1. Guiding Principles

In the normal course of business, SanKav Pharmaceuticals LLC (hereinafter “SanKav”) may collect personal information that it uses to help children, adults, and the elderly so that they lead healthy lives and have access to proper nutrition, medical services, treatments, and education regardless of their backgrounds, financial circumstances, and geographical locations. Below are principles that, at a high level, guide how SanKav conducts business ethically and in compliance with the applicable laws, regulations and industry standards.

 

2. Information Collection

 

2.1 Overview

A. In the normal course of business, SanKav collects or receives information from a range of sources. This information may be actively collected by SanKav or may be obtained inadvertently or in conjunction with other information.

 

2.2 How information is collected

A. SanKav may collect certain information automatically when individuals visit the SanKav website or other online service. This information includes:​

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i. Internet Protocol (IP) address, which is a number automatically assigned to a computer by an Internet Service Provider. Most websites on the internet collect IP addresses as a standard practice. Collection of IP addresses allows a website to determine website usage levels. SanKav websites may collect this information by using cookies. Many internet security services and software packages prevent cookies from attaching to a computer’s hard drive, thus preventing data collection.

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ii. Location Information may be collected from users who visit a SanKav website or use a SanKav technology application. This includes information from the IP address or that may be provided by the type of device an individual is using to access SanKav digital property.

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B. SanKav collects information that individuals provide to the company directly or through a third party, such as a market research organization. This information includes, but may not be limited to:

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i. Name, email address, street address, professional credentials, date of birth, and other personal information that an individual provides by uploading information to a SanKav website. This information may be uploaded in conjunction with an employment application, joining a Company sponsored competition, requesting additional information about products or services, or as part of an adverse event report.

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ii. Information provided as part of a patient assistance program.

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iii. Information collected during HCP, payer, patient, or other advisory board or consulting type activities.

 

iv. Details provided in correspondence with the Company about a product, concern or other topic.

 

3. Use of Information

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3.1 Overview

A. Information collected by SanKav that is de-identified may be used for any purpose not prohibited under applicable law or Company policy. SanKav respects the contribution that such information can make to improving the Company’s operational efficiency and clinical outcomes and recognizes the sensitivity around using personal information, even after it is de-identified.

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3.2 How Information is Used

A. In addition to using personal information for the specific purposes for which it was initially provided or collected, SanKav may use personal information for the following:

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i. Deliver targeted sales and marketing information related to the services an individual requested or about which he or she inquired.

 

ii. Advise individuals as to other products or services offered by SanKav. Marketing activities can be via telephone, email, or other channels as permitted by law. Individuals have the right to opt out of their personal information being used for marketing activities.

 

iii. Develop and administer speaker programs. This includes activities related to verifying speaker credentials, training, scheduling, advertising speaker events, processing honoraria, and reimbursing expenses.

 

iv. Conduct research and development activities by aggregating an individual’s de-identified information and analyzing to improve distribution and product channels.

 

v. As otherwise required under applicable law and SanKav policy.

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3.3 Data Retention

A. SanKav retains Personal Information described in this Policy for as long as necessary to satisfy the purpose for which it was originally collected or for which there is legitimate business, operational or clinical purpose. Data is retained pursuant to applicable law. Individuals may opt out of their Personal Information being collected by SanKav as described in Section 4.6 of this Policy.

 

B. It is the responsibility of the SanKav representative receiving the information to retain it in an appropriate way that satisfies all applicable laws and SanKav policies. Additional guidance should be sought from Legal Counsel as needed.

 

4. Children's Information

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4.1 Policy

A. SanKav does not knowingly solicit or collect information from children under the age of 13 years of age without the consent of a parent or legal guardian.

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B. SanKav Representatives receiving information from a patient advocacy organization or other external entity must ensure that any release authorizing SanKav to use information for a child under 18 years of age is signed by a parent or legal guardian.

 

5. Sharing of Information

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5.1 Overview

A. To better serve patients, caregivers and the larger Healthcare Community, SanKav may share personal information. Information sharing is limited to third parties with whom SanKav has established relationships or as mandated by law.

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5.2 How Information is Shared or Disclosed

A. Personal information may be shared with third parties that SanKav uses to administer and provide services on our behalf. These services include patient preauthorization, assisting in research and development activities, process management, etc.

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B. SanKav may share personal information with professional service individuals or firms retained by the company for routine or specific business purposes. These parties include, but are not limited to, legal counsel, auditing organizations and accountants.

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C. Information posted by individuals to an SanKav social media account or other interactive media account managed by SanKav or an authorized third party, may be shared with SanKav, friends or connections of the posting entity, other parties active on the media site, or other parties exposed to the content. Information shared on many websites and social media accounts is subjected to the hosting company’s own privacy policies.

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D. Personal information that SanKav obtains may be shared as part of business negotiations or transactions. Example of such sharing include information exchanged during asset valuation and due diligence associated with a proposed sale or divestiture.

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E. SanKav will share information as required by law or court order. This includes adverse event reporting and complying with subpoenas or lawful requests for information from appropriate government health organizations.

 

6. Opt-Out Option and Information Destruction

 

6.1 Overview

A. SanKav respects the choice of patients, stakeholders, or other parties to opt out of certain uses of their personal information.

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6.2 Policy

A. At any time, an individual may limit or opt out of allowing SanKav to collect or use his or her data or Personal information by contacting the Company.

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B. SanKav Representatives may include an opt out option on communication using or requesting personal information to the extent technically available. This opt out option may take the form of an “unsubscribe” button at the bottom of an email or a checkable box on a form as examples.

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C. Individuals who opt out of SanKav collecting or using Personal Information may continue to receive notification regarding products or services they purchased, such as invoices or delivery status updates.

 

7. Other Matters

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7.1 CALIFORNIA RESIDENTS

A. We do not sell personal data about California residents.

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B. During the past 12 months we may have engaged in delivering online advertising that was tailored to your interests, which might be deemed to be a sale of data under the California Consumer Privacy Act, but we did not disclose data that would identify you by name, address or phone number.

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7.2 Other Information

A. Cookies. Certain SanKav websites may use cookies, a small file placed on computer hard drives. Browser cookies may be refused by activating the appropriate setting on your browser. Certain website features may also use local stored objects (or flash cookies) to collect and store information about user preferences and navigation to, from and on SanKav websites. Users may be able to limit access to flash cookies with add-ons and other tools available online. However, limiting access to cookies may affect user experience and limit access to certain parts of our Websites. Unless you have adjusted your settings so that it will refuse cookies, certain SanKav websites may issue cookies during a visit to our websites.

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B. Web Beacons. Pages of SanKav Websites and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit SanKav, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Although the information SanKav collects automatically does not personally identify users, SanKav may link that information to information that does personally identify users that SanKav may otherwise collect as described in this policy.

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C. Third-party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements on Websites such as social media websites, are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information during the use of SanKav Websites. The information collected may be associated with user personal information or your online activities over time and across different websites and other online services. This information may be used to provide users with interest-based (behavioral) advertising or other targeted content. SanKav does not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible advertiser or content provider directly.

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i. Unless otherwise noted, SanKav presumes that individuals providing information on behalf of other individuals are permitted to do so.

 

ii. For further guidance on SanKav’s data and privacy practices and policies, please contact Legal Counsel.

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D. Unless otherwise noted, SanKav presumes that individuals providing information on behalf of other individuals are permitted to do so. If there are any questions about this Privacy Policy, please contact us by writing to the following address:

 

Sanjeev K. Gupta

SanKav Pharmaceuticals LLC

20 Newburgh Road

Washington Township, NJ 07840

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