Privacy Notice

This Privacy Notice sets out how the Patient Assistance Program run by GlaxoSmithKline, LLC and ViiV, PLC (collectively, the Patient Assistance Program,”) collects, uses, transfers, processes, and discloses your data and sets out our security practices. We respect your privacy and are committed to protecting your personal information.

When we say “The Patient Assistance Program”, “GSK”, “ViiV”, “we”, “us” or “our”, this is who we are referring to.

Please note, our privacy practices are subject to the applicable laws of the places in which we operate.

We may change this Privacy Notice from time to time. We encourage you to review this Privacy Notice periodically.

Specific State Resident’s Supplemental Notice: Please review our State Specific Resident’s Supplemental Notice (“Supplemental Notice”) at the end of this notice or by clicking this link. This notice applies to residents of California, Colorado, Connecticut, Utah and Virginia. This Supplemental Notice provides additional details about our privacy practices related to your personal information as required by the applicable U.S. Privacy Laws in your state of residence. Some portions of this Supplemental Notice apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents.

In this privacy notice, we explain:

• What personal information do we collect about you?
• How do we collect your personal information?
• How do we use your personal information?
• How do we use cookies and similar technologies?
• How long do we keep your personal information?
• With whom do we share your personal information?
• How do we protect your personal information?
• What are your rights and choices regarding your personal information?
• Our responsibility regarding websites that we do not own or control
• Information about children
• How we update this privacy notice?
• How to contact us?
• What is included under the Specific State Resident’s Supplemental Notice?

What personal information do we collect about you?

The personal information, including sensitive personal information, that we collect, and process/or disclose may include, both currently and in the preceding 12 months:

We and our service providers collect personal information in a variety of ways, including from

• business service providers.

We use your personal information for the purposes we have described below in this Privacy Notice, or for purposes which are reasonably compatible with the ones described.

To manage our relationship with you.

We will use your personal information:

• To respond to your requests;
• To improve our level of service;
• To provide our products and services to you;
• To promote our products and services;
• To manage your account, if necessary;
• To provide you with information when you request it
• To provide information when we believe it may be of interest to you;
• To invite you to provide your views on our products and services, participate in research or attend events;
• To report any product adverse events that you notify us about;
• To consider your application for employment;
• To perform analytics and understand your preferences;
• To create aggregated and anonymized or de-identified data;
• To provide access where required to our sites and facilities;
• To assist with sales compensation;
• To perform identity verification
• To detect and prevent fraud
• Exercise and defend legal claims
• To gain insights and feedback on our products and services in order to correct or improve them, by analyzing information from external sources such as Google, Facebook and Twitter (and others);
• For our own internal administrative and quality assurance purposes; and
• For other purposes that may be detailed on a website or mobile application which will be described at the time the information is collected.
• To manage and improve our processes and our business operations.

We will use your personal information to:

• Manage and protect our network and information systems security
• Project our equipment and facilities
• Conduct risk and security assurance measures
• Manage our workforce effectively;
• Prepare and perform management reporting and analysis, including analytics and metrics.

To achieve other purposes.

We will use your personal information:

• To follow applicable laws and regulations;
• To respond to lawful requests from competent public authorities;
• To tell you about changes to our terms, conditions and policies;
• To exercise or defend the Patient Assistance Program against potential, threatened or actual litigation;
• To detect fraud and risk
• To protect the Patient Assistance Program’s or your vital interests, or those of another person;
• To disclose any transfers of value made to you in relation to expert services that you provide to us;
• For the purpose of authorship of a scientific publication;
• To respond to and handle your queries or requests;
• To assist with product safety and recalls; and
• When we sell, assign or transfer all or part of our business.

Website and mobile application usage information

We also collect information about your computer browser type and operating system, websites you visited before and after visiting our websites, standard server log information, Internet Protocol (IP) addresses, location data, mobile phone service provider, and mobile phone operating system.

We use this information to understand how our visitors use our websites and mobile applications so that we can improve them, the services we offer, and our advertising. We may also share this information with other companies within the Patient Assistance Program group and with other third parties, including through the use of cookies and similar technologies, as discussed below.

Use of IP addresses

An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organization’s local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online.

The Patient Assistance Program, or third-party companies acting on our behalf, may collect IP addresses for the purposes of systems administration and to audit the use of our websites. We also may use IP addresses to identify users of our websites when we feel it is necessary to enforce compliance with the websites’ terms of use or to protect our service, websites or other users.

Our websites and mobile applications may use technology called “cookies” and similar technologies, such as web beacons (collectively “cookies”). A cookie is a small text file that is placed on your hard disk by a server. Cookies and similar technologies allow our websites and mobile applications to respond to you and provide a more personalized experience.

The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. For example, our server may set a cookie that keeps you from having to enter a password more than once during a visit to a website.

Our advertising partners also may use these technologies to display advertising tailored to your interests on other websites and services, although you have a number of choices as described further below. We are not responsible for the privacy practices of these advertising partners.

Cookies and Targeted Advertising Choices

In this section, we describe choices you have with respect to cookies, including those used for targeted advertising. Many of the choices you have are browser-based choices, which means they will apply only to the specific browser you use when you opt out or exercise the applicable choice. You will need to opt-out separately on all your browsers. In addition, if you delete cookies, change browsers, or use a different device, you may need to opt out or exercise your choice again.

Browser and Device Settings. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer. Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences, and note that your browser controls might not control other types of technologies. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If you choose to decline all cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit. Please check your device settings and mobile app permissions for additional information on how to opt out.

Do-Not-Track Signals, Global Privacy Control, and Similar Mechanisms. Some web browsers transmit "do-not-track" signals to websites. Because the “do-not track” browser-based standard signal has yet to gain widespread acceptance, we don’t currently respond to those signals. However, we support the Global Privacy Control in certain jurisdictions [such as California], as described below in the “Your Opt-Out Rights” section.

Your Opt-Out Rights. In accordance with applicable laws for your state (Please review the Supplemental Notice), you can opt out or withdraw consent of processing of your personal information for targeted advertising by:

• clicking the “Your Privacy Choices” link at the bottom of relevant web pages or within relevant apps and then toggling off targeting cookies; or
• broadcasting the Global Privacy Control, which the Patient Assistance Program supports in certain jurisdictions to facilitate state opt-out rights. The Global Privacy Control is a browser-based setting that communicates your preferences to opt out of processing for targeted advertising to online services that you visit. Please visit the Global Privacy Control website to learn more about the setting and how to enable it for each participating browser system that you use.

In addition, in accordance with applicable laws for your state, you may request to opt out or withdraw consent of any non-cookie based (i.e., offline) sharing of their personal information for targeted advertising by submitting a request via the form found at privacy.gsk.com/request and select US Laws and providing the requested information.

Please note that the Patient Assistance Program and its service providers may still use technologies for the Patient Assistance Program ’s advertising and other purposes in accordance with applicable laws.

Other Industry Choices. Some advertising partners may participate in an industry organization that offers users an opportunity to opt out of ad targeting. To learn more, including about how to opt out from interest-based advertising, please visit About Our Ads. You may download the AppChoices application at www.aboutads.info/appchoices to opt out in mobile apps. Due to the differences between using apps and websites on mobile devices, you also should check the settings for your apps and device to opt out. For more information about targeted advertising, please see the Network Advertising Initiative’s (NAI) opt out page.

Some of our websites may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of the website, including your IP address. More information on Google Analytics can be found here: https://policies.google.com/technologies/partner-sites. If you would like to opt-out of having your data used by Google Analytics, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/.

We keep your personal information for as long as needed or permitted for the purpose(s) described in this privacy policy and consistent with applicable law. In addition, we might keep the information for longer based on criteria such as applicable rules on statute of limitations, any legal requirements to retain your personal information in light of compliance obligations, any relevant litigation or regulatory investigations, and the duration of your use of our website and receipt of our services.

We share your personal information on a need-to-know basis, to the extent necessary to follow laws and regulations, and to manage the activities related to our relationship with you.

We share your personal information with teams in our companies and affiliates who need to see it to do their jobs. Please see this link for a list of our affiliates and their locations.

In some cases, our relationship with you is supported by specialized service providers working on our behalf. These service providers are contractually-required to protect your personal information and not to use it for their own purposes.

These specialized service providers include:

• advertising partners that provide us services;
• internet service providers;
• data analytics providers;
• operating systems and platforms;
• social networks;
• joint marketing partners; and
• research partners.

We will share your personal information with local or foreign regulators, or government and law enforcement authorities as necessary or appropriate, in particular when we have a legal obligation to do so. These may be in or outside your country of residence. We may also disclose your personal information for other legal reasons, such as to enforce our terms and conditions; and protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

We may share your personal information in connection with a sale or business transaction, such as a 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).

We may also share information with advertising partners as described in the section entitled “How do we use cookies and similar technologies?” and for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

The Patient Assistance Program will take appropriate legal, organizational, and technical measures to protect your personal information consistent with applicable privacy and data security laws.

Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the personal information you transmit to our websites or mobile applications: any transmission is at your own risk. While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to help prevent such unfortunate occurrences.
 

Data Subject Rights:

You may be entitled under applicable laws to request:

• That we provide you transparency about our privacy practices, including copies of your personal information that we process, subject to some exceptions;
• Provide portability of your information, subject to some exceptions;
• Correct information that is inaccurate or incomplete, subject to some exceptions; and
• Delete your personal information, subject to some exceptions.
• Where allowed in your jurisdiction, limit use of certain types of information, subject to some operational limitations which may require us to opt you out of the use of your information entirely
• Where allowed in your jurisdiction, the ability to opt out of the sale or sharing of your information.

To make a request or to express a privacy concern, you or your authorized agent should use our online webform available at: Individual Privacy Rights Request Self Service Webform. To appeal a request you feel was denied in error, please respond to the contact information provided in the response denying your request.

For additional contact information, please refer to the “Contact Information and Privacy Point of Contact” section.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do. We may need to request additional personal information from you, such as your home address, email address and government issued ID, in order to protect against fraudulent or spoofed requests. If you want to make a request as an authorized agent on behalf of an another individual under applicable law , you may use the submission methods noted in the “Contact Information and Privacy Point of Contact” section. As part of our verification process, we may request that you provide us with proof that you have been authorized by the individual on whose behalf you are making the request, which may include signed permission. If you object to us using your personal information or withdraw permission for us to use your personal information, after initially giving it to us, we will respect your choice in line with applicable law. While we will do our best to limit the ability such withdrawal has on our ability to provide you services and information you requested, some of the functionality and features available on our services may change or no longer be available to you.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on our websites and online services may change or no longer be available to you. Any difference in services are related to the value provided.

Separate from data subject rights afforded to you under applicable law, you may have commercial relationships with specific teams whom you may contact for information about matters relating to your relationship with those business teams, including: The Patient Assistance Program team.

From time to time, we may provide links to websites or mobile applications that are not allowed or controlled by us or embed third party websites or content or work with third parties to display advertising on third party websites or services. Our Privacy Notice does not cover them. Please read the privacy notices on those websites and mobile applications if you would like to find out how they collect, use and share your personal information.

Our services are not directed to those under 16 and we do not knowingly collect, sell, or share for targeted advertising any personal information from minors under 16 years of age.

From time to time, we will update this Privacy Notice. Any changes become effective when we post the revised Privacy Notice, although we may elect to otherwise notify you in some cases where changes are significant or where required by law. This Privacy Notice was last updated as of the "Last Updated" date shown above.

If you have any questions about this Privacy Notice, need more information or would like to raise a privacy concern, please contact us at US.CPA@gsk.com. If you want to correct the personal information we may have about you, or if you and want to exercise applicable rights granted by your jurisdiction regarding your personal information, please contact us at:

Online:
Use our online webform available at: privacy.gsk.com/request and select US Laws.

Telephone:
The Patient Assistance Program 1.888.825.5249
 

This Supplemental Notice provides additional details about our privacy practices related to your Personal Information as required by the applicable U.S. Privacy Laws in your state of residence. Some portions of this Supplemental Notice apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents

The following definitions apply in this Supplemental Notice

• “Consumers” means residents of California, Colorado, Connecticut, Utah and Virginia
• “Personal Information” means information of residents of that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information also includes “Sensitive Personal Information” that we specifically described in this Supplemental Notice.
• “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
• “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration.
• “Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us.
• “Vendor” means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by certain contractual obligations consistent with applicable laws to use your Personal Information only as directed by us.