services and programs
• The processing is necessary for the performance of a contract between you and Gilead
• The processing is necessary for the performance of a contract, concluded in your interest, between Gilead and a third party
• The processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests
• The processing is required by applicable law
• With your consent, as described in specific terms, privacy notices and/or consent forms where we collect your consent. Where Gilead relies on consent to process personal information, the opportunity to consent will be provided prior to the relevant processing of your personal information. Your consent may be given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney. Where Gilead relies on consent, you will be entitled to withdraw that consent at any time.

Generally, we disclose the personal information we collect as described in this section:

• Within our family of companies. In the normal course of performing Services, personal information may be shared within Gilead and its affiliates for purposes consistent with this Privacy Statement.
• With our service providers and partners. We may retain other companies and individuals to perform services on our behalf and we may collaborate with other companies and individuals with respect to the Services. Examples of service providers include data analysis firms, credit card processing companies, customer service and support providers, email and SMS vendors, web hosting and development companies, and fulfillment companies. Providers also include our co-promote partners for products and treatments that we jointly develop and/or market with other companies. Some providers may collect personal information on our behalf.
• Third party platforms, providers and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of our Services, or as necessary to respond to your requests. We may also make certain personal information (such as browsing information) available to third parties in support of our marketing, advertising, campaign management, and analytics purposes.
• In connection with business transactions. If we are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
• For product safety and adverse incident reporting. Gilead may share personal information related to product safety and adverse incidents with relevant national and/or international regulatory authorities, law enforcement, or public bodies or courts, where Gilead is required to by applicable laws, regulations, or at the request of those authorities.
• To comply with our general legal obligations. Gilead may disclose, without your prior permission, any personal information about you or your use of our Services if necessary to:
• protect and defend the rights, property or safety of Gilead and others;
• enforce the terms and conditions that apply to use of our Services;
• as required by a legally valid request from a competent governmental authority and/or to comply with a judicial proceeding, court order, or legal process;
• enhance product security and prosecute those who threaten product security; or
• respond to claims that any content violates the rights of third parties.

We may also disclose personal information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.

• Security and protection of rights. Where we believe necessary to investigate, detect, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of the terms of service and other agreements. We may also use certain information as evidence in litigation in which we are involved.
• Additional information about healthcare professionals. We may disclose personal information about healthcare professionals as disclosed below:
• For safety monitoring, reporting and auditing and responding to inquiries or issues in relation to our Services
• To comply with requirements imposed by industry codes of conduct, including the transfer of value data of healthcare professionals and the public disclosure of such data

We and our third-party providers use cookies, web beacons (also referred to as pixels or tags) and similar technologies within our Services to automatically collect information about the use of our Services. Cookies are small text files that are transferred to your computer or mobile device by a website. Web beacons are small files that are embedded into a webpage and can track users, similar to a cookie. The information collected by cookies, web beacons and similar tracking technologies varies depending on the website or Services being used, but may include non-identifying information, as well as personal information, such as details regarding the device or browser you are using, your IP address, the previous website you visited, the links you clicked, pages you visited and other usage and browsing activity.

We and our third-party providers use this information to analyze and understand how users access, use and interact with our content and Services, to identify and resolve bugs and errors, and to secure, protect, optimize and improve the performance of our Services (such as to enable language settings on a website). In addition, some of our websites and Services may include advertising and targeting cookies and tags that are used by us and third parties to personalize content and ads within the Services and to better target advertising on third party sites, mobile apps and online services. These third parties may combine the information collected via cookies, web beacons and similar technologies on our Services with similar information collected on third party sites, mobile apps and online services.

To learn more about the use cookies, web beacons and other tracking technologies, including targeting cookies and tags, on the Services, please see our Cookie Statement.

Managing Your Cookie Preferences. We make available several ways for you to manage your preferences regarding targeted advertising and cookies on our websites as described below:

• Cookie settings manager. You may exercise your right to opt-out online by clicking on the “Cookies Settings” link on the website cookie banner of the Gilead site you’re visiting. For further information about the data we may collect, please see our Cookie Statement.
• Browser settings. You can also adjust your browser settings to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors who disable cookies will be able to browse our websites, but some features may not function.
• Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your use of our websites and mobile apps, and those of third parties, in order to display more relevant targeted advertising to you. Users in Europe may obtain more information at the following links: youronlinechoices.eu (European Interactive Digital Advertising Alliance)

Custom Lists and Matching. We may also disclose or make available certain customer list information (such as your name, email address and other contact information) to third parties so that we can better target ads and content to you across third party sites, platforms and services. In some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns. You can opt out of this type of targeted advertising to you by submitting an opt out request to us as set forth in the “Your Privacy Rights and Choices” section below.

Aggregate Data and Non-identifiable Data

We may also use and disclose aggregate, anonymous, and other non-identifiable data, and in some cases de-identified data, related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in de-identified form and not attempt to reidentify the information, except in accordance with applicable laws.

Gilead operates all over the world. Therefore, we may need to transfer personal information outside of the country where it is collected for the purposes, and in the manner, set out in this Privacy Statement, including to servers and other storage facilities. To the extent that any personal information is sent outside of an individual’s country, it is subject to the laws of the country in which it is, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country, which may not provide an equivalent level of protection to the laws of your home country.

Gilead implements appropriate safeguards to protect personal information, such as entering into contracts that contain standard data protection clauses. Where Gilead has knowledge that a service provider or affiliate is using or disclosing personal information in a manner inconsistent with this Privacy Statement, Gilead will take appropriate steps to prevent or stop the use or disclosure. You can request a copy of the safeguards referenced in this section by contacting us as set forth in the “Contact Information” section below.

We retain the personal information we collect only as reasonably necessary for the purposes described in this Privacy Statement, in accordance with our records retention policies, as required under applicable law, or as otherwise disclosed to you at the time of collection. The criteria used to determine our retention periods includes: (i) the length of time we have an ongoing relationship with you; (ii) whether we have a legal obligation to retain the information; and (iii) whether retention is necessary due to the nature of our business activities (for example, enforcing other applicable program or participation terms and conditions, or any active litigation or regulatory investigations).

Gilead has implemented safeguards to protect the personal information we collect. However, we cannot guarantee that such measures are 100% effective at preventing theft, loss, unauthorized access, use or disclosure and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information. Gilead urges you to exercise caution when transmitting personal information over the internet and to store your passwords in a safe place.

You may have certain rights which depend on Gilead’s reason for processing your personal information, local laws, and exceptions to those laws in your jurisdiction, as described in this Section. In addition, residents of certain jurisdictions may be entitled to additional rights under the laws of those jurisdictions; please refer to the section titled, “Additional Privacy Information for Certain Jurisdictions” below for more information. We will not restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Services.

• Marketing communications and reminders: You may unsubscribe or opt-out from our marketing emails and future communications at any time by following the instructions included in those emails.
• Cookie preferences. You may exercise your consumer right to opt-out by clicking the “Cookies Settings” link on the website cookie banner of the Gilead site you’re visiting. For further information about the data we may collect, please see our Cookie Statement.
• Access, correction, and deletion. You may have the right under applicable law to review, correct, and request deletion of your personal information. You may submit a request to access, correct, and delete personal information, or another privacy request, through our web portals:
  Residents of the EEA/UK/Switzerland
  

You may also submit a request to us as set forth in the “Contact Information” section below. We will respond to your request as required by applicable law. When you submit a request regarding your personal information, we reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

To help us respond to your request, all communications to Gilead should include the sender’s name and contact information (such as email address, phone number or mailing address), and a detailed explanation of the request. In addition, communications related to Gilead websites should include, as applicable, the email address used for registration and the Gilead website address on which personal information was provided (e.g., www.gilead.com). Email requests to delete, amend, or correct personal information should include “Deletion Request” or “Amendment/Correction Request”, as applicable, in the subject line of the email. Gilead will endeavor to respond to all reasonable requests in a timely manner, and in any case, within any time limits prescribed by applicable local law.

Please note that Gilead may not be able to comply with a request where personal information has been destroyed, erased or made anonymous in accordance with Gilead’s record retention obligations and practices, or where we are unable to verify your identity.

Our Services are not targeted to children, and we do not knowingly collect personal information from children under 13 without parental consent. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. If you are a parent and you believe we have collected your child’s information, please contact us as set forth below in the “Contact Information” section.

Links to other websites, services, and applications that are not operated or controlled by Gilead (“Third-Party Services”) may be contained in our Services. This Privacy Statement does not apply to the Third-Party Services. Please review the applicable privacy statements of any Third-Party Services before providing any information to or through them.

Any questions, concerns, or complaints regarding handling of personal information by Gilead, or related to revocation of consent to collect, process, transfer, or disclose your personal information should be directed by email to [email protected].

You may also contact us by telephone at +1 (833) GILEAD2 (+1 (833) 445-3232), or by mail at the following address:
Gilead Sciences, Inc.
Attn: Privacy
333 Lakeside Drive
Foster City, CA 94404
USA

To submit a request relating to your privacy rights and choices, please use our web portal:

Residents of the EEA/UK/Switzerland

Gilead may update this Privacy Statement from time to time. Gilead will provide notice of such changes by updating the effective date listed on this Privacy Statement. If we materially change how we process your personal information previously collected by us, we will not use the personal information previously gathered without providing notice and/or obtaining your consent. Please check this Privacy Statement frequently for the latest information on our privacy practices.

Residents of certain jurisdictions may have additional rights and choices regarding the processing of their personal information, as described in the applicable Privacy Statement supplements.

If you are an EU/UK/Swiss citizen and/or accessing Gilead websites in the EEA, the UK or Switzerland, then this Supplement may apply in addition to the above.

EU, UK, and Swiss citizens generally have the following rights with respect to their personal information:

• The right to request access to the personal information that Gilead has about you;
• The right to rectify or correct any personal information that is inaccurate or incomplete;
• The right to request a copy of your personal information in electronic format so that you can transmit the data to third parties, or to request that Gilead directly transfer your information to third parties;
• The right to object to the processing of your personal information for marketing and other purposes;
• The right to erasure of your personal information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your personal information to certain limited purposes where erasure is not possible; and
• The right to withdraw consent at any time (where relevant)

Transfers of your personal information may be made to entities located outside the European Economic Area, United Kingdom, and/or Switzerland, including entities located in the United States, for processing consistent with the purposes above. Gilead will implement appropriate contractual measures (including the Standard Contractual Clauses, a copy of which you can obtain by contacting [email protected]) to ensure that the relevant Gilead companies and third parties outside the European Economic Area, United Kingdom, and/or Switzerland provide an adequate level of protection to your personal information as set out in this Privacy Statement and as required by applicable law.

For the processing of personal information relating to the EEA, UK, and/or Switzerland, Gilead has assigned a data protection officer responsible for overseeing our compliance with data protection law, whom you may contact at [email protected] in case of any questions or concerns regarding the processing of your personal information.

If Gilead’s processing of your personal information is covered by EU/UK/Swiss law, you may also lodge a complaint with the corresponding data protection supervisory authority in your country of residence.

You can find the relevant supervisory authority name and contact details under http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

You can find the contact details of the UK Commissioner under https://ico.org.uk.